DEPOSITORY INSTITUTION REPORTS

1

FFIEC

Federal Financial Institutions Examination Council

Arlington, VA 22226

CALL REPORT DATE: December 31, 2017

FOURTH 2017 CALL, NUMBER 282

SUPPLEMENTAL INSTRUCTIONS

December 2017 Call Report Materials

There are no new or revised Call Report data items and no updates to the instruction books for the FFIEC 051,

FFIEC 041, and FFIEC 031 Call Reports this quarter. One new topic has been added to the Supplemental

Instructions for December 2017: “Credit Losses on Financial Instruments.”

Sample FFIEC 051, FFIEC 041, and FFIEC 031 Call Report forms, including the cover (signature) page, and

instructional materials for December 2017 can be printed and downloaded from the FFIEC’s website

(https://www.ffiec.gov/ffiec_report_forms.htm) and the FDIC’s website (https://www.fdic.gov/callreports).

In addition, institutions that use Call Report software generally can print paper copies of blank forms from their

software. Please ensure that the individual responsible for preparing the Call Report at your institution has

been notified about the electronic availability of the December 2017 report forms and these Supplemental

Instructions. The locations of changes to the text of the previous quarter’s Supplemental Instructions (except

references to the quarter-end report date) are identified by a vertical line in the right margin.

Submission of Completed Reports

Each institution’s Call Report data must be submitted to the FFIEC's Central Data Repository (CDR), an

Internet-based system for data collection (https://cdr.ffiec.gov/cdr/), using one of the two methods described

in the banking agencies' Financial Institution Letter (FIL) for the December 31, 2017, report date. The CDR

Help Desk is available from 9:00 a.m. until 8:00 p.m., Eastern Time, Monday through Friday, to provide

assistance with user accounts, passwords, and other CDR system-related issues

ernet-based system for data collection (https://cdr.ffiec.gov/cdr/), using one of the two methods described

in the banking agencies' Financial Institution Letter (FIL) for the December 31, 2017, report date. The CDR

Help Desk is available from 9:00 a.m. until 8:00 p.m., Eastern Time, Monday through Friday, to provide

assistance with user accounts, passwords, and other CDR system-related issues. The CDR Help Desk can

be reached by telephone at (888) CDR-3111, by fax at (703) 774-3946, or by e-mail at CDR.Help@ffiec.gov.

Institutions are required to maintain in their files a signed and attested hard-copy record of the Call Report data

file submitted to the CDR. The appearance of this hard-copy record of the submitted data file need not match

exactly the appearance of the sample report forms on the FFIEC’s website, but the hard-copy record should

show at least the caption of each Call Report item and the reported amount. A copy of the cover page printed

from Call Report software or from the FFIEC’s website should be used to fulfill the signature and attestation

requirement. The signed cover page should be attached to the hard-copy record of the Call Report data file

that must be placed in the institution's files.

Currently, Call Report preparation software products marketed by (in alphabetical order) Axiom Software

Laboratories, Inc.; DBI Financial Systems, Inc.; Fed Reporter, Inc.; FIS Compliance Solutions; FiServ, Inc.;

KPMG LLP; Lombard Risk; SHAZAM Core Services; and Wolters Kluwer Financial Services meet the

technical specifications for producing Call Report data files that are able to be processed by the CDR. Contact

information for these vendors is provided on the final page of these Supplemental Instructions.

Credit Losses on Financial Instruments

In June 2016, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU)

No

ers Kluwer Financial Services meet the

technical specifications for producing Call Report data files that are able to be processed by the CDR. Contact

information for these vendors is provided on the final page of these Supplemental Instructions.

Credit Losses on Financial Instruments

In June 2016, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update (ASU)

No. 2016-13, “Measurement of Credit Losses on Financial Instruments,” which introduces the current expected

credit losses methodology (CECL) for estimating allowances for credit losses. Under CECL, the allowance for

credit losses is a valuation account, measured as the difference between the financial assets’ amortized cost

basis and the net amount expected to be collected on the financial assets (i.e., lifetime credit losses). To

estimate expected credit losses under CECL, institutions will use a broader range of data than under existing

U.S. generally accepted accounting principles (GAAP). These data include information about past events,

current conditions, and reasonable and supportable forecasts relevant to assessing the collectability of the

cash flows of financial assets.

The ASU is applicable to all financial instruments carried at amortized cost (including loans held for

investment, net investment in leases, and held-to-maturity debt securities, as well as trade and reinsurance

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

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receivables and receivables that relate to repurchase agreements and securities lending agreements) and

off-balance-sheet credit exposures not accounted for as insurance, including loan commitments, standby

letters of credit, and financial guarantees. The new standard does not apply to trading assets, loans held for

sale, financial assets for which the fair value option has been elected, or loans and receivables between

entities under common control.

The ASU also modifies the treatment of credit impairment on available-for-sale (AFS) debt securities

rance, including loan commitments, standby

letters of credit, and financial guarantees. The new standard does not apply to trading assets, loans held for

sale, financial assets for which the fair value option has been elected, or loans and receivables between

entities under common control.

The ASU also modifies the treatment of credit impairment on available-for-sale (AFS) debt securities. Under

the new standard, institutions will recognize a credit loss on an AFS debt security through an allowance for

credit losses, rather than the current practice required by U.S. GAAP of write-downs of individual securities for

other-than-temporary impairment.

For institutions that are public business entities and are also U.S. Securities and Exchange Commission (SEC)

filers, as both terms are defined in U.S. GAAP, the ASU is effective for fiscal years beginning after

December 15, 2019, including interim periods within those fiscal years. For public business entities that are

not SEC filers, the ASU is effective for fiscal years beginning after December 15, 2020, including interim

periods within those fiscal years. For institutions that are not public business entities (i.e., that are private

companies), the ASU is effective for fiscal years beginning after December 15, 2020, and for interim periods of

fiscal years beginning after December 15, 2021. For all institutions, early application of the new standard is

permitted for fiscal years beginning after December 15, 2018, including interim periods within those fiscal

years. Institutions must apply ASU 2016-13 for Call Report purposes in accordance with the effective dates

set forth in the ASU. An institution that early adopts ASU 2016-13 for U.S. GAAP financial reporting purposes

should also early adopt the ASU in the same period for Call Report purposes

tted for fiscal years beginning after December 15, 2018, including interim periods within those fiscal

years. Institutions must apply ASU 2016-13 for Call Report purposes in accordance with the effective dates

set forth in the ASU. An institution that early adopts ASU 2016-13 for U.S. GAAP financial reporting purposes

should also early adopt the ASU in the same period for Call Report purposes.

