Bank Policy Institute Recommends Changes to Country Exposure Reporting Forms

The Bank Policy Institute (BPI") urged federal banking agencies to revise and consolidate information on country exposures currently collected on Federal Financial Institutions Examination Council ("FFIEC") reporting forms. 

In a comment letter to the Office of the Comptroller of the Currency, the Federal Reserve Board and the Federal Deposit Insurance Corporation, the nonpartisan banking policy group urged the agencies to reduce reporting burdens associated with the Country Exposure Report ("FFIEC 009") and the Country Exposure Information Report ("FFIEC 009a").

The FFIEC 009 and FFIEC 009a forms require US banking organizations to provide detailed information on their exposures to foreign countries, including breakdowns by counterparty, guarantor, currency, maturity and sector. The agencies recently sought public input on extending these reports and invited suggestions on ways to "minimize the burden of information collections."

BPI recommended the agencies:

1. Revise SFT and NDFI Reporting. BPI urged the agencies to permit risk-transfer recognition for securities financing transactions ("SFTs") and to align their reporting treatment with other collateralized claims and the regulatory capital rules. The association argued that reporting SFTs based on underlying collateral—rather than counterparty—would better reflect true risk and align with other regulatory reports. BPI also called for the agencies to align the reporting of non-depository financial institutions with the Call Report for consistency.

2. Consolidate Duplicative Reports. The BPI recommended folding the granular cross-border exposure reporting required by the FR 2510—currently applicable to US GSIBs—into the FFIEC 009 as a separate memo section completed only by those institutions. The association noted that both forms rely on the same dataset and that consolidation would preserve supervisory access to detailed information while allowing GSIBs to stop maintaining separate processes and control frameworks for essentially the same reporting.

3. Introduce Materiality Thresholds. The BPI proposed limiting country-level disclosures to each filer's top 35 foreign exposures and only those exceeding a $2 billion materiality threshold, with smaller exposures aggregated into other categories. The association said regional breakouts could be retained to preserve geographic visibility. BPI explained that this approach—already used in the FR 2510—would eliminate the need to report immaterial positions across more than 200 jurisdictions.