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OCC Bulletin 2019-51 | October 29, 2019

Consolidated Reports of Condition and Income: Request for Comment on Reporting Data on Loans to Small Businesses and Small Farms in the Call Report


Chief Executive Officers of All National Banks, Federal Savings Associations, and Federal Branches and Agencies of Foreign Banks; Department and Division Heads; All Examining Personnel; and Other Interested Parties


On October 17, 2019, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (collectively, the agencies) published a request for comment on ways to modify the current requirements for reporting data on loans to small businesses and small farms in the Consolidated Reports of Condition and Income (call report) so that the reported data better reflect lending to these sectors of the U.S. economy. Comments must be received by the agencies no later than December 16, 2019.

Note for Community Banks

The agencies are seeking feedback from all national banks and federal savings associations (collectively, banks), including community banks, that report data on Schedule RC-C, Part II, “Loans to Small Businesses and Small Farms.”


The U.S. Government Accountability Office (GAO) reviewed the data collected on the call report Schedule RC-C, Part II as part of a study of the effect of regulations on small business lending. In summarizing its findings with respect to call report data on loans to small businesses, the GAO indicated that the amounts reported by community banks do not accurately capture lending to small businesses generally due to (1) the definition of small business loans excludes loans greater than $1 million; (2) the thresholds have not been adjusted for inflation since 1992; and (3) reported amounts are based on loan size rather than the size of the borrowing entity. The GAO recommended that the agencies should reevaluate, and modify as needed, the requirements for the data banks report in the call report to better reflect lending to small businesses.

Based on the GAO’s recommendation, the agencies are reviewing the data currently collected on Schedule RC-C, Part II. Feedback from this request for comment will be used to assess what steps the agencies should take.

Further Information

Please contact Cady Codding, Senior Policy Accountant, Office of the Chief Accountant, at (202) 649-6280; or Kevin Korzeniewski, Counsel, Chief Counsel’s Office, (202) 649-5490.

Grovetta N. Gardineer
Senior Deputy Comptroller for Bank Supervision Policy

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