The Call Report forms and instructions will be revised to conform to the ASU at a future date, and the agencies

will request comment on the proposed revisions through a Federal Register notice.

For additional information, institutions should refer to the agencies’ Frequently Asked Questions on the New

Accounting Standard on Financial Instruments – Credit Losses, which were most recently updated on

September 6, 2017, the agencies’ June 17, 2016, Joint Statement on the New Accounting Standard on

Financial Instruments – Credit Losses, and ASU 2016-13, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176168232528&acceptedDisclaimer=true.

Accounting for Hedging Activities

In August 2017, the FASB issued ASU No. 2017-12, “Targeted Improvements to Accounting for Hedging

Activities.” This ASU amends Accounting Standards Codification (ASC) Topic 815, Derivatives and Hedging,

to “better align an entity’s risk management activities and financial reporting for hedging relationships through

changes to both the designation and measurement guidance for qualifying hedging relationships and the

presentation of hedge results.”

For institutions that are public business entities, as defined under U.S. GAAP, the ASU is effective for fiscal

years beginning after December 15, 2018, including interim periods within those fiscal years. For institutions

that are not public business entities (i.e., that are private companies), the ASU is effective for fiscal years

beginning after December 15, 2019, and interim periods beginning after December 15, 2020

ublic business entities, as defined under U.S. GAAP, the ASU is effective for fiscal

years beginning after December 15, 2018, including interim periods within those fiscal years. For institutions

that are not public business entities (i.e., that are private companies), the ASU is effective for fiscal years

beginning after December 15, 2019, and interim periods beginning after December 15, 2020. Refer to the

Glossary entries for “public business entity” and “private company” in the Call Report instructions for further

information on these terms.

Early application of the ASU is permitted for all institutions in any interim period or fiscal year before the

effective date of the ASU. Further, the ASU specifies transition requirements and offers transition elections for

hedging relationships existing on the data of adoption (i.e., hedging relationships in which the hedging

instrument has not expired, been sold, terminated, or exercised or for which the institution has not removed

the designation of the hedging relationship). These transition requirements and elections should be applied on

the date of adoption of the ASU and the effect of adoption should be reflected as of the beginning of the fiscal

year of adoption (i.e., the initial application date). Thus, if an institution early adopts the ASU in an interim

period, any adjustments shall be reflected as of the beginning of the fiscal year that includes the interim period

of adoption, e.g., as of January 1 for a calendar year institution. An institution that early adopts ASU 2017-12

hould be reflected as of the beginning of the fiscal

year of adoption (i.e., the initial application date). Thus, if an institution early adopts the ASU in an interim

period, any adjustments shall be reflected as of the beginning of the fiscal year that includes the interim period

of adoption, e.g., as of January 1 for a calendar year institution. An institution that early adopts ASU 2017-12

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

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in an interim period for U.S. GAAP financial reporting purposes should also early adopt the ASU in the same

period for Call Report purposes.

The Call Report instructions, including the Glossary entry for “Derivative Contracts,” will be revised to conform

to the ASU at a future date.

For additional information, institutions should refer to ASU 2017-12, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176169282347&acceptedDisclaimer=true.

Regulatory Capital Treatment of Certain Centrally-Cleared Derivative Contracts

On August 14, 2017, the banking agencies issued supervisory guidance on the regulatory capital treatment of

certain centrally-cleared derivative contracts in light of recent changes to the rulebooks of certain central

counterparties. Under the previous requirements of these central counterparties’ rulebooks, variation margin

transferred to cover the exposure that arises from marking cleared derivative contracts, and netting sets of

such contracts, to fair value was considered collateral pledged by one party to the other, with title to the

collateral remaining with the posting party. These derivative contracts are referred to as collateralized-to-

market contracts

central counterparties’ rulebooks, variation margin

transferred to cover the exposure that arises from marking cleared derivative contracts, and netting sets of

such contracts, to fair value was considered collateral pledged by one party to the other, with title to the

collateral remaining with the posting party. These derivative contracts are referred to as collateralized-to-

market contracts. Under the revised rulebooks of certain central counterparties, variation margin for certain

centrally-cleared derivative contracts, and certain netting sets of such contracts, is considered a settlement

payment for the exposure that arises from marking these derivative contracts and netting sets to fair value,

with title to the payment transferring to the receiving party. In these circumstances, the derivative contracts

and netting sets are referred to as settled-to-market contracts.

Under the agencies’ regulatory capital rules, in general, an institution must calculate the trade exposure

amount for a cleared derivative contract, or a netting set of such contracts, by using the methodology

described in section 34 of the rules to determine (i) the current credit exposure and (ii) the potential future

exposure of the derivative contract or netting set of such contracts for purposes of the standardized approach

risk-based capital calculation and the supplementary leverage ratio calculation. The risk-weighted asset

calculations under the advanced approaches capital framework have similar requirements. Current credit

exposure is determined by reference to the fair value of each derivative contract as measured under U.S.

GAAP. Potential future exposure is determined, in part, by multiplying each derivative contract’s notional

principal amount by a conversion factor. The conversion factors vary by the category (for example, interest

rate, equity) and remaining maturity of the derivative contract

ent credit

exposure is determined by reference to the fair value of each derivative contract as measured under U.S.

GAAP. Potential future exposure is determined, in part, by multiplying each derivative contract’s notional

principal amount by a conversion factor. The conversion factors vary by the category (for example, interest

rate, equity) and remaining maturity of the derivative contract. The regulatory capital rules provide that, for a

derivative contract that is structured such that on specified dates any outstanding exposure is settled and the

terms are reset so that the fair value of the contract is zero, the remaining maturity equals the time until the

next reset date.

