FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026

The FFIEC Call Report for the 30 September 2026 report date has to reach the FFIEC’s Central Data Repository (CDR) by Friday 30 October 2026. It is also the first quarter-end report since the OCC, the Federal Reserve Board and the FDIC brought their amended community bank leverage ratio (CBLR) rule into force on 1 July 2026. The rule lowers the CBLR requirement from 9 percent to 8 percent and lengthens the grace period from two quarters to four, so for a qualifying bank under $10 billion in total consolidated assets the September report is the first one where the new numbers decide how Schedule RC-R is completed.

The instruction books have not caught up. The FDIC’s current-quarter Call Report page, last updated on 2 October 2026, lists the September 30, 2026 versions of the FFIEC 031, FFIEC 041 and FFIEC 051 report forms and says the September 2026 instruction updates are still pending. Until they arrive, the page sends filers to the June 2026 instructions for the FFIEC 031 and 041 and the December 2025 instructions for the FFIEC 051. Both books still describe a CBLR of greater than 9 percent and a two-quarter grace period.

Which form a bank files this quarter was settled earlier: by its foreign offices, its capital category and its total assets at 30 June 2025, unless a new foreign office, a merger or a change in capital category moved it during 2026. What is left for September is a short list: the CBLR answer in Schedule RC-R, Part I, item 31.a, the brokered reciprocal deposit amounts under the amended reciprocal deposit exception, the semiannual items that drop out of a September report, the leverage buffer items that U.S. GSIB bank subsidiaries have reported on the FFIEC 031 since June, and a CDR submission that clears the published edits with signed attestations on file.

Related reading: FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period

Call Report dates around the 30 September 2026 report

• 29 April 2026: the CBLR final rule is published in the Federal Register at 91 FR 22973, after adoption by the three agencies on 23 April 2026.
• Wednesday 1 July 2026: the CBLR final rule takes effect.
• Wednesday 30 September 2026: report date. Balances are reported as of the close of business, which the instructions define as the bank’s own cut-off time for posting transactions to the general ledger that day; later adjusting entries that belong to the quarter are reported as if posted by that cut-off.
• 2 October 2026: latest update of the FDIC’s current-quarter page, listing the three September forms and marking the September instruction updates as pending.
• Friday 30 October 2026: CDR submission date, 30 calendar days after the report date. The data file must arrive with all corrections made and all edit explanations provided, and no extensions of time are granted.
• Wednesday 4 November 2026: the 35-calendar-day limit for a bank with more than one foreign office, other than a “shell” branch or an International Banking Facility (IBF).
• Thursday 31 December 2026: next report date, when the semiannual items return.
• Wednesday 31 March 2027: first report date for form changes triggered by total assets reported at 30 June 2026.

The 30 October date is a receipt deadline at the CDR, so the working deadline sits earlier. The General Instructions state that a file the CDR cannot process, or one the bank has not adequately validated, is rejected, and that a corrected resubmission arriving after the submission date may draw the penalties prescribed for late submission. The five extra days for multi-office banks come with a request attached: the instructions urge those banks to use them only if absolutely necessary.

Which banks file which FFIEC Call Report form

The Call Report is a mandatory collection under four statutes: 12 U.S.C. 161 for national banks, 12 U.S.C. 324 for state member banks, 12 U.S.C. 1817 for insured state nonmember commercial and savings banks, and 12 U.S.C. 1464 for federal and state savings associations. Under 12 U.S.C. 1817(a)(3), each insured depository institution makes four reports of condition a year to its appropriate federal banking agency, on dates selected jointly by the FDIC Chairman, the Comptroller of the Currency and the Chairman of the Federal Reserve Board. The agencies run the collection under three OMB control numbers: 1557-0081 (OCC), 7100-0036 (Board) and 3064-0052 (FDIC). Their December 2025 Paperwork Reduction Act notice counted 971 national banks and federal savings associations, 707 state member banks and 2,798 insured state nonmember banks and state savings associations as respondents.

Every national bank, state member bank, insured state nonmember bank and savings association files a consolidated Call Report, normally as of the close of business on the last calendar day of each quarter. Three facts pick the form: whether the bank has any “foreign” office, its total consolidated assets, and the capital standards that apply to it.

