On March 26, ISDA and the Securities Industry and Financial Markets Association submitted a joint response to the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency on the proposed reporting revisions of the Call Report, FFIEC 101 and FFIEC 102, which are designed to reflect the implementation of the Basel III Endgame proposal.

It is important that the Agencies review the comments on the Basel III Endgame proposal submitted by the Associations and consider these before finalizing the reporting requirements. In addition, the proposed reporting requirements require significant effort to implement.  Thus, it is essential that the final reporting forms and instructions be published with sufficient time for banking organizations to make the necessary changes to their systems and calculations.