Previously, I discussed the history FR 2052a Complex Institution Liquidity Monitoring Report. My next blog will outline the recent changes to the report.
As allowed in the FR’s 2052a guidelines, the Federal Reserve has already requested that monthly filers submit FR 2052a data on a more frequent basis and altered the asset and liquidity thresholds of when a financial institution must provide daily reporting. The challenge is that not all banks are positioned to support more frequent reporting. These banks may face constraints on data availability and resourcing to support process cycle times. Submission procedures that rely on manual processes, observed more frequently in monthly than daily filers, may be overwhelmed, resulting in a deterioration of controls and quality.
As published online in February 2020 on the Office of Information and Regulatory Affairs, Office of Management and Budget website, to implement the reporting requirements of the final rule, the Federal Reserve Board modified the current FR 2052a reporting frequency. The Board revised the FR 2052a:
- So that BHCs and SLHCs with less than $100 billion in total consolidated assets would no longer have to report;
- BHCs or SLHCs subject to Category II standards ($700 billion or more in total consolidated assets or $75 billion or more in cross-jurisdictional activity) would have to report FR 2052a daily; and
- BHCs or SLHCs subject to Category III standards with $75 billion or more in weighted short-term wholesale funding would have to report FR 2052a daily, rather than monthly.
Consistent with EGRRCPA’s changes, the revisions:
- Remove foreign banking organizations (FBOs) with less than $100 billion in combined U.S. assets from the scope of FR 2052a reporting requirements
- Require foreign banking organizations with combined U.S. assets of $100 billion or more to report the FR 2052a on a daily basis if they are:
- Subject to Category II standards, or
- Subject to Category III standards and have $75 billion or more in weighted short-term wholesale funding or
- Subject to monthly filing requirements on all other foreign banking organizations with combined U.S. assets of $100 billion or more.
The first as-of date for the amended FR 2052a was June 30, 2020 (October 1, 2020, for foreign banking organizations with U.S. assets).
Download our guide to learn more about the FR 2052a report, including; history and recent changes, consolidation of subsidiary institutions requirement, data to be reported, reporting burdens and tools needed for reporting.