Developments in Securities Regulation, Corporate Governance, Capital Markets, M&A and Other Topics of Interest. MORE

The federal bank and thrift regulatory agencies announced proposed changes to reporting requirements for savings associations and savings and loan holding companies regulated by the Office of Thrift Supervision, or OTS. 

The proposed changes include a change from quarterly Thrift Financial Reports to quarterly Consolidated Reports of Condition and Income, commonly known as Call Reports. 

The agencies — the OTS, the Office of the Comptroller of the Currency, or OCC, the Federal Deposit Insurance Corporation, or FDIC, and the Federal Reserve Board — are proposing the changes pursuant to the Dodd-Frank Act.  Provisions of the Dodd-Frank Act require the transfer of OTS functions to the OCC, the FDIC, the Federal Reserve Board and the Bureau of Consumer Financial Protection on July 21, 2011. 

Perceived benefits of the proposed changes include uniform reporting systems and processes among all FDIC-insured banks and savings institutions.  These changes also would make uniform all reporting requirements among all holding companies supervised by the Federal Reserve Board. Also, the agencies would have a common set of reports for monitoring and evaluating financial condition and trends. 

The proposed changes would:

  • Require savings associations to file quarterly Call Reports, beginning with the March 31, 2012 report date. Effective on that date, all schedules of the Thrift Financial Report (including Schedules CMR and HC) would be eliminated;
  • Require savings associations to file data through the Summary of Deposits with the FDIC, beginning with the June 30, 2011 report date. Effective on that date, the OTS’s Branch Office Survey would be eliminated;
  • End collection of monthly median cost of funds data from savings associations, effective January 31, 2012; the last cost of funds indices would be published as of December 31, 2011; and
  • Require savings and loan holding companies to file the same reports with the Federal Reserve that bank holding companies file, beginning with the March 31, 2012 report date.  

Under the proposals, savings associations and their holding companies would continue their current reporting processes until the effective dates cited above.

Check dodd-frank.com frequently for updates on the Dodd-Frank Act and other important securities law matters.