More Banks Eligible to File Short Form Call Report
With the release of the final rule this month, more institutions will be eligible to file the shorter Form 051 Call Report. This version, which was previously only available to institutions up to $1 billion in total assets, will now be available to institutions up to $5 billion.
Conversion is Optional
Changing to the Form 051 is optional and not required for newly eligible institutions. But once a change is made, regulators expect that institutions will continue to file the Form 051 as long as they remain eligible.
Institutions that are more than $3 billion in total assets or otherwise required for file the consolidated Form FRY-9C to report consolidated financial information may want to carefully consider before changing forms. The Form 051 does not contain all of the information that may be needed to complete the FRY-9C.
Time Savings?
When many smaller financial institutions changed to the Form 051 in 2017, they found that the transition was relatively seamless thanks in part of the current call report software available. The transition to the new form requires little time investment other than some initial time to review the new form and instructions.
Though the Form 051 is approximately a dozen pages shorter than the Form 041, most institutions have noticed little reduction in the amount of time required to complete the shorter form. Many of lines eliminated from the Form 041 to create the Form 051 are already not completed by the majority of community banks today.
Should You Convert?
The primary advantages of completing the Form 051 include a call report that is easier for your management team and board members to review and a shorter form that may be somewhat easier for new call report preparers to learn to prepare. Before converting you will want to consider whether your institution plans to exceed the $5 billion threshold in the near term and whether any information from the Form 041 will be helpful in preparing your FRY-9C, if required.
CLA is always here to help. Please contact us to discuss your call report further.
Amanda Garnett is a principal in the financial institutions practice of CliftonLarsonAllen (CLA) from Peoria, Illinois. She currently leads the firm’s Midwest financial institution tax team and serves institutions ranging in size from $15 million to $3.5 billion in total assets. In addition to tax compliance, Amanda assists clients in the areas of tax consulting, mergers and acquisitions, and regulatory reporting. She also routinely teaches courses for banking associations across the country.
My understanding is that this change is not effective until the September call report. Can you confirm if this is the case? Thank you!