We need more eyes on this. The second notice is huge and there is far more to break down than my 0.69420741 wrinkles are capable of. Get in here wrinkle apes!

Rules and Links (ordered by deadline) (second one is huge, don’t skip 88 FR 89489)
- These collections concern small business lending & shadow banking data collections
- These collections are pertinent, considering the state of the economy and financial sector.
- The FDIC is looking for comment on whether these collections are necessary as part of the “Paperwork
Reduction Act of 1995”
- More info is present in each of the individual notices

**v If you’re short on time, skip this and go to the next one v**

89 FR 3923: Lending to Small Businesses
Comments due: 02/21/24
FDIC PDF: https://www.govinfo.gov/content/pkg/FR-2024-01-22/pdf/2024-01092.pdf
Better Format: https://www.federalregister.gov/documents/2024/01/22/2024-01092/agency-information-collection-activities-proposed-collection-renewal-comment-request

**Overview**:

Concerns lending to small businesses. Potential CRE impact?

**Collections**:

OMB Number: 3064–0085:
Record Retention
Credit reporting History
Demographic Information collected for Monitoring Purposes
Disclosure for Optional Self-Test
Notification of Action
Appraisal Report
Notice of Right to Appraisal
Recordkeeping of Credit Applications from Small Businesses
Initial implementation of System to Support Requirements in IC 9
Record Retention of Small Business Lending Data
Reporting Small Business Lending Data to CFPB
Implementation Activities to Support Requirements in IC 12
Notice of Nondiscrimination to Applicants
Initial implementation Activities for Requirements in IC 14
Firewall” Exception Notification
Initial Implementation Activities for Requirements in IC 16
Website Disclosure of Small Business Lending Data

OMB Number: 3064–0149:
Affiliate Marketing Disclosure—Implementation.
Consumer Opt Out Notices
Affiliate Marketing Disclosure—Ongoing

OMB Number: 3064–0194:
Covered Financial Company Asset Sales Purchaser Eligibility Certification

**Why does this matter**:

Helps prevent/identify discriminatory/predatory lending practices.

**v THIS IS HUGE v **

88 FR 89489: Call Reports, Shadow Banking (NDFIs), & Electronic Signatures
Comments due: 02/26/24 (only 11 days remaining!!!)
FDIC PDF: https://www.govinfo.gov/content/pkg/FR-2023-12-27/pdf/2023-28473.pdf
Better Format: https://www.federalregister.gov/documents/2023/12/27/2023-28473/proposed-agency-information-collection-activities-comment-request
Overview:

  • Proposal to extend and revise collection of Consolidated Reports of Condition and Income (Call Reports) for a three-year period.

    • Changes include new reporting requirements for Shadow Banking!!

  • Includes changes to reporting on loans to nondepository financial institutions (NDFIs aka Shadow Banking)

  • Considers adopting ongoing standards for electronic signatures.
    *Note: The OCC stated here stands for **Office of the Comptroller of the Currency **
    Note: NDFIs include a wide range of counterparties including insurance companies, mortgage companies, private equity funds, hedge funds, broker-dealers, real estate investment trusts (REITs), marketplace lenders, special purpose entities, and other financial vehicles.

    Collections:
    A. FFIEC 031, FFIEC 041, and FFIEC 051:
    *OCC: OMB Control No.: 1557–0081.
    BOARD: OMB Control No.: 7100–0036.
    FDIC: OMB Control No.: 3064–0052.
    B. FFIEC 002 and 002S:
    OMB Control Number: 7100–0032.

    What’s Affected:
    Loans to Nondepository Financial Institutions (Shadow Banks)
    **Schedule RC–C, Part I, Loans and Leases **
    - More detailed reporting?
    **Schedule RC–L, “Derivatives and Off-Balance Sheet Items” **
    - field name changes, and different layout for accuracy?
    **Schedule RC–N, “Past Due and Nonaccrual Loans, Leases, and Other Assets” **
    - idk honestly. Moving things around? More granularity?
    - Wrinkle ape help smooth ape pls
    **Schedule C, “Loans” **
    - increased details in reports
    **Reporting on Guaranteed Structured Financial Products **

    • Aims to address concerns raised about the lack of transparency in reporting the composition of structured financial products in item 5.b of RC-B.
    • The proposed Memorandum item would collect total amortized cost and total fair value for held-to-maturity and available-for-sale securities guaranteed by U.S. government agencies or sponsored agencies.
      **Long-Term Debt **
    • The federal bank regulatory agencies have proposed a rule requiring large banks with total assets of $100 billion or more to maintain a layer of long-term debt, aiming to enhance financial stability.
      -The proposal affects insured depository institutions (IDIs) meeting certain criteria and would introduce new line items in Schedule RC–R, Part I, of the Call Reports to monitor compliance with the proposed long-term debt requirements.
      **Electronic Signatures **
    • The agencies are proposing to establish ongoing standards for electronic signatures on the Call Reports

    Why does this matter:

    1. Call Reports aid agencies in monitoring the financial industry’s safety, soundness, and risk profiles.
    2. update the Call Report forms and instructions to increase the granularity in reporting exposure to Shadow Banking (NDFIs) and to improve reporting consistency.

TLDRS: 88 FR 89489 is Huge and would give more information about Shadow Banking to regulators