For the purpose of the regulatory capital rules, the August 2017 supervisory guidance states that if, after

accounting and legal analysis, an institution determines that (i) the variation margin payment on a centrally

cleared settled-to-market contract settles any outstanding exposure on the contract, and (ii) the terms are

reset so that the fair value of the contract is zero, the remaining maturity on such a contract would equal the

time until the next exchange of variation margin on the contract. In conducting its legal analysis to determine

whether variation margin may be considered settlement of outstanding exposure under the regulatory capital

rules, an institution should evaluate whether the transferor of the variation margin has relinquished all legal

claims to the variation margin and whether the payment of variation margin constitutes settlement under the

central counterparty’s rulebook, any other applicable agreements governing the derivative contract, and

applicable law. Among other requirements, a central counterparty’s rulebook may require an institution to

satisfy additional obligations, such as payment of other expenses and fees, in order to recognize payment of

variation margin as satisfying settlement under the rulebook

ement under the

central counterparty’s rulebook, any other applicable agreements governing the derivative contract, and

applicable law. Among other requirements, a central counterparty’s rulebook may require an institution to

satisfy additional obligations, such as payment of other expenses and fees, in order to recognize payment of

variation margin as satisfying settlement under the rulebook. The legal and accounting analysis performed by

the institution should take all such requirements into account.

Institutions should refer to the supervisory guidance in its entirety for purposes of determining the appropriate

regulatory capital treatment of settled-to-market contracts under the regulatory capital rules. This guidance is

available at https://www.fdic.gov/news/news/financial/2017/fil17033a.pdf.

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

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Premium Amortization on Purchased Callable Debt Securities

In March 2017, the FASB issued ASU No. 2017-08, “Premium Amortization on Purchased Callable Debt

Securities.” This ASU amends ASC Subtopic 310-20, Receivables – Nonrefundable Fees and Other Costs

(formerly FASB Statement No. 91, “Accounting for Nonrefundable Fees and Costs Associated with Originating

or Acquiring Loans and Initial Direct Costs of Leases”), by shortening the amortization period for premiums on

callable debt securities that have explicit, non-contingent call features and are callable at fixed prices and on

preset dates. Under existing U.S. GAAP, the premium on such a callable debt security generally is required to

be amortized as an adjustment of yield over the contractual life of the debt security

nitial Direct Costs of Leases”), by shortening the amortization period for premiums on

callable debt securities that have explicit, non-contingent call features and are callable at fixed prices and on

preset dates. Under existing U.S. GAAP, the premium on such a callable debt security generally is required to

be amortized as an adjustment of yield over the contractual life of the debt security. Under the ASU, the

excess of the amortized cost basis of such a callable debt security over the amount repayable by the issuer at

the earliest call date (i.e., the premium) must be amortized to the earliest call date (unless the institution

applies the guidance in ASC Subtopic 310-20 that allows estimates of future principal prepayments to be

considered in the effective yield calculation when the institution holds a large number of similar debt securities

for which prepayments are probable and the timing and amount of the prepayments can be reasonably

estimated). If the call option is not exercised at its earliest call date, the institution must reset the effective

yield using the payment terms of the debt security.

The ASU does not change the accounting for debt securities held at a discount. The discount on such debt

securities continues to be amortized to maturity (unless the Subtopic 310-20 guidance mentioned above is

applied).

For institutions that are public business entities, as defined under U.S. GAAP, the new standard is effective for

fiscal years beginning after December 15, 2018, including interim periods within those fiscal years. For

institutions that are not public business entities (i.e., that are private companies), the new standard is effective

for fiscal years beginning after December 15, 2019, and interim periods within fiscal years beginning after

December 15, 2020.

Early application of the new standard is permitted for all institutions, including adoption in an interim period of

2017 or a subsequent year before the applicable effective date for an institution

(i.e., that are private companies), the new standard is effective

for fiscal years beginning after December 15, 2019, and interim periods within fiscal years beginning after

December 15, 2020.

Early application of the new standard is permitted for all institutions, including adoption in an interim period of

2017 or a subsequent year before the applicable effective date for an institution. If an institution early adopts

the ASU in an interim period, the cumulative-effect adjustment shall be reflected as of the beginning of the

fiscal year of adoption.

An institution must apply the new standard on a modified retrospective basis as of the beginning of the period

of adoption. Under the modified retrospective method, an institution should apply a cumulative-effect

adjustment to affected accounts existing as of the beginning of the fiscal year the new standard is adopted.

The cumulative-effect adjustment to retained earnings for this change in accounting principle should be

reported in Call Report Schedule RI-A, item 2.

For additional information, institutions should refer to ASU 2017-08, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176168934053&acceptedDisclaimer=true.

Recognition and Measurement of Financial Instruments: Investments in Equity Securities

In January 2016, the FASB issued ASU 2016-01, “Recognition and Measurement of Financial Assets and

Financial Liabilities.” This ASU makes targeted improvements to U.S. GAAP. As one of its main provisions,

the ASU requires investments in equity securities, except those accounted for under the equity method and

those that result in consolidation, to be measured at fair value with changes in fair value recognized in net

income. Thus, the ASU eliminates the existing concept of AFS equity securities, which are measured at

fair value with changes in fair value generally recognized in other comprehensive income. To be classified

as AFS under current U.S

pt those accounted for under the equity method and

those that result in consolidation, to be measured at fair value with changes in fair value recognized in net

income. Thus, the ASU eliminates the existing concept of AFS equity securities, which are measured at

fair value with changes in fair value generally recognized in other comprehensive income. To be classified

as AFS under current U.S. GAAP, an equity security must have a readily determinable fair value and not be

held for trading. In addition, for an equity security that does not have a readily determinable fair value, the

ASU permits an entity to elect to measure the security at cost minus impairment, if any, plus or minus changes

resulting from observable price changes in orderly transactions for the identical or a similar investment of the

same issuer. When this election is made for an equity security without a readily determinable fair value, the

ASU simplifies the impairment assessment of such an investment by requiring a qualitative assessment to

identify impairment.

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

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The ASU’s measurement guidance for investments in equity securities also applies to other ownership

interests, such as interests in partnerships, unincorporated joint ventures, and limited liability companies.

However, the measurement guidance does not apply to Federal Home Loan Bank and Federal Reserve Bank

stock.