FFIEC 031: foreign offices, $100 billion, or advanced approaches

A bank of any size with a foreign office files the FFIEC 031, the report for a bank with domestic and foreign offices. The instructions define three kinds of foreign office: an IBF, a branch or consolidated subsidiary in a foreign country, and a majority-owned Edge or Agreement subsidiary. For a bank chartered and headquartered in the 50 states or the District of Columbia, a branch or consolidated subsidiary in Puerto Rico or a U.S. territory or possession also counts as foreign. A branch on a U.S. military facility abroad counts as domestic.

Domestic-only banks land on the FFIEC 031 in two further cases: when they are advanced approaches institutions, whatever their size, and when their total consolidated assets are $100 billion or more, including Category III banks of that size. The $100 billion test runs on total assets reported at 30 June each year and moves the bank to the 031 from the following March. The advanced approaches perimeter is wider than its name. The instructions’ footnote covers subsidiaries of U.S. GSIBs, Category II institutions (at least $700 billion in total consolidated assets, or at least $75 billion in cross-jurisdictional activity with at least $100 billion in total consolidated assets), subsidiaries of depository institutions or holding companies that use the advanced approaches, and institutions that elect them. A depository institution subsidiary of a U.S. GSIB therefore files the 031 even with domestic offices only.

FFIEC 041: domestic offices only, under $100 billion

The FFIEC 041 covers banks with domestic offices only and total consolidated assets under $100 billion, including Category III banks of that size and excluding advanced approaches institutions. The Category III point is easy to miss. Category III status attaches to depository institution subsidiaries of Category III groups, so a bank well under $100 billion can carry it, and that bank files the 041 with the additional Schedule RC-R items the instructions reserve for advanced approaches and Category III banks. It cannot use the 051.

FFIEC 051: eligibility, two exclusions and a supervisory override

A bank with domestic offices only and total assets under $5 billion is eligible for the FFIEC 051 unless it is an advanced approaches institution, is subject to Category III capital standards, or is a “large” or “highly complex” institution for deposit insurance assessment purposes under 12 CFR 327.8 and 327.16(f). Eligibility is measured on 30 June and applies from the following March. An eligible bank may choose the 041 instead.

The primary federal regulator, jointly with the state chartering authority where there is one, can also require an eligible bank to file the 041 based on supervisory needs. The instructions name the activities it may weigh, all areas where the 051 collects less: trading, derivatives, mortgage banking, fair value option usage, servicing, securitization and asset sales, and variable interest entities. The agencies say they anticipate making that call in a limited number of cases.

The three forms differ in depth more than in purpose. The FFIEC 031 and 041 share one instruction book covering Schedules RC and RC-A through RC-V (the Report of Condition) and RI and RI-A through RI-E (the Report of Income). The FFIEC 051 has its own book, drops several schedules and adds Schedule SU, which collects supplemental information on complex or specialized activities. The agencies’ December 2025 notice estimated the average quarterly burden at 86.25 hours for the 031, 55.56 for the 041 and 34.99 for the 051.

For readers who know the EU framework, I read the Call Report as FINREP-style balance-sheet and income data (see our FINREP reporting guide) plus a capital schedule, Schedule RC-R, in a single bank-level filing, with holding company data collected separately, for example on the FR Y-9C. At larger banking organizations the Call Report also sits next to Federal Reserve collections such as those covered in our FR 2052a reporting guide and our FR Y-14 reporting update.

Why a threshold crossed in 2026 leaves the September form alone

The instructions state that institutions are expected to file the same report form, either the FFIEC 051 or the FFIEC 041, for each quarterly report date in a given year. Asset-based form changes follow the June test: total assets at 30 June 2026 decide eligibility from the March 2027 report. A bank on the 051 that reported $5.2 billion at 30 June 2026 therefore keeps filing the 051 for September and December 2026, assuming nothing else changes, and moves to the 041 with the 31 March 2027 report. The same timing governs the detail thresholds inside each form, such as the $1 billion and $10 billion items, which start with the March report after the June in which the bank first crossed them and stop only after four consecutive quarters below the line.

Four events override the calendar and change the form for the first quarterly report date after they happen:

• A bank with domestic offices only establishes or acquires a foreign office. It files the FFIEC 031 for the first quarterly report date following the start of operations at that office. A bank that divests all its foreign offices stays on the 031 through the end of the calendar year in which those operations ceased.
• A business combination, a transaction between entities under common control, or a branch acquisition that is not a business combination. The resulting institution files the 031 if it acquires a foreign office or reaches $100 billion in total consolidated assets, and picks up any additional items whose thresholds it now passes.
• An FFIEC 051 filer becomes an advanced approaches institution. It moves to the 031.
• An FFIEC 051 filer becomes a Category III institution, or a large or highly complex institution for deposit insurance purposes. It moves to the 041, or to the 031 if it also opens or acquires a foreign office in the same quarter.

