Regulatory Wrap-Up: Key Changes
Regulatory Wrap-Up: Key Changes
Now and Heading into 2026
As we close out 2025 and look toward a fresh new year, regulators have delivered a full stocking of updates that will shape our Call Report community here at Call Report Resources. First, we have new Call Report requirements as of 12/31/2025 and then potentially some impacts looking ahead in 2026. Here are some important developments to have on your radar.
ADOPT NOW BY 12/31/2025:
FIL 30-2025: Revisions to Call Report Forms and Instructions
FIL 30-2025 clarifies that loans modified for borrowers experiencing financial difficulty must be reported for 12 months following modification. These revisions take effect on December 31, 2025. Early adoption was permitted with the September 2025 Call Report. Be sure to adopt these changes before filing the 12/2025 Call Report. You can see the redline for the updated Call Report instructions in Call Report Resources, or here:
FFIEC Red Line Reporting Form 051
KEEP ON YOUR RADAR in 2026
Community Banks that qualify for CBLR Framework- take note:
FIL 55-2025: Proposed Changes to the Community Bank Leverage Ratio (CBLR) Framework just released November 25, 2025.
Regulators are seeking public comment on proposed updates to the Community Bank Leverage Ratio (CBLR) framework that would lower the required CBLR from 9% to 8% and extend the grace period for banks that fall out of compliance from two quarters to four. The proposal aims to preserve strong capital levels by requiring community banks that opt into the CBLR framework to maintain capital comparable to, or higher than, risk-based standards, while keeping the leverage ratio at twice the minimum required for non-CBLR banks. A final rule is expected after the agencies review public feedback. We encourage you to comment to support any measures that make sense for your institution.
KEEP IN MIND
All of the prudential regulators have introduced expanded time frames for community bank regulatory exams. They have also stated that they will have greater reliance on the bank’s own or third-party auditors and risk management partners. What does this mean for you?
It certainly means that community banks may have fewer regulator visits. However, it puts the focus squarely on the bank’s risk management process to identify issues and address them. It makes Call Report data accuracy even more pivotal. Be sure that the Call Report is covered adequately in audit and risk management at your institution before someone calls it to your attention!
Here is an example of the community bank supervision shift:
OCC Bulletin 2025-24: A Key Shift in Community Bank Supervision
Just in time for the new year, the OCC’s Bulletin 2025-24 introduces a more customized, risk-focused approach to community bank supervision, effective January 1, 2026. By eliminating exam activities driven solely by OCC policy rather than statute, examiners gain flexibility to tailor scope and timing based on each bank’s unique risk profile. Examiners will concentrate more heavily on material and emerging risks, reinforcing the agency’s emphasis on safety and soundness and data-driven oversight.
STAY ALERT
Brokered Deposits: Anticipated Reforms and Heightened Oversight
Brokered deposits remained a regulatory focus in 2025, with bipartisan proposals in Congress seeking to modernize definitions and oversight. If enacted, these changes could ease restrictions on certain deposits widely used by community and fintech-partner banks. Staying alert to legislative developments will help institutions prepare for potential shifts in funding strategies and Call Report treatment, ensuring they enter 2026 ready to unwrap new opportunities. Our CRR blog discusses these proposals in more detail.
Call Report Resources Blog - Brokered Deposits Back in Focus
Wrapping Up the Year
As we deck the halls and ring in the New Year, these regulatory updates offer both clarity and opportunity for banks preparing their 2026 strategies. Whether adjusting Call Report processes, evaluating supervision changes, or responding to proposed capital updates, now is the perfect time to tighten up internal processes and start the new year on solid footing.
Here’s to a joyful holiday season, a well-earned celebration of 2025 successes, and a bright, confident, and prosperous 2026!