For institutions that are public business entities, as defined under U.S. GAAP, ASU 2016-01 is effective for

fiscal years beginning after December 15, 2017, including interim periods within those fiscal years. For all

other entities, the ASU is effective for fiscal years beginning after December 15, 2018, and interim periods

within fiscal years beginning after December 15, 2019. Early application of the ASU is permitted for all

institutions that are not public business entities as of the fiscal years beginning after December 15, 2017,

including interim periods within those fiscal years

scal years. For all

other entities, the ASU is effective for fiscal years beginning after December 15, 2018, and interim periods

within fiscal years beginning after December 15, 2019. Early application of the ASU is permitted for all

institutions that are not public business entities as of the fiscal years beginning after December 15, 2017,

including interim periods within those fiscal years. Institutions must apply ASU 2016-01 for Call Report

purposes in accordance with the effective dates set forth in the ASU.

With the elimination of AFS equity securities upon an institution’s adoption of ASU 2016-01, the amount of net

unrealized gains (losses) on these securities, net of tax effect, that is included in accumulated other

comprehensive income (AOCI) on the Call Report balance sheet (Schedule RC, item 26.b) as of the adoption

date will be reclassified (transferred) from AOCI into the retained earnings component of equity capital on the

balance sheet (Schedule RC, item 26.a). Thereafter, changes in the fair value of (i.e., the unrealized gains

and losses on) an institution’s equity securities that would have been classified as AFS under existing U.S.

GAAP will be recognized through net income rather than other comprehensive income (OCI). For an

institution’s holdings of equity securities without readily determinable fair values as of the adoption date, the

measurement provisions of the ASU are to be applied prospectively to these securities.

For additional information, institutions should refer to ASU 2016-01, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176167762170&acceptedDisclaimer=true.

Recognition and Measurement of Financial Instruments: Fair Value Option Liabilities

In addition to the changes in the accounting for equity securities discussed in the preceding section of these

Supplemental Instructions, ASU No

institutions should refer to ASU 2016-01, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176167762170&acceptedDisclaimer=true.

Recognition and Measurement of Financial Instruments: Fair Value Option Liabilities

In addition to the changes in the accounting for equity securities discussed in the preceding section of these

Supplemental Instructions, ASU No. 2016-01 requires an institution to present separately in OCI the portion of

the total change in the fair value of a liability resulting from a change in the instrument-specific credit risk

(“own credit risk”) when the institution has elected to measure the liability at fair value in accordance with the

fair value option for financial instruments. Until an institution adopts the own credit risk provisions of the ASU,

U.S. GAAP requires the institution to report the entire change in the fair value of a fair value option liability in

earnings. The ASU does not apply to other financial liabilities measured at fair value, including derivatives.

For these other financial liabilities, the effect of a change in an entity’s own credit risk will continue to be

reported in net income.

The change due to own credit risk, as described above, is the difference between the total change in fair value

and the amount resulting from a change in a base market rate (e.g., a risk-free interest rate). An institution

may use another method that it believes results in a faithful measurement of the fair value change attributable

to instrument-specific credit risk. However, it will have to apply the method consistently to each financial

liability from period to period.

The effective dates of ASU 2016-01 are described in the preceding section of these Supplemental Instructions

erest rate). An institution

may use another method that it believes results in a faithful measurement of the fair value change attributable

to instrument-specific credit risk. However, it will have to apply the method consistently to each financial

liability from period to period.

The effective dates of ASU 2016-01 are described in the preceding section of these Supplemental Instructions.

Notwithstanding these effective dates, early application of the ASU’s provisions regarding the presentation in

OCI of changes due to own credit risk on fair value option liabilities is permitted for all entities for financial

statements of fiscal years or interim periods that have not yet been issued or made available for issuance, and

in the same period for Call Report purposes.

When an institution with a calendar year fiscal year adopts the own credit risk provisions of ASU 2016-01, the

accumulated gains and losses as of the beginning of the fiscal year due to changes in the instrument-specific

credit risk of fair value option liabilities, net of tax effect, are reclassified from Schedule RC, item 26.a,

“Retained earnings,” to Schedule RC, item 26.b, “Accumulated other comprehensive income.” If an institution

with a calendar year fiscal year chooses to early apply the ASU’s provisions for fair value option liabilities in an

interim period after the first interim period of its fiscal year, any unrealized gains and losses due to changes in

effect, are reclassified from Schedule RC, item 26.a,

“Retained earnings,” to Schedule RC, item 26.b, “Accumulated other comprehensive income.” If an institution

with a calendar year fiscal year chooses to early apply the ASU’s provisions for fair value option liabilities in an

interim period after the first interim period of its fiscal year, any unrealized gains and losses due to changes in

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

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own credit risk and the related tax effects recognized in the Call Report income statement during the interim

period(s) before the interim period of adoption should be reclassified from earnings to OCI. In the Call Report,

this reclassification would be from Schedule RI, item 5.l, “Other noninterest income,” and Schedule RI, item 9,

“Applicable income taxes,” to Schedule RI-A, item 10, “Other comprehensive income,” with a corresponding

reclassification from Schedule RC, item 26.a, to Schedule RC, item 26.b.

Additionally, for purposes of reporting on Schedule RC-R, Part I, institutions should report in item 10.a, “Less:

Unrealized net gain (loss) related to changes in the fair value of liabilities that are due to changes in own credit

risk,” the amount included in AOCI attributable to changes in the fair value of fair value option liabilities that are

due to changes in the institution’s own credit risk. Institutions should note that this AOCI amount is included in

the amount reported in Schedule RC-R, Part I, item 3, “Accumulated other comprehensive income (AOCI).”

For additional information, institutions should refer to ASU 2016-01, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176167762170&acceptedDisclaimer=true.

New Revenue Recognition Accounting Standard

In May 2014, the FASB issued ASU No. 2014-09, “Revenue from Contracts with Customers,” which added

ASC Topic 606, Revenue from Contracts with Customers

I).”

For additional information, institutions should refer to ASU 2016-01, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176167762170&acceptedDisclaimer=true.

