A Publication of Pepper Hamilton LLP
Financial Services Alert
Federal Regulators Propose New Reporting Requirements for OTS-Regulated Savings Associations and Savings and Loan Holding Companies
Wednesday, February 09, 2011
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:
- 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.
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
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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