HTVAs And Call Report Schedule RC-T
HTVAs And Call Report Schedule RC-T . Federal Financial Institutions Examination Council’s ‘call report’ (FFIEC 041) making clear state and Federal banks must fair market value HTVAs held in any trust and custody account included on Form RC-T of the call report. Schedule RC-T/Fiduciary and Related Services requires the bank to report the market value of both managed and non-managed assets held in all types of accounts. The Supplemental Instructions under ‘Fiduciary and Related Services’ states:
Banks that have fiduciary or related activities in the form of assets or accounts must provide information on these assets and accounts... . In item 4, column A, of Schedule RC-T, banks must report the market value of managed assets held in personal trust and agency accounts. ...’ (emphasis added)
At a presentation to the FIRMA Annual Convention in April 2005 Joel Miller, a Senior Advisor in the Asset Management Division of the Office of the Comptroller of the Currency, stated ‘ call report data integrity is critical. Filings must be accurate (because) RC-T data is vital to monitor fiduciary risk in bank. Sanctions are possible for material errors.’ Miller observed that banks have an obligation to provide valuations, for three reasons: (1) it is their duty to their accounts; (2) for regulatory reporting purposes (ERISA certified statements, IRA Form 5498 and Call Report Schedule RC-T); and (3) it is the basis for fees. He stated ‘banks should have a methodology and pricing cycle appropriate for the type of account and the type of asset including exchange traded equities, bonds, unique assets (real estate, closely held securities, limited partnerships) and alternative investments (hedge funds).