New Revenue Recognition Accounting Standard

In May 2014, the FASB issued ASU No. 2014-09, “Revenue from Contracts with Customers,” which added

ASC Topic 606, Revenue from Contracts with Customers. The core principle of Topic 606 is that an entity

should recognize revenue at an amount that reflects the consideration to which it expects to be entitled

in exchange for transferring goods or services to a customer as part of the entity’s ordinary activities.

ASU 2014-09 also added Topic 610, Other Income, to the ASC. Topic 610 applies to income recognition that

is not within the scope of Topic 606, other Topics (such as Topic 840 on leases), or other revenue or income

guidance. As discussed in the following section of these Supplemental Instructions, Topic 610 applies to an

institution’s sales of repossessed nonfinancial assets, such as other real estate owned (OREO). The sale of

repossessed nonfinancial assets is not considered an “ordinary activity” because institutions do not typically

invest in nonfinancial assets. ASU 2014-09 and subsequent amendments are collectively referred to herein

as the “new standard.”

The new standard specifically excludes financial instruments and other contractual rights or obligations within

the scope of Topic 310, Receivables; Topic, 320, Investments – Debt and Equity Securities; Topic 815,

Derivatives and Hedging; and certain other ASC Topics. Therefore, many common revenue streams in the

financial sector, such as interest income, fair value adjustments, gains and losses on sales of financial

instruments, and loan origination fees, are not within the scope of the new standard

n

the scope of Topic 310, Receivables; Topic, 320, Investments – Debt and Equity Securities; Topic 815,

Derivatives and Hedging; and certain other ASC Topics. Therefore, many common revenue streams in the

financial sector, such as interest income, fair value adjustments, gains and losses on sales of financial

instruments, and loan origination fees, are not within the scope of the new standard. The new standard may

change the timing for the recognition of, and the presentation of, those revenue streams within the scope of

ASC Subtopic 606-10, such as certain fees associated with credit card arrangements, underwriting fees and

costs, and deposit-related fees.

For institutions that are public business entities, as defined under U.S. GAAP, the new standard is effective for

fiscal years beginning after December 15, 2017, including interim reporting periods within those fiscal years.

For institutions that are not public business entities (i.e., that are private companies), the new standard is

effective for fiscal years beginning after December 15, 2018, and interim reporting periods within fiscal years

beginning after December 15, 2019. Early application of the new standard is permitted for all institutions for

fiscal years beginning after December 15, 2016, and interim reporting periods as prescribed in the new

standard. If an institution chooses to early adopt the new standard for financial reporting purposes, the

institution should implement the new standard in its Call Report for the same quarter-end report date.

For Call Report purposes, an institution must apply the new standard on a modified retrospective basis as of

the effective date of the standard. Under the modified retrospective method, an institution should apply a

cumulative-effect adjustment to affected accounts existing as of the beginning of the fiscal year the new

standard is adopted

s Call Report for the same quarter-end report date.

For Call Report purposes, an institution must apply the new standard on a modified retrospective basis as of

the effective date of the standard. Under the modified retrospective method, an institution should apply a

cumulative-effect adjustment to affected accounts existing as of the beginning of the fiscal year the new

standard is adopted. The cumulative-effect adjustment to retained earnings for this change in accounting

principle should be reported in Call Report Schedule RI-A, item 2. An institution that early adopts the new

standard must apply it in its entirety. The institution cannot choose to apply the guidance to some revenue

streams and not to others that are within the scope of the new standard.

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

7

For additional information, institutions should refer to the new standard, which is available at

http://www.fasb.org/jsp/FASB/Page/SectionPage&cid=1176156316498.

Revenue Recognition: Accounting for Sales of OREO

As stated in the preceding section, Topic 610 applies to an institution’s sale of repossessed nonfinancial

assets, such as OREO. When the new standard becomes effective at the dates discussed above, Topic 610

will eliminate the prescriptive criteria and methods for sale accounting and gain recognition for dispositions of

OREO currently set forth in Subtopic 360-20, Property, Plant, and Equipment – Real Estate Sales. Under the

new standard, an institution will recognize the entire gain or loss, if any, and derecognize the OREO at the

time of sale if the transaction meets certain requirements of Topic 606. Otherwise, an institution will generally

record any payments received as a deposit liability to the buyer and continue reporting the OREO as an asset

at the time of the transaction.

The following paragraphs highlight key aspects of Topic 610 that will apply to seller-financed sales of OREO

once the new standard takes effect

f sale if the transaction meets certain requirements of Topic 606. Otherwise, an institution will generally

record any payments received as a deposit liability to the buyer and continue reporting the OREO as an asset

at the time of the transaction.

The following paragraphs highlight key aspects of Topic 610 that will apply to seller-financed sales of OREO

once the new standard takes effect. When implementing the new standard, an institution will need to exercise

judgment in determining whether a contract (within the meaning of Topic 606) exists for the sale or transfer of

OREO, whether the institution has performed its obligations identified in the contract, and what the transaction

price is for calculation of the amount of gain or loss. For additional information, please refer to the Glossary

entry for “Foreclosed Assets” in the Call Report instruction books, which was updated in March 2017 to

incorporate guidance on the application of the new standard to sales of OREO.

Under Topic 610, when an institution does not have a controlling financial interest in the OREO buyer under

Topic 810, Consolidation, the institution’s first step in assessing whether it can derecognize an OREO asset

and recognize revenue upon the sale or transfer of the OREO is to determine whether a contract exists under

the provisions of Topic 606. In order for a transaction to be a contract under Topic 606, it must meet five

criteria. Although all five criteria require careful analysis for seller-financed sales of OREO, two criteria in

particular may require significant judgment. These criteria are the commitment of the parties to the transaction

to perform their respective obligations and the collectability of the transaction price

. In order for a transaction to be a contract under Topic 606, it must meet five

criteria. Although all five criteria require careful analysis for seller-financed sales of OREO, two criteria in

particular may require significant judgment. These criteria are the commitment of the parties to the transaction

to perform their respective obligations and the collectability of the transaction price. To evaluate whether a

transaction meets the collectability criterion, a selling institution must determine whether it is probable that it

will collect substantially all of the consideration to which it is entitled in exchange for the transfer of the OREO,

i.e., the transaction price. To make this determination, as well as the determination that the buyer of the

OREO is committed to perform its obligations, a selling institution should consider all facts and circumstances

related to the buyer’s ability and intent to pay the transaction price. As with the current accounting standards

governing seller-financed sales of OREO, the amount and character of a buyer’s initial equity in the property

(typically the cash down payment) and recourse provisions remain important factors to evaluate. Other factors

to consider may include, but are not limited to, the financing terms of the loan (including amortization and any

balloon payment), the credit standing of the buyer, the cash flow from the property, and the selling institution’s

continuing involvement with the property following the transaction.