For a bank already filing, a September form change therefore comes from one of those events in the third quarter, or from a supervisory direction to move from the 051 to the 041. A merger that closed in August is the case to check first, because it can move both the form and the threshold-driven items at once.

The community bank leverage ratio on the September Call Report

The CBLR final rule amends 12 CFR 3.12 (OCC), 12 CFR 217.12 (Board) and 12 CFR 324.12 (FDIC). For a qualifying community banking organization that has opted in, the rule now requires a leverage ratio of greater than 8 percent in place of greater than 9 percent. A bank that stops meeting any qualifying criterion gets a grace period of four reporting periods under its Call Report, provided its leverage ratio stays above 7 percent. At 7 percent or less, the bank must comply with the risk-based capital requirements for the quarter in which it reports that ratio. A bank that has spent eight or more of the previous twenty quarters in the grace period cannot use it in the current quarter. A bank that stops qualifying because of a merger or acquisition gets no grace period for the quarter in which the transaction occurs.

The other qualifying criteria did not change: total consolidated assets under $10 billion, no advanced approaches status, trading assets plus trading liabilities of 5 percent or less of total consolidated assets, and off-balance sheet exposures of 25 percent or less, excluding derivatives other than sold credit derivatives and excluding unconditionally cancellable commitments. The rule’s own baseline shows how many banks the new calibration touches. Using 30 June 2025 Call Reports, the agencies counted 4,241 depository institutions inside the size and simplicity thresholds, 3,638 of them with a leverage ratio above 9 percent, and 1,693 of those qualifying banks actually in the framework, 47 percent. They estimate that 2,039 depository institutions would adopt the framework at 8 percent, an increase of 323, and call the estimate imprecise.

What the instruction books still say

The Schedule RC-R general instructions in the June 2026 FFIEC 031 and 041 book still describe a CBLR of greater than 9 percent “in calendar year 2022 and thereafter”, a two-quarter grace period, and a floor of one percentage point below the requirement, together with the 2021 and 2022 transition table. The FFIEC 051 RC-R instructions in use carry the same wording. The June 2026 supplemental instructions added a “Community Bank Leverage Ratio” topic recording the 23 April adoption, the 1 July effective date and the Federal Register citation.

The final rule explains the lag. In its Paperwork Reduction Act section, the agencies say the rule creates no new collection of information but needs clarifications to the Call Report instructions (FFIEC 031, 041 and 051), which they plan to address separately through the FFIEC. Elsewhere the rule says those clarifications are not expected to affect the items that CBLR banks are required to report. I read that as follows for a 30 September 2026 report date: the amended regulation supplies the percentages (greater than 8 percent, a grace floor above 7 percent, four quarters, the eight-of-twenty limit), and the RC-R line items and mechanics stay as printed. That is my interpretation of how the rule and the pending instructions fit together, and a bank in doubt can put the question to its primary federal regulator, which the General Instructions name as the channel for interpretations, with referral to the FFIEC’s Task Force on Reports.

Answering item 31.a and completing items 32 through 38.c

Item 31 is the leverage ratio itself: item 26 (tier 1 capital) divided by item 30, reported as a percentage to four decimal places. Item 31.a asks whether the bank has a CBLR framework election in effect as of the quarter-end report date, answered “1” or “0”. A bank that answers “1” completes items 32 through 37 and, where applicable, items 38.a through 38.c, and leaves the rest of the risk-based reporting alone: on the FFIEC 031 and 041 it skips Part I items 39 through 55.b, on the FFIEC 051 items 39 through 54, and on all three forms the whole of Part II.

The qualifying tests sit in specific lines. Item 32 is total assets from Schedule RC, item 12, which must be under $10 billion. Item 33 adds trading assets and trading liabilities without netting them, with column B as a percentage of total assets that must be 5 percent or less. Item 34 builds the off-balance sheet total from the unused portion of conditionally cancellable commitments, securities lent and borrowed, and other exposures such as financial and performance standby letters of credit, sold credit protection and off-balance sheet securitization exposures; item 34.d, column B, must be 25 percent or less. Unconditionally cancellable commitments go to item 35 and stay out of that test.

