On February 3, 2011, the Office of Thrift Supervision (OTS), the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve Board (Fed) together announced proposed changes to reporting requirements for savings and loan holding companies.
The proposed changes, pursuant to the Dodd-Frank Act, include a change from quarterly Thrift Financial Reports to quarterly Consolidated Reports of Condition and Income, also known as Call Reports. Savings and loan associations and savings and loan companies are regulated by the OTS, but under the Dodd-Frank Act require the transfer of OTS functions to the OCC, FDIC, Fed and the new Bureau of Consumer Financial Protection created by the Dodd-Frank Act on July 21, 2011.
The proposed changes would:
If implemented, these proposed changes will mean uniform reporting systems and processes among all FDIC-insured banks and savings institutions and would make uniform all reporting requirements among all holding companies supervised by the Fed. Additionally, the OTS, OCC, FDIC, the Fed and the Bureau of Consumer Financial Protection would have a common set of reports for monitoring and evaluating financial conditions and trends.
Under the proposals, savings associations and their holding companies would continue their current reporting processes until the effective dates cited above. The agencies are requesting comment on the proposed changes within 60 days of their publication in the Federal Register, which is expected soon.
Frank A. Mayer, III and Andrew C. Maher
More Resources on the Dodd-Frank Act
For additional information, please visit Pepper's Financial Services Reform Resource Center.
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