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compliance auditing - regulations
New Call Report System Implementation

By: Jennifer Kramer

The banking agencies have implemented the Central Data Repository (CDR) to process the Reports of Condition and Income (Call Reports) beginning with the third quarter 2005. This filing period begins with the September 30, 2005 call report and data must be received by October 30, 2005. The CDR will require banks to validate their Call Report data before it will be accepted. In order to accommodate this validation process and make the October 30, 2005, banks should start preparation of their Call Report earlier than usual. The new validation process will require banks to correct errors identified by the CDR and, where necessary, to prepare explanatory comments for data that fall outside specific parameters. These explanatory comments, which will be filed along with a bank's data, will be considered confidential.

This new process is expected to reduce the need for subsequent validation questions from the banking agencies. The completion of validation prior to submission will allow the agencies to release each institution's Call Report data to the public shortly after accepting the data into the CDR.

Banks will continue to interact with the banking agencies and their Call Report software vendors as they do today. While data will be submitted to the CDR in a new format, the agencies are working closely with Call Report software vendors to minimize the impact of this change on a bank's Call Report preparation and reporting process. Call Report Analysts will be available during the filing period to help banks resolve outstanding edit failures and respond to banks' inquiries about the third quarter Call Report filing deadline.
To date, over ninety-five percent of all banks have enrolled in the CDR and been given access to file their Call Report data via the new system. If your bank has not yet enrolled, please visit the FFIEC's web site for information on how to enroll at the CDR web site. Immediate enrollment will help ensure that your bank will be able to submit third quarter Call Report data.

Additionally, beginning on September 19, 2005, corrections to prior period data will no longer be accepted by EDS, the banking agencies' pre-CDR electronic collection agent. Banks should contact their Call Report Analyst for instructions on how to submit updates to prior period data.

To learn more about the banking agencies' Call Report modernization initiative, please visit the FFIEC's web site.

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