The election runs through the report. The compliance guide revised in July 2026 and published with FIL-43-2026 says a qualifying bank opts in by completing the associated reporting line items and opts out by completing the risk-based reporting instead, and the RC-R instructions add that the primary federal supervisor may disallow the framework based on its evaluation of the bank’s risk profile. A bank with a leverage ratio above 8 percent and at or below 9 percent that meets the other criteria can therefore make its first election on the September report through item 31.a. The guide also allows an opt-out between reporting periods, by giving the regulators the risk-based capital ratios at that time.

Grace quarters now need a twenty-quarter record

The grace period begins at the end of the quarter in which the bank stops meeting a criterion. The rule’s own example: a breach on 15 February that persists to quarter-end makes 31 March grace quarter one, and 30 June, 30 September and 31 December quarters two to four; unless the bank meets every criterion again by then, it reports under the risk-based framework from the following 31 March. A breach can come from any criterion, so a bank whose off-balance sheet exposures pass 25 percent enters the grace period even with a leverage ratio comfortably above 8 percent.

The eight-of-twenty limit is where record-keeping changes. A quarter counts as grace usage each time the bank does not meet the qualifying definition at quarter-end. The rule counts usage from before 1 July 2026, judged against the CBLR requirement in force at each quarter-end, including the 2021 quarters when it stood at 8.5 percent. For the 30 September 2026 quarter the window is the twenty quarters from the third quarter of 2021 to the second quarter of 2026. According to the compliance guide, quarters in which the bank chose not to use the framework do not count, while grace quarters used earlier in the window still count after an exit and a later return. After a merger, only the surviving entity’s history counts, and the acquired bank’s grace usage is disregarded.

A bank that was already in a grace period on 1 July 2026 has a specific question: how many quarters its current grace period now runs. The final rule’s lookback footnote covers earlier usage toward the limit. The rule leaves Call Report instruction clarifications to the FFIEC, and the FDIC page still showed the September 2026 instruction updates as pending on 2 October, so until an update addresses a running grace period, the question goes to the primary federal regulator.

What a September Call Report leaves out

September is a quarterly-only report for a set of items that the instructions collect semiannually, in June and December, or annually. A blank in one of those items in a September file is the instruction working as written. On the FFIEC 031 and 041, the semiannual list includes Schedule RC-B, Memorandum item 3 on held-to-maturity securities sold or transferred; the negative amortization mortgage items in Schedule RC-C, Part I, Memorandum items 8.a to 8.c and Schedule RI, Memorandum item 12; Schedule RC-C, Part I, Memorandum item 12 on loans acquired in business combinations; the credit card line and merchant sales items in Schedule RC-L; and Schedule RC-N, Memorandum items 7 and 8 on nonaccrual asset additions and sales.

The FFIEC 051 list is longer, and one entry matters more than the rest. Schedule RC-R, Part II, items 1 through 25, the risk-weighting of assets and other exposures, are completed in the June and December reports only, while items 26 through 31, which run from the risk-weighted assets base to total risk-weighted assets, stay quarterly. A risk-based 051 filer therefore reports its risk-weighted assets total in September without the line-by-line build behind it. The 051 also defers Schedule RC-C, Part II on loans to small businesses and small farms, the components of other assets and other liabilities in Schedules RC-F and RC-G, and, for banks with $1 billion or more in total assets, Schedule RI-C on the disaggregated allowance for credit losses.

Annual December items and the March-only Schedule RC, Memorandum items 1 and 2 on external audit work and fiscal year-end are absent too. Fiduciary data in Schedule RC-T follows its own trigger, and the tiers differ by form. On the FFIEC 031 and 041, banks with total fiduciary assets above $250 million, or gross fiduciary income above 10 percent of revenue, complete the applicable items quarterly, and other banks with fiduciary powers complete them annually in December. On the FFIEC 051, quarterly reporting applies above $1 billion in fiduciary assets or on the income test, banks above $250 million and up to $1 billion that miss the income test report semiannually in June and December, and the remaining banks report annually in December. On every form, Schedule RC-T, items 23 through 26 and Memorandum items 1, 2 and 4 are December-only, even for banks in the quarterly tier, so those lines are blank in a September report.

FFIEC 031 leverage buffer items for GSIB bank subsidiaries

Two lines were added to the FFIEC 031 with effect from the 30 June 2026 report date, and September is the second report to carry them. Schedule RC-R, Part I, item 56.a, “Leverage buffer standard”, and item 56.b, “Leverage buffer”, are completed only by depository institution subsidiaries of U.S. GSIBs. They follow the agencies’ capital final rule published on 1 December 2025, which changed the enhanced supplementary leverage ratio standard for those banks to a buffer standard equal to 50 percent of the parent GSIB’s method 1 surcharge, capped at one percent. That rule took effect on 1 April 2026, with early adoption allowed from 1 January 2026.

