General

1. General • How to report • Deposit • Pass through balances • Trust Funds • Escrow Funds • Exempt vs. Non Exempt • Primary Obligations • Data accuracy and edit explanations • Call vs. FR 2900

2. How to Report – Consolidation • Deposits, vault cash, and allowable deductions for: • Banks head office • Branches located in the U.S. • Bank operating subsidiaries located in the U.S. • U.S. military facility branches

3. How to Report - Consolidation • Do not consolidate • Edge and agreement subsidiaries • Balances due to and due from non-U.S. branches • International banking facilities (IBF) • Different from the Regulatory Agency Statement of Conditions (Call Report) report

4. How to Report – Overdrafts & Negative Balances • Negative (-) balances should be reported as zero • Overdrawn individual accounts should be considered a loan and not reported on the FR 2900 • Bona fide cash management arrangement: • Agreement between an institution and a depositor where balances in one account may be used to offset the overdrafts in another account of the same type or a related depositor

5. How to Report – Record Keeping • “Close of Business” • Cut off time for posting transactions to the GL accounts • Should be consistently applied • Must be posting debits and credits to be considered open

6. What is a Deposit? • Regulation D definition: The unpaid balance of money or its equivalent received or held by a depository institution in the usual course of business and for which it has given or is obligated to give credit, either conditionally or unconditionally, to an account, including interest credited, or which is evidenced by an instrument on which the depository institution is primarily liable;

7. Pass Through Balances Federal Reserve says your bank has a reserve balance to hold Respondent Bank Correspondent Bank Exclude from B1 – Due From DI Exclude from A1a – Due To DI Funds to satisfy FHLB Non-member bank NCUA Central Liquidity Facility Depository Institution with Fed account

8. Trust Funds • Do not report: • Segregated from general assets • Not available for general investment or lending • Report: • Deposited into other departments of the reporting institution • Reporting DI • Other DI’s • Mingled with general assets of the reporting DI

9. Escrow Funds • Funds deposited with a DI under an agreement that requires the DI to pay all or some portion of the funds to a third party at a certain time or upon fulfillment of certain conditions. • Can be set up as: • Demand deposit • Savings deposit • Time deposit

10. Exempt Vs. Non-Exempt The concept of exempt and non-exempt entities applies only to primary obligations. ** See FR 2900 glossary for an all inclusive list

11. Primary Obligation What is a primary obligation? • Borrowing by the DI When to report? • Counter party non-exempt and • Proceeds supply or maintain availability of funds Where to report? • Transaction accounts • Savings deposits • Time deposits

12. Data Accuracy & Edit Explanations • Data Accuracy • Monetary policy and FOMC operations • Publishing aggregate data • Reserve requirement calculations • Reduces revisions!!!!!!!! • Edit Explanations • Who • What • When (or how long) • Why • How

13. Sample Explanations • NOW/Share Drafts (A2) • Increase of $15m on 6/22 • Explanation possibilities: • Yes it did go up, the total is higher • Some of the accounts increased • The County Treasurer’s office opened an account with a $15m initial deposit on 6/22 as a result of winning the public funds bid • Which response would you choose? 3

14. FR 2900 Vs. “Call “ Report • Timing • Quarterly • Expectations • Data to be accurate on both reports • Edits to be researched • Explanations • Revisions • Common causes • Primary obligations • Adjustments

15. Questions