If the five contract criteria in Topic 606 have not been met, the institution generally may not derecognize the

OREO asset or recognize revenue (gain or loss) as an accounting sale has not occurred. In contrast, if an

institution determines the contract criteria in Topic 606 have been met, it must then determine whether it has

satisfied its performance obligations as identified in the contract by transferring control of the asset to the

buyer, indicators of which are identified in the new standard

the

OREO asset or recognize revenue (gain or loss) as an accounting sale has not occurred. In contrast, if an

institution determines the contract criteria in Topic 606 have been met, it must then determine whether it has

satisfied its performance obligations as identified in the contract by transferring control of the asset to the

buyer, indicators of which are identified in the new standard. For seller-financed sales of OREO, the transfer

of control generally occurs on the closing date of the sale when the institution obtains the right to receive

payment for the property and transfers legal title to the buyer. However, an institution must consider all

relevant facts and circumstances to determine whether control of the OREO has transferred.

When a contract exists and an institution has transferred control of the asset, the institution should

derecognize the OREO asset and recognize a gain or loss for the difference between the transaction price and

the carrying amount of the OREO asset. Generally, the transaction price in a sale of OREO will be the

contract amount in the purchase/sale agreement, including for a seller-financed sale financed at market terms.

However, the transaction price may differ from the amount stated in the contract due to the existence of off-

market terms on the financing. In this situation, to determine the transaction price, the contract amount should

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

8

be adjusted for the time value of money by using as the discount rate a market rate of interest considering the

credit characteristics of the buyer and the terms of the financing.

As stated in the preceding section on the new revenue recognition accounting standard, for Call Report

purposes, an institution must apply the new standard on a modified retrospective basis

– DECEMBER 2017

8

be adjusted for the time value of money by using as the discount rate a market rate of interest considering the

credit characteristics of the buyer and the terms of the financing.

As stated in the preceding section on the new revenue recognition accounting standard, for Call Report

purposes, an institution must apply the new standard on a modified retrospective basis. To determine the

cumulative-effect adjustment for the change in accounting for seller-financed OREO sales, an institution

should measure the impact of applying Topic 610 to the outstanding seller-financed sales of OREO currently

accounted for under Subtopic 360-20 using the installment, cost recovery, reduced-profit, or deposit method

as of the beginning of the fiscal year the new standard is adopted. The cumulative-effect adjustment to

retained earnings for this change in accounting principle should be reported in Call Report Schedule RI-A,

item 2.

Accounting for Leases

In February 2016, the FASB issued ASU No. 2016-02, “Leases,” which added ASC Topic 842, Leases. This

guidance, once effective, supersedes ASC Topic 840, Leases.

Topic 842 does not fundamentally change lessor accounting; however, it aligns terminology between lessee

and lessor accounting and brings key aspects of lessor accounting into alignment with the FASB’s new

revenue recognition guidance in Topic 606. As a result, the classification difference between direct financing

leases and sales-type leases for lessors moves from a risk-and-rewards principle to a transfer of control

principle. Additionally, there is no longer a distinction in the treatment of real estate and non-real estate leases

by lessors.

The most significant change that Topic 842 makes is to lessee accounting. Under existing accounting

standards, lessees recognize lease assets and lease liabilities on the balance sheet for capital leases, but do

not recognize operating leases on the balance sheet

principle. Additionally, there is no longer a distinction in the treatment of real estate and non-real estate leases

by lessors.

The most significant change that Topic 842 makes is to lessee accounting. Under existing accounting

standards, lessees recognize lease assets and lease liabilities on the balance sheet for capital leases, but do

not recognize operating leases on the balance sheet. The lessee accounting model under Topic 842 retains

the distinction between operating leases and capital leases, which the new standard labels finance leases.

However, the new standard requires lessees to record a right-of-use (ROU) asset and a lease liability on the

balance sheet for operating leases. (For finance leases, a lessee’s lease asset also is designated an ROU

asset.) In general, the new standard permits a lessee to make an accounting policy election to exempt leases

with a term of one year or less at their commencement date from on-balance sheet recognition. The lease

term generally includes the noncancellable period of a lease as well as purchase options and renewal options

reasonably certain to be exercised by the lessee, renewal options controlled by the lessor, and any other

economic incentive for the lessee to extend the lease. An economic incentive may include a related-party

commitment. When preparing to implement Topic 842, lessees will need to analyze their existing lease

contracts to determine the entries to record on adoption of this new standard.

For a sale-leaseback transaction to qualify for sales treatment, Topic 842 requires certain criteria within

Topic 606 to be met. Topic 606 focuses on the transfer of control of the leased asset from the seller/lessee to

the buyer/lessor. A sale-leaseback transaction that does not transfer control is accounted for as a financing

arrangement. For a transaction currently accounted for as a sale-leaseback under existing U.S

ion to qualify for sales treatment, Topic 842 requires certain criteria within

Topic 606 to be met. Topic 606 focuses on the transfer of control of the leased asset from the seller/lessee to

the buyer/lessor. A sale-leaseback transaction that does not transfer control is accounted for as a financing

arrangement. For a transaction currently accounted for as a sale-leaseback under existing U.S. GAAP, an

entity is not required to reassess whether the transaction would have qualified as a sale and a leaseback

under Topic 842 when it adopts the new standard.

Leases classified as leveraged leases prior to the adoption of Topic 842 may continue to be accounted for

under Topic 840 unless subsequently modified. Topic 842 eliminates leveraged lease accounting for leases

that commence after an institution adopts the new accounting standard.

For institutions that are public business entities, as defined under U.S. GAAP, ASU 2016-02 is effective for

fiscal years beginning after December 15, 2018, including interim reporting periods within those fiscal years.