Item 56.b is mechanical: the supplementary leverage ratio in item 55.b less 3.0000 percent, reported as zero if the result is negative. FIL-57-2025, which announced the final reporting change, says the FFIEC 041 and 051 are being extended for three years without revision, so the leverage buffer items exist only on the 031.

Brokered reciprocal deposits under the Housing Act

A statutory change to the reciprocal deposit exception also reaches the September report ahead of the instruction books. Section 902 of the 21st Century ROAD to Housing Act, effective 11 July 2026, amended the exception in section 29(i) of the Federal Deposit Insurance Act. The general cap, previously the lesser of $5 billion or 20 percent of the agent institution’s total liabilities, became a tiered share of total liabilities with a $30 billion maximum. In the agent institution definition, the Housing Act replaced the “outstanding or good” composite condition test in the first prong, which the FDIC had interpreted as a CAMELS composite rating of 1 or 2, with a CAMELS composite rating of 1, 2 or 3, and kept the well capitalized condition. The FDIC conformed its brokered deposit rule in 12 CFR 337.6 through an interim final rule published and effective on 1 September 2026 (91 FR 56022).

The interim final rule says the FFIEC will issue supplemental instructions as part of the September 30, 2026 Call Report instructions on reporting brokered and reciprocal deposits under the new law, and that no new line items are needed. On 28 September 2026 OMB gave emergency approval to the agencies’ revision of Call Reports submitted on or after 30 September 2026, which conforms the instructions for Schedule RC-E, Memorandum item 1.b, “Total brokered deposits”, and Schedule RC-O, item 9, “Brokered reciprocal deposits”, to the statutory and regulatory definition of a brokered reciprocal deposit. The interim final rule also says a bank should generally determine whether it qualifies as an agent institution as of the quarter-end, and that an institution that no longer qualifies must report all of its reciprocal deposits as brokered reciprocal deposits in Schedule RC-O, item 9.

Accounting topics in the latest supplemental instructions

The FDIC’s September page listed no supplemental instructions as of its 2 October update, which leaves the June 2026 edition as the latest. Three of its topics bear on a third-quarter close.

The FDIC special assessment. Banks subject to it account for it under ASC Subtopic 450-20, accruing the estimate as a liability in Schedule RC-G, item 1.b, and as an expense in Schedule RI, item 7.d, with the amount also shown in Schedule RI-E, item 2.g. The supplemental instructions tell banks to adjust earlier accruals for later FDIC notifications, including the update on the eighth quarterly collection delivered through invoices due on 30 March 2026. The FDIC’s interim final rule of 16 December 2025 (90 FR 59369) reduced the rate for that eighth collection quarter, removed the extended assessment period and provided for an offset against regular assessments if collections exceed losses once the litigation with SVB Financial Trust is resolved.

Purchased seasoned loans under ASU 2025-08. The standard takes effect for annual periods beginning after 15 December 2026, with early adoption permitted. An early adopter reports the initial allowance for credit losses recognised on purchased seasoned loans in Schedule RI-E, item 6.a, the same line used for purchased credit-deteriorated assets, and checks that the Schedule RC-R amounts follow the capital rules.

Transfers from available-for-sale to held-to-maturity. Classification is reassessed at each reporting date, in line with the quarterly Call Report dates, and a transfer is recorded on the date it happens. The supplemental instructions call it inappropriate to amend a previously submitted Call Report to report a debt security retroactively in another category when the transfer was not documented with evidence of the actual transfer date. An amendment cannot repair a missing transfer memo, so the documentation has to exist at the September close.

The same edition lists ASU 2025-06 on internal-use software, ASU 2025-09 on hedge accounting and ASU 2025-10 on government grants, with effective dates from annual periods beginning after 15 December 2026 onward depending on the standard and the entity type, and says the Call Report instructions will be revised to conform at a future date.

Submitting the Call Report through the CDR

The CDR is the only accepted channel. A bank either uses software to prepare, edit and submit its data directly, or completes a paper report and has a software vendor or another party convert and submit it. Filing a paper report directly with the FDIC or a Federal Reserve Bank is not an acceptable method. Software must meet the CDR’s technical specifications. The General Instructions say vendors whose software has passed CDR testing are listed in each quarter’s Financial Institution Letter, the June 2026 supplemental instructions point to the CDR Help Desk for vendor information, and a bank may also build its own software and test it with the CDR.

