The recent tax law changes, which became law on December 22, 2017, will have a significant impact on future tax payments...

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Small banks have the option to complete the new FFIEC 051 Call Report as of March 31, 2017 or delay implementation until March 31, 2018. FFIEC 051 applies to FDIC-supervised financial institutions with domestic offices only and less than $1 billion in total assets.

Results from the UK voting on the so-called “Brexit” (short for “British exit”) referendum came as a major surprise to political and financial commentators. The general expectation was that UK voters would decide to stay in the European Union. It appears that the opinion pollsters, bookies, and the markets (which had rallied in response to a purported trend toward a “stay” vote) got it wrong.

The new RC-R preparation process has been the most significant change to Call Report submissions in 2015. During our reviews of clients’ Call Reports, we have noted some uncertainty regarding the new risk weighting requirements for certain investment securities. The recent changes have impacted the ways that corporate notes and bonds, including bank holding company issues, are to be risk weighted for capital adequacy purposes.

There is both good news and bad news regarding the “Volker rule”. The good news is that it probably will not impact community banks with “plain vanilla” securities portfolios classified as AFS or HTM. The bad news is that the rule has been issued, it is long and complex, and it may impact some banks’ ability to hold unregistered asset-backed securities after the conformance period ends on July 21, 2015. While not an issue for most community banks, it will clearly impact larger banks and increase the compliance burden of any bank engaged in securities trading, market making or sponsorship of any “covered fund”.

My first reaction to the idea of investing without knowing ratings is that it is not really going to happen. The rating agencies perform a valuable service, and it is just much more efficient to have an agency analyze and rate bonds, versus every investor trying to do the same thing on his/her own. Moreover, there is still a big audience of investors who will want the rating agency analysis and summary ratings. This will continue to include banks.

Decay rates on non-maturity deposits (including MMA, Savings, NOW accounts, etc.) relate to cash-flow and liquidity projections made by the Bank, and, when combined with "Beta" factors, the re-pricing impacts of such deposits in IRR modeling. Increasingly, regulators are requesting that banks develop their own customized decay rates for non-maturity deposits rather than use the industry averages or “rules of thumb”.

Liquidity risk management has increasingly become a “key” area of focus by regulatory agencies. The reasons for this attention are not difficult to understand, as liquidity related issues were a major contributing factor to the failures at Bear Stearns, Lehman Brothers and numerous other institutions. The resulting “turmoil” in the financial markets and overall damage to the economy have prompted federal regulators to issue a new, more detailed Interagency Policy Statement covering “Funding and Liquidity Risk Management.”