3 FFIEC Call Report Forms
The Three FFIEC Call Report Forms: Which One Tells Your Bank’s Story?
Every quarter, banks across the country sit down to tell their story, the real financial picture. And just like Goldilocks wandering into the bears’ cottage, that story has to fit just right. The FFIEC Call Report is how the story gets told, but not every institution is served the same bowl of porridge.
In fact, there are three different Call Report forms, and the one your bank files depends on its size, capital standards, and whether it has any international flair. Choose the wrong one, and suddenly the porridge is too hot, too cold, or far more work than necessary.
Here’s a breakdown of the three forms, and which one belongs at your bank’s table.
FFIEC 031: Papa Bear’s Call Report (The Big One)
Papa Bear doesn’t do anything small, and neither does the FFIEC 031. This is the most comprehensive Call Report form and is required for institutions of any size that maintain at least one foreign office, including:
- A foreign branch or consolidated subsidiary
- A majority-owned Edge or Agreement corporation
- An international banking facility (IBF)
Even banks without foreign offices may still be served Papa Bear’s porridge if they meet either of the following:
- They are an advanced approaches institution for regulatory capital purposes
- They have $100 billion or more in total consolidated assets
- With expanded schedules and detailed international reporting requirements, FFIEC 031 is the largest, most complex bowl on the table. Necessary for global banks, but definitely not light reading.
FFIEC 041: Mama Bear’s Call Report (Just Right for Most)
Mama Bear likes balance, and so does the FFIEC 041. This is the form most institutions file, making it the industry’s workhorse.
It applies to banks with:
- Domestic offices only, and
- Less than $100 billion in total assets
The FFIEC 041 shares much of the same structure and instructions as the FFIEC 031, but without the extra international reporting. It’s thorough without being overwhelming, exactly why it fits most domestic institutions.
One important plot twist:
FFIEC 041 filers with less than $5 billion in total assets as of June 30 may elect to switch to the FFIEC 051 beginning with the following March 31 reporting .
Mama Bear won’t mind if you downsize.
FFIEC 051: Baby Bear’s Call Report (Nice and Simple)
Baby Bear keeps things simple, and so does the FFIEC 051. This form is designed for the least complex institutions, those with:
- Domestic offices only, and
- Total assets under $5 billion, as of June 30 of the prior year
The FFIEC 051 significantly reduces reporting burden by:
- Eliminating certain line items and schedules
- Converting others to annual or semiannual reporting
There is one extra item on Baby Bear’s plate: Supplemental Schedule SU, which must be completed quarterly. Fortunately, it consists mostly of yes/no questions, with follow-up detail only when applicable.
Just be careful, once a bank exceeds $5 billion in total assets (measured as of June 30 of the prior year), it must move out of Baby Bear’s chair and transition to the FFIEC 041 beginning with the first quarter of the following year.
Growth is exciting, but it comes with more porridge.
FIL 56-2025: Regulators Reconsider the Menu
On December 1, 2025, regulators issued FIL 56-2025, asking the industry a simple question: Is this porridge too complicated?
The agencies are requesting public input on ways to streamline the Call Report and reduce regulatory burden, including feedback on:
- What banks already collect and maintain in their systems for internal and Call Report purposes
- Which schedules and line items require the most time and resources each quarter
- Whether changes to reporting frequency could improve efficiency
- How current and emerging technologies could simplify Call Report preparation
- Notably, regulators are considering whether to further streamline the FFIEC 051 and expand eligibility to banks with total assets above the current $5 billion threshold.
Comments are due January 30, 2026, and additional developments are expected.
Final Thoughts
The Call Report may be a regulatory requirement, but the version your bank files is part of its story, a reflection of its size, structure, and complexity. Understanding the differences among the FFIEC 031, 041, and 051 helps ensure your institution is reporting accurately, efficiently, and confidently.
After all, no one wants to discover, mid-quarter, that they have been sitting in the wrong chair, eating the wrong porridge, and answering far more questions than necessary.
