Published December 9, 2013 | December 2013 issue
Each year, some Ninth District depository institutions find out that they must file deposit data on a new schedule or report form. It may not be clear to the institution why this change occurs. This article summarizes the Federal Reserve System’s process for identifying which institutions must change their deposit reporting schedule.
The Depository Institutions Deregulation and Monetary Control Act of 1980 authorized the Federal Reserve System to impose reserve requirements on all depository institutions and to collect data used to calculate those requirements. The Garn-St. Germain Depository Institutions Act of 1982 required that institutions with a reserve requirement of 0 percent be subjected to less overall reporting than other institutions. This act also implemented the annual indexing of reporting and reserve requirement thresholds so that smaller institutions can grow their deposit base while maintaining their eligibility for reduced reporting.
To carry out its responsibilities under these acts, the Federal Reserve System conducts an annual two-phase review in which staff compare available deposit data to the annually indexed reporting thresholds to determine each institution’s filing requirement (weekly, quarterly, annually or nonreporter).1
The first phase of the review occurs in March through June. Staff use total deposit data from the previous December’s Call Report to identify which current nonreporters should file the annual report as of June 30 and which institutions that filed the annual report in the previous year should become nonreporters.2
The second phase of the review occurs in July and encompasses weekly, quarterly and annually filed deposit data to determine the reporting status for each institution that would begin in September. An institution’s reporting assignment is based on the maximum observed levels of net transaction accounts and total transaction accounts, savings deposits and small time deposits during the first half of the current year.3
As a result of the annual two-phase review, some institutions must begin filing deposit data more frequently and others are eligible for reduced reporting. The Reserve Banks notify affected institutions of the change in their reporting status when such a change occurs. An institution required to report on an increased frequency will begin the new regimen in September. An institution eligible for reduced reporting may elect to continue reporting at the higher frequency at its discretion. However, that institution must continue that level of reporting for a full year (i.e., September to September).
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1 Banking Edge/Agreement corporations and U.S. branches and agencies of foreign banks that provide weekly deposit data are not eligible for reduced reporting and are therefore excluded from this review. Bankers’ banks and corporate credit unions are not eligible for reduced reporting. At any time of the year, a depository institution that is experiencing above normal growth could be required to begin reporting more frequently.
2 Data are adjusted for any merger activity that may have occurred since the previous December.
3 For weekly deposit reporters, it is the maximum of the 13 weekly averages from weeks ending in early April through late June; for quarterly deposit reporters, it is the maximum of the two weekly averages in the March and June reporting periods; and for annual reporters, it is the values reported for June 30.