General

1
General

• How to report
• Deposit
• Pass through balances
• Trust Funds
• Escrow Funds
• Exempt vs. Non Exempt
• Primary Obligations
• Data accuracy and edit explanations
• Call vs. FR 2900

2
How to Report Consolidation

• Deposits, vault cash, and allowable deductions
  for
• Banks head office
• Branches located in the U.S.
• Bank operating subsidiaries located in the U.S.
• U.S. military facility branches

3
How to Report - Consolidation

• Do not consolidate
• Edge and agreement subsidiaries
• Balances due to and due from non-U.S. branches
• International banking facilities (IBF)
• Different from the Regulatory Agency Statement of
  Conditions (Call Report) report

4
How to Report Overdrafts Negative Balances

• Negative (-) balances should be reported as zero
• Overdrawn individual accounts should be
  considered a loan and not reported on the FR 2900
• Bona fide cash management arrangement
• Agreement between an institution and a depositor
  where balances in one account may be used to
  offset the overdrafts in another account of the
  same type or a related depositor

5
How to Report Record Keeping

• Close of Business
• Cut off time for posting transactions to the GL
  accounts
• Should be consistently applied
• Must be posting debits and credits to be
  considered open

6
What is a Deposit?

• Regulation D definition
• The unpaid balance of money or its equivalent
  received or held by a
• depository institution in the usual course of
  business and for which it
• has given or is obligated to give credit, either
  conditionally or
• unconditionally, to an account, including
  interest credited, or which
• is evidenced by an instrument on which the
  depository institution is
• primarily liable

7
Pass Through Balances
Federal Reserve says your bank has a reserve
balance to hold
Respondent Bank
Correspondent Bank
Exclude from B1 Due From DI
Exclude from A1a Due To DI
Funds to satisfy
FHLB
Non-member bank
NCUA Central Liquidity Facility
Depository Institution with Fed account
8
Trust Funds

• Do not report
• Segregated from general assets
• Not available for general investment or lending
• Report
• Deposited into other departments of the reporting
  institution
• Reporting DI
• Other DIs
• Mingled with general assets of the reporting DI

9
Escrow Funds

• Funds deposited with a DI under an agreement that
  requires the DI to pay all or some portion of the
  funds to a third party at a certain time or upon
  fulfillment of certain conditions.
• Can be set up as
• Demand deposit
• Savings deposit
• Time deposit

10
Exempt Vs. Non-Exempt
The concept of exempt and non-exempt entities
applies only to primary obligations.
Exempt U.S. offices of Commercial banks Trust companies Mutual and stock savings banks Building or savings loan associations Credit unions U.S. Government agencies Non-Exempt Individuals Partnerships Corporations State and local governments Bank holding company (not a bank) Non bank subsidiaries Parent company Bank International institutions

See FR 2900 glossary for an all inclusive list
11
Primary Obligation

• What is a primary obligation?
• Borrowing by the DI
• When to report?
• Counter party non-exempt
• and
• Proceeds supply or maintain availability of funds
• Where to report?
• Transaction accounts
• Savings deposits
• Time deposits

12
Data Accuracy Edit Explanations

• Data Accuracy
• Monetary policy and FOMC operations
• Publishing aggregate data
• Reserve requirement calculations
• Reduces revisions!!!!!!!!
• Edit Explanations
• Who
• What
• When (or how long)
• Why
• How

13
Sample Explanations

• NOW/Share Drafts (A2)
• Increase of 15m on 6/22
• Explanation possibilities
• Yes it did go up, the total is higher
• Some of the accounts increased
• The County Treasurers office opened an account
  with a 15m initial deposit on 6/22 as a result
  of winning the public funds bid
• Which response would you choose?

3
14
FR 2900 Vs. Call Report

• Timing
• Quarterly
• Expectations
• Data to be accurate on both reports
• Edits to be researched
• Explanations
• Revisions
• Common causes
• Primary obligations
• Adjustments

15
Questions