For institutions that are not public business entities, the new standard is effective for fiscal years beginning

after December 15, 2019, and interim reporting periods within fiscal years beginning after December 15, 2020.

Early application of the new standard is permitted for all institutions. An institution that early adopts the new

standard must apply it in its entirety to all lease-related transactions. If an institution chooses to early adopt

he new standard is effective for fiscal years beginning

after December 15, 2019, and interim reporting periods within fiscal years beginning after December 15, 2020.

Early application of the new standard is permitted for all institutions. An institution that early adopts the new

standard must apply it in its entirety to all lease-related transactions. If an institution chooses to early adopt

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

9

the new standard for financial reporting purposes, the institution should implement the new standard in its

Call Report for the same quarter-end report date.

For Call Report purposes, an institution must apply the new standard on a modified retrospective basis. Under

the modified retrospective method, an institution should apply a cumulative-effect adjustment to affected

accounts existing as of the beginning of the fiscal year the new standard is adopted. The cumulative-effect

adjustment to retained earnings for this change in accounting principle should be reported in Schedule RI-A,

item 2. The ROU asset recorded upon adoption should be reflected in Schedule RC, item 6, “Premises and

fixed assets” and the related lease liability recorded upon adoption should be reflected in Schedule RC-M,

item 5.b, “Other borrowings.” These classifications are consistent with the current Call Report instructions for

reporting a lessee’s capital leases. The agencies do not plan to add any new items to the Call Report for

reporting leases under the new lease accounting standard.

The agencies have received questions regarding how lessee institutions should treat ROU assets under the

agencies’ regulatory capital rules (12 CFR Part 3 (OCC); 12 CFR Part 217 (Board); and 12 CFR Part 324

(FDIC)). Those rules require that most intangible assets be deducted from regulatory capital. However, some

institutions are uncertain whether ROU assets are intangible assets

standard.

The agencies have received questions regarding how lessee institutions should treat ROU assets under the

agencies’ regulatory capital rules (12 CFR Part 3 (OCC); 12 CFR Part 217 (Board); and 12 CFR Part 324

(FDIC)). Those rules require that most intangible assets be deducted from regulatory capital. However, some

institutions are uncertain whether ROU assets are intangible assets. The agencies are clarifying that to the

extent an ROU asset arises due to a lease of a tangible asset (e.g., building or equipment), the ROU asset

should be treated as a tangible asset not subject to deduction from regulatory capital. An ROU asset not

subject to deduction must be risk weighted at 100 percent under Section 32(l)(5) of the agencies’ regulatory

capital rules and included in a lessee institution’s calculations of total risk-weighted assets. In addition, such

an asset must be included in a lessee institution’s total assets for leverage capital purposes. The agencies

believe this treatment is consistent with the current treatment of capital leases under the rules, whereby a

lessee’s lease assets under capital leases of tangible assets are treated as tangible assets, receive a 100

percent risk weight, and are included in the leverage ratio denominator. This treatment is also consistent with

the approach taken by the Basel Committee on Banking Supervision

(https://www.bis.org/press/p170406a.htm).

For additional information on ASU 2016-02, institutions should refer to the FASB’s website at:

http://www.fasb.org/cs/ContentServer?c=FASBContent_C&pagename=FASB%2FFASBContent_C%2FCompl

etedProjectPage&cid=1176167904031, which includes a link to the new accounting standard.

Accounting for Measurement-Period Adjustments Related to a Business Combination

In September 2015, the FASB issued ASU No. 2015-16, “Simplifying the Accounting for Measurement-Period

Adjustments.” Under ASC Topic 805, Business Combinations (formerly FASB Statement No

gename=FASB%2FFASBContent_C%2FCompl

etedProjectPage&cid=1176167904031, which includes a link to the new accounting standard.

Accounting for Measurement-Period Adjustments Related to a Business Combination

In September 2015, the FASB issued ASU No. 2015-16, “Simplifying the Accounting for Measurement-Period

Adjustments.” Under ASC Topic 805, Business Combinations (formerly FASB Statement No. 141(R),

“Business Combinations”), if the initial accounting for a business combination is incomplete by the end of the

reporting period in which the combination occurs, the acquirer reports provisional amounts in its financial

statements for the items for which the accounting is incomplete. During the measurement period, the acquirer

is required to adjust the provisional amounts recognized at the acquisition date, with a corresponding

adjustment to goodwill, to reflect new information obtained about facts and circumstances that existed as of

the acquisition date that, if known, would have affected the measurement of the amounts recognized as of that

date. At present under Topic 805, an acquirer is required to retrospectively adjust the provisional amounts

recognized at the acquisition date to reflect the new information. To simplify the accounting for the

adjustments made to provisional amounts, ASU 2015-16 eliminates the requirement to retrospectively account

for the adjustments. Accordingly, the ASU amends Topic 805 to require an acquirer to recognize adjustments

to provisional amounts that are identified during the measurement period in the reporting period in which

adjustment amounts are determined. Under the ASU, the acquirer also must recognize in the financial

statements for the same reporting period the effect on earnings, if any, resulting from the adjustments to the

provisional amounts as if the accounting for the business combination had been completed as of the

acquisition date

ified during the measurement period in the reporting period in which

adjustment amounts are determined. Under the ASU, the acquirer also must recognize in the financial

statements for the same reporting period the effect on earnings, if any, resulting from the adjustments to the

provisional amounts as if the accounting for the business combination had been completed as of the

acquisition date.

In general, the measurement period in a business combination is the period after the acquisition date during

which the acquirer may adjust provisional amounts reported for identifiable assets acquired, liabilities

assumed, and consideration transferred for the acquiree for which the initial accounting for the business

combination is incomplete at the end of the reporting period in which the combination occurs. Topic 805

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

10

provides additional guidance on the measurement period, which shall not exceed one year from the acquisition

date, and adjustments to provisional amounts during this period.