Before the deadline the file has to pass the FFIEC-published validation criteria, which the instructions split into validity edits and quality edits and which are published ahead of each quarter-end. The General Instructions require a report that passes those criteria or contains explanations for any quality edits it does not pass, prepared in line with the FFIEC’s “Guidelines for Resolving Edits”. The bank stays responsible for the accuracy of the data whichever route it uses, and the instructions say that responsibility cannot be transferred to software vendors, servicers or others outside the bank.

Late or inaccurate filing carries statutory penalties. For insured state nonmember banks, 12 U.S.C. 1817(a)(1) sets three tiers of per-day penalties: the lowest for a bank that keeps procedures reasonably adapted to avoid inadvertent error and still misses a deadline or files false or misleading information as a result of such an error, or that inadvertently files a report minimally late; a higher tier for other late or inaccurate reports; and the highest where false or misleading information is submitted knowingly or with reckless disregard for its accuracy, capped at the lesser of a fixed dollar amount or 1 percent of total assets per day.

The signature page has two parts. The chief financial officer, or the person performing an equivalent function, signs a declaration attesting to the correctness of the reports. Directors other than that officer attest as well: at least three for national banks, state member banks and savings associations, and at least two for state nonmember banks. Electronic signatures are allowed if the process meets the instructions’ principles, which include associating the signature with a full version of the report and recording the date of signing so that it can be shown to precede submission.

The bank keeps in its files a signed and attested record of each quarter’s report, as a printout showing each caption and amount, a computer-generated facsimile or a copy of the form, with the signed cover page attached. The General Instructions set retention at three years after the report date, with workpapers and supporting documentation, unless state requirements are longer, tying the period to section 7(b)(4) of the Federal Deposit Insurance Act. The CDR Help Desk, reachable at (888) CDR-3111 or cdr.help@cdr.ffiec.gov, handles accounts, passwords and system issues from 9:00 a.m. to 8:00 p.m. Eastern Time, Monday to Friday.

After filing: public data, confidential treatment and amendments

Call Report data go public quickly. The instructions say all schedules, including the optional narrative statement, are available to the public apart from listed exceptions, and that individual bank data are posted on the CDR’s Public Data Distribution site as soon as they have been submitted, accepted and prepared for publication. The exceptions include the FDIC deposit insurance assessment amount in Schedule RI-E, item 2.g, the assessment-related data in Schedule RC-O, Memorandum items 6 through 9, 14 and 15, and the probability of default data in Schedule RC-O, Memorandum item 18. The revision OMB approved on 28 September 2026 adds a confidentiality exception for the brokered reciprocal deposit amounts reported in Schedule RC-O, items 9 and 9.a, for Call Reports submitted on or after 30 September 2026.

A bank that wants other items withheld has to ask in writing before it submits the report, identifying the items, justifying the request and showing the specific harm that public release would cause. The instructions add that merely stating competitive harm is not sufficient and that approval comes only in certain limited circumstances.

Amendments follow two tests in the General Instructions. The primary federal supervisor may require an amended report where a previously submitted report contains significant classification errors, meaning an item reported on the wrong line, or errors in recognition and measurement that are material for the bank, with materiality read through FASB Concepts Statement No. 8. A revised file goes to the CDR through the same process as the original and has to pass the published validation criteria again. Where the supervisor’s reading of the instructions differs from the bank’s, the supervisor can require the report to follow its interpretation and require earlier reports to be amended.

Frequently Asked Questions

We opened an International Banking Facility in August 2026 and have no other foreign office. Which form and which deadline apply for 30 September?

An IBF is a foreign office under the Call Report instructions, so the bank files the FFIEC 031 from the first quarterly report date after the IBF started operating, which is 30 September 2026. The 35-day window does not follow, because it is reserved for banks with more than one foreign office other than a shell branch or an IBF. The submission date stays Friday 30 October.

Our holding company has opted into the CBLR on the FR Y-9C. Does the bank have to make the same election on its Call Report?

No. The CBLR final rule states that banking organizations within a consolidated group may make different elections, and that a qualifying organization can adopt the framework regardless of what an affiliate depository institution or the holding company does. The bank’s election is made in its own Schedule RC-R, item 31.a, and the holding company’s on its FR Y-9C where that report applies.

Can an FFIEC 051 filer switch to the FFIEC 041 for the September report?

