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Fe d e r a l R e s e r v e B a n k of N ew York N E W Y O R K , N. Y. 1 0 0 4 - 5 AREA CODE 212 791-6164 December 23, 1977 POSTPONEMENT OF EFFECTIVE DATE OF REVISED REPORTS OF CONDITION AND INCOME To the Chief Executive Officer of Each State Member Bank in the Second Federal Reserve District: ' The Board of Governors of the Federal Reserve System and the other Federal bank regulatory agencies have postponed the effective date of the revised Reports of Condition and Income. Enclosed is a copy of a letter dated December 20, 1977, signed by Chairman Burns to State member banks announcing the postponement. We will inform you of the new date when it is set by the Board of Governors. Questions regarding this matter may be directed to Richard A. Nelson, Manager, Banking Studies Department (Tel. No. 212-791-5849). PAUL A. VOLCKER, President. CHAIRMAN OF THE FEDERAL BOARD OF GOVERNORS R E S E R V E S TSTEM W A S H I N G T O N , O. C . 20551 December 20, 1977 TO THE CHI E F E X E C U T I V E O F F I C E R OF THE M E M B E R B A N K A D D R E S S E D On O c t o b e r 20, the three F e deral b a n k i n g s u p e r vi s o r y age n c i e s issued for com m e n t p r o p o s a l s for r e v i s i o n s in the R e ports of C o n d i t i o n and Income. These p r o p o s a l s w o u l d a f f e c t m a i n l y banks w i t h foreign offices but there w e r e also a n u m b e r of cha n g e s p ro p o s e d for o th e r banks with m o r e than $300 m i l l i o n in assets and some r e l a t i v e l y m i n o r c h anges for b anks b e l o w that size. U n d e r the p roposals, the r e v i s i o n s w e r e be effe ct iv e w i t h the reports to be filed as o f M a r c h 31, 1978. to In r e s p o n s e to these p r oposals, b a nks and others h a v e m a d e a s i g n if ic an t n u m b e r of thoug h t f u l and c o n s t r u c t i v e c o m m e n t s - - b o t h on the subs ta nc e of the changes and on timing and o t her a d m i n i s t r a t i v e a s p e c t s - that the a g encies are now in process of evaluating. B e c a u s e of the time needed to give c a reful c o n s i d e r a t i o n to these comments and in r e s p o n s e to the freque n t l y expr e s s e d request for m o re adeq ua t e lead time for banks to p r e p a r e for the r e vised r e p o r t i n g r e qu irements, the a g encies have c o n cl u d e d that the o r i g i n a l l y proposed M a r c h 31 i m p l e m e n t a t i o n date w o u l d be i n a p p r o p r i a t e and u n d u l y b u r d e n s o m e on b a n k s . In addition, the Se c u r i t i e s and E x c h a n g e C o m m i s s i o n has r e cently released for comment a revised v e r s i o n of its p r o po s a l s for a n e w A r t i c l e 9 of its R e g u l a t i o n S-X d e a ling w i t h financial st a t e m e n t s of b a n k h o l di ng compa n i e s and banks. The prop o s e d M a r c h 31, 1978 i m p l e m e n t a t i o n date for the b a n ki n g agencies' revised C o n d i t i o n and I n come R e ports w ou ld not ha v e a f forded the agencies o p p o r t u n i t y to give a d e q u a t e a t t e nt i on to SEC's revised proposals. (O v er) TO THE CHIEF EXECUTIVE OFFICER OF THE MEMBER BANK ADDRESSED Page 2 In light of these circumstances, the banking agencies have deferred the date of implementation of the revised Condition and Income Reports. After further consideration of these and other factors affecting the choice of an appropriate date, the agencies will announce in the near future a new date for implementation of the revised reports. I want to assure you that we greatly appreciate the time and attention that many bankers have devoted to their detailed analyses of the proposed revisions and that we will give all comments received our careful consideration before settling on the final