For institutions that are public business entities, as defined under U.S. GAAP, ASU 2015-16 is effective for

fiscal years, and interim periods within those fiscal years, beginning after December 15, 2015. For institutions

that are not public business entities (i.e., that are private companies), the ASU is effective for fiscal years

beginning after December 15, 2016, and interim periods within fiscal years beginning after December 15,

2017. The ASU’s amendments to Topic 805 should be applied prospectively to adjustments to provisional

amounts that occur after the effective date of the ASU. Thus, institutions with a calendar year fiscal year that

are public business entities were required to apply the ASU to any adjustments to provisional amounts that

occur after January 1, 2016, beginning with their Call Reports for March 31, 2016

he ASU’s amendments to Topic 805 should be applied prospectively to adjustments to provisional

amounts that occur after the effective date of the ASU. Thus, institutions with a calendar year fiscal year that

are public business entities were required to apply the ASU to any adjustments to provisional amounts that

occur after January 1, 2016, beginning with their Call Reports for March 31, 2016. Institutions with a calendar

year fiscal year that are private companies must apply the ASU to any adjustments to provisional amounts that

occur after January 1, 2017, beginning with their Call Reports for December 31, 2017. Early application of

ASU 2015-16 is permitted in Call Reports that have not been submitted.

For additional information, institutions should refer to ASU 2015-16, which is available at

http://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=1176166411212&acceptedDisclaimer=true.

Amending Previously Submitted Report Data

Should your institution find that it needs to revise previously submitted Call Report data, please make the

appropriate changes to the data, ensure that the revised data passes the FFIEC-published validation criteria,

and submit the revised data file to the CDR using one of the two methods described in the banking agencies'

FIL for the December 31, 2017, report date. For technical assistance with the submission of amendments to

the CDR, please contact the CDR Help Desk by telephone at (888) CDR-3111, by fax at (703) 774-3946, or by

e-mail at CDR.Help@ffiec.gov

asses the FFIEC-published validation criteria,

and submit the revised data file to the CDR using one of the two methods described in the banking agencies'

FIL for the December 31, 2017, report date. For technical assistance with the submission of amendments to

the CDR, please contact the CDR Help Desk by telephone at (888) CDR-3111, by fax at (703) 774-3946, or by

e-mail at CDR.Help@ffiec.gov.

Other Reporting Matters

For the following topics, institutions should continue to follow the guidance in the specified Call Report

Supplemental Instructions:

•

“Purchased” Loans Originated By Others – Supplemental Instructions for September 30, 2015

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201509.pdf)

•

True-up Liability under an FDIC Loss-Sharing Agreement – Supplemental Instructions for June 30, 2015

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201506.pdf)

•

Troubled Debt Restructurings, Current Market Interest Rates, and ASU No. 2011-02 – Supplemental

Instructions for December 31, 2014

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201412.pdf)

•

Determining the Fair Value of Derivatives – Supplemental Instructions for June 30, 2014

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201406.pdf)

•

Indemnification Assets and ASU No. 2012-06 – Supplemental Instructions for June 30, 2014

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201406.pdf)

•

Other-Than-Temporary Impairment of Debt Securities – Supplemental Instructions for June 30, 2014

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201406.pdf)

•

Small Business Lending Fund – Supplemental Instructions for March 31, 2013

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201303.pdf)

•

Reporting Purchased Subordinated Securities in Schedule RC-S – Supplemental Instructions for

September 30, 2011

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201109.pdf)

•

Treasury Department’s Capi

nst_201406.pdf)

•

Small Business Lending Fund – Supplemental Instructions for March 31, 2013

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201303.pdf)

•

Reporting Purchased Subordinated Securities in Schedule RC-S – Supplemental Instructions for

September 30, 2011

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201109.pdf)

•

Treasury Department’s Capital Purchase Program – Supplemental Instructions for September 30, 2011

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_FFIEC041_suppinst_201109.pdf)

•

Deposit insurance assessments – Supplemental Instructions for September 30, 2009

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200909.pdf)

SUPPLEMENTAL INSTRUCTIONS – DECEMBER 2017

11

•

Accounting for share-based payments under FASB Statement No. 123 (Revised 2004), Share-Based

Payment – Supplemental Instructions for December 31, 2006

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200612.pdf)

•

Commitments to originate and sell mortgage loans – Supplemental Instructions for March 31, 2006

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200603.pdf) and June 30, 2005

(https://www.ffiec.gov/PDF/FFIEC_forms/FFIEC031_041_suppinst_200506.pdf)

Call Report Software Vendors

For information on available Call Report preparation software products, institutions should contact:

Axiom Software Laboratories, Inc.

67 Wall Street, 17th Floor

New York, New York 10005

Telephone: (212) 248-4188

http://www.axiomsl.com

DBI Financial Systems, Inc.

P.O. Box 14027

Bradenton, Florida 34280

Telephone: (800) 774-3279

http://www.e-dbi.com

Fed Reporter, Inc.

28118 Agoura Road, Suite 202

Agoura Hills, California 91301

Telephone: (888) 972-3772

http://www.fedreporter.net

FIS Compliance Solutions

16855 West Bernardo Drive,

Suite 270

San Diego, California 92127

Telephone: (800) 825-3772

http://www.callreporter.com

FiServ, Inc

O. Box 14027

Bradenton, Florida 34280

Telephone: (800) 774-3279

http://www.e-dbi.com

Fed Reporter, Inc.

28118 Agoura Road, Suite 202

Agoura Hills, California 91301

Telephone: (888) 972-3772

http://www.fedreporter.net

FIS Compliance Solutions

16855 West Bernardo Drive,

Suite 270

San Diego, California 92127

Telephone: (800) 825-3772

http://www.callreporter.com

FiServ, Inc.

1345 Old Cheney Road

Lincoln, Nebraska 68512

Telephone: (402) 423-2682

http://www.premier.fiserv.com

KPMG LLP

303 Peachtree Street, Suite 2000

Atlanta, Georgia 30308

Telephone: (404) 221-2355

https://advisory.kpmg.us/risk-

consulting/frm/capital-

management.html

Lombard Risk

One Gateway Center,

26th Floor

Newark, New Jersey 07102

Telephone: (973) 648-0900

http://www.lombardrisk.com

SHAZAM Core Services

6700 Pioneer Parkway

Johnston, Iowa 50131

Telephone: (888) 262-3348

http://www.cardinal400.com

Wolters Kluwer Financial Services

130 Turner Street, Building 3,

4th Floor

Waltham, Massachusetts 02453

Telephone (800) 261-3111

http://www.wolterskluwer.com