An eligible bank may choose the 041, but the instructions expect the same form, either the 051 or the 041, for every quarterly report date in a given year. My reading is that a voluntary move would therefore normally start with a March report. A switch in mid-year outside the event-driven cases in the General Instructions is a question to raise with the primary federal regulator before the filing, since that regulator also decides interpretation questions.

A quality edit fails because a balance genuinely moved sharply this quarter. Does the number have to change?

No. A quality edit can stay unpassed if it is explained; the General Instructions require a report that passes the validity and quality edits or contains explanations for quality edits it does not pass. The explanation has to be in the file by the submission date, consistent with the FFIEC’s “Guidelines for Resolving Edits”, because the CDR deadline applies to the data with all explanations provided.

Our bank newly qualifies under the new CBLR threshold, with a leverage ratio greater than 8 percent. Does opting in need a separate notice to the regulator?

The compliance guide describes the opt-in as completing the associated reporting line items on the Call Report. In Schedule RC-R that means entering “1” in item 31.a and completing items 32 through 37, plus items 38.a to 38.c where they apply. The primary federal supervisor keeps the power to disallow the framework based on the bank’s risk profile.

Do we still have to publish the balance sheet in a local newspaper?

There is no federal requirement to publish the Report of Condition balance sheet in a newspaper. The General Instructions tell state-chartered banks to check with their state banking authority about any state publication requirement, and the same instructions point state banks to their state supervisor for any requirement to send copies of the Call Report filed with the federal agencies.

The September instruction update may be posted after we file. Do we refile if it changes something?

The FDIC page directs filers to the June 2026 (FFIEC 031 and 041) and December 2025 (FFIEC 051) books until the update is complete, and the CBLR final rule says the planned clarifications are not expected to affect the items CBLR banks report. The reciprocal deposit change is another matter, because the FDIC’s interim final rule says the September 2026 supplemental instructions will cover reporting brokered and reciprocal deposits under the new law, which bears on Schedule RC-E, Memorandum item 1.b, and Schedule RC-O, item 9. An amendment becomes necessary only on the General Instructions’ own tests, a significant classification error or a material recognition or measurement error, or where the primary federal supervisor requires one.

Related Articles

• FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period: how the Federal Reserve’s September 2026 FR Y-9C instructions carry the same CBLR change for holding companies.
• FR Y-14 Reporting: April 30 Deadline, New Fields and a 2027 Proposal: the capital planning and stress testing schedules filed by larger US holding companies.
• FR 2052a Reporting: Complex Institution Liquidity Monitoring Report: who files the Federal Reserve’s liquidity monitoring report, its tables and its daily and monthly clocks.
• FINREP Reporting Explained: the EU’s supervisory financial reporting framework, useful for comparing structure with the US Call Report.
• COREP Reporting Explained: the EU’s capital reporting templates, the closest European counterpart to Schedule RC-R.

Key Takeaways

• Book the CDR upload for well before Friday 30 October 2026; a rejected file resubmitted after that date counts as late, and only banks with more than one non-shell, non-IBF foreign office get until Wednesday 4 November.
• Test item 31.a against a leverage ratio of greater than 8 percent for 30 September 2026, even though the June 2026 and December 2025 instruction books in use still print 9 percent.
• Build the grace-quarter log now: twenty quarter-ends from the third quarter of 2021, each marked against the CBLR requirement in force on that date, including 8.5 percent for 2021.
• Check for a foreign office opened or a merger closed in the third quarter; either can move the September form, while a June 2026 asset figure only moves it from March 2027.
• Expect an FFIEC 051 risk-based filer to report Schedule RC-R, Part II items 26 through 31 in September without the items 1 through 25 detail, which returns in December.
• Confirm that every quality edit left open carries an explanation and that the signed cover page, with at least three director attestations (at least two for state nonmember banks) plus the CFO declaration, is on file before submission.
• Locate the transfer documentation for any securities moved from available-for-sale to held-to-maturity this quarter before the books close; an amendment cannot backdate it.

