Emerging Issues
Bank Call Report
The FFIEC has proposed several changes to the Bank Call Report that would become effective with the 06/30/2023 filing.
- Schedule RI – Income Statement
- Non cash Income from negative Amortization on Closed-End Loans Secured by 1-4 Family Residential Properties – this would be deleted
- Schedule RC-C, Part I – Loans and Leases
Reverse Mortgages – the detailed line items for “Home Equity Conversion Mortgage (HECM) Reverse Mortgages” and “Proprietary Reverse Mortgages” would be combined into single line items as follows:
- Reverse Mortgages Outstanding That Are Held For Investment [15(a)] – this would include the information that was previously reported on 15(a)(1) and 15(a)(2).
- Estimated Number Of Reverse Mortgage Loan Referrals To Other Lenders During The Year From Whom Compensation Has Been Received For Services Performed In Connection With The Origination Of The Reverse Mortgages. [15(b)] – this would include the information that was previously reported on 15(b)(1) and 15(b)(2).
- Principal Amount Of Reverse Mortgage Originations That Have Been Sold During The Year. [15(c)] – this would include the information that was previously reported on 15(c)(1) and 15(c)(2).
Schedule RC-F – Other Assets
FDIC Loss – Sharing Indemnification Assets [Item RC-F-6(d)] – this would be deleted.
Schedule RC-N – Past Due & Nonaccrual Loans, Leases, & Other Assets
Loans & Leases Reported In Items 1 Through 8 Above That Are Covered By Loss- Sharing Agreements With The FDIC [Item RC-N-12] – this would be deleted along with sub-items 12(a)(1)(a) through 12(f).
Other Schedules that may have updates and Comment Deadline
RC – M Memoranda
SU – Supplemental Information
Comment Deadline – April 24, 2023
Reference: Federal Register: February 21, 2023; pp. 10644-10649
Compliance Questions & Answers
Question / EFTA
Does Regulation E require an error resolution log to be kept for tracking the date, amounts/liabilities, etc.?
Answer.
Keeping a log or spreadsheet is not specifically required by the regulation. However, Regulation E does require financial institutions to maintain some record of their compliance with its provisions. In addition, when auditors or examiners review an institutions Regulation E compliance, they usually ask for the log or other record of the Regulation E error resolution process.