Sources and References

• FDIC, Current Quarter Call Report Forms, Instructions, and Related Materials (September 30, 2026 forms; instruction updates pending; page updated 2 October 2026): fdic.gov current-quarter Call Report materials
• FFIEC 031, FFIEC 041 and FFIEC 051 reporting forms for the September 30, 2026 report date, as listed on the FDIC page: FFIEC 031 (PDF), FFIEC 041 (PDF), FFIEC 051 (PDF)
• FFIEC 051 Call Report instructions, General Instructions, December 2025: fdic.gov FFIEC 051 General Instructions (PDF)
• FFIEC 031 and 041 Call Report instructions, General Instructions (FDIC-hosted 2024 edition): fdic.gov FFIEC 031 and 041 General Instructions (PDF)
• FFIEC 031 and 041 Call Report instructions, Schedule RC-R, Part I, June 2026: fdic.gov Schedule RC-R Part I, June 2026 (PDF)
• FFIEC 051 Call Report instructions, Schedule RC-R, Part I and Part II: fdic.gov FFIEC 051 Schedule RC-R Part I (PDF) and FFIEC 051 Schedule RC-R Part II (PDF)
• FFIEC 031 and 041 Call Report instructions, Schedule RC-T, Fiduciary and Related Services (item 3 sets the reporting frequency for each group of items): fdic.gov FFIEC 031 and 041 Schedule RC-T (PDF)
• FFIEC 051 Call Report instructions, Schedule RC-T, Fiduciary and Related Services (item 3 sets the quarterly, semiannual and annual reporting tiers): fdic.gov FFIEC 051 Schedule RC-T (PDF)
• FFIEC, Supplemental Instructions, June 2026 Call Report Materials (attachment to FIL-33-2026; also the source for the FDIC interim final rule of 16 December 2025, 90 FR 59369, and the special assessment accounting): fdic.gov Supplemental Instructions June 2026 (PDF)
• FDIC, FIL-33-2026, Consolidated Reports of Condition and Income for Second Quarter 2026, 2 July 2026: fdic.gov FIL-33-2026
• OCC, Board of Governors of the Federal Reserve System and FDIC, Regulatory Capital Rule: Community Bank Leverage Ratio Framework, final rule, 91 FR 22973, 29 April 2026, effective 1 July 2026: federalregister.gov FR Doc. 2026-08298 and FDIC copy of the final rule (PDF)
• FDIC, FIL-19-2026, Final Rule on Revisions to the Community Bank Leverage Ratio (CBLR) Framework, 23 April 2026: fdic.gov FIL-19-2026
• FDIC, FIL-43-2026, Community Bank Leverage Ratio Framework: Community Bank Compliance Guide Update, 30 July 2026, and the guide revised July 2026: fdic.gov FIL-43-2026 and CBLR compliance guide (PDF)
• FDIC, Reciprocal Deposits: Implementing the 21st Century ROAD to Housing Act, interim final rule, 91 FR 56022, published and effective 1 September 2026 (section III.C covers Call Report changes): federalregister.gov FR Doc. 2026-17865 and govinfo.gov FR Doc. 2026-17865 (PDF)
• OMB, emergency approval of the Call Report revision for brokered reciprocal deposits, 28 September 2026 (OMB control numbers 3064-0052, 1557-0081 and 7100-0036): reginfo.gov ICR 202609-3064-009 (FDIC), reginfo.gov ICR 202609-1557-002 (OCC) and reginfo.gov ICR 202609-7100-003 (Board)
• 12 CFR Part 324 (FDIC capital rule), annual edition, including section 324.12 before the 2026 amendments: govinfo.gov 12 CFR Part 324 (PDF)
• OCC, Board and FDIC, Proposed Agency Information Collection Activities; Comment Request (Call Report), Federal Register Vol. 90, No. 236, 11 December 2025, FR Doc. 2025-22481: govinfo.gov FR Doc. 2025-22481 (PDF)
• FDIC, FIL-57-2025, Revisions to the Consolidated Reports of Condition and Income (Call Reports), 12 December 2025: fdic.gov FIL-57-2025
• 12 U.S.C. 1817 (Federal Deposit Insurance Act section 7), reports of condition and penalties: govinfo.gov 12 U.S.C. 1817
• FFIEC Central Data Repository: cdr.ffiec.gov/cdr and Public Data Distribution: cdr.ffiec.gov/public

Before the 30 October CDR deadline

For a bank under $10 billion, the CBLR judgment that changed this quarter is the item 31.a answer under the 8 percent rule. Three things need an owner before the file goes to the CDR: a leverage ratio and qualifying-criteria test for 30 September run against the amended rule, a twenty-quarter grace log from the third quarter of 2021, and a check that no foreign office or merger in the quarter has moved the bank to a different form. A bank that uses reciprocal deposits adds a fourth: the quarter-end agent institution check behind its brokered amounts in Schedule RC-E, Memorandum item 1.b, and Schedule RC-O, item 9. Then submit early enough that a rejected file can be fixed and resent by Friday 30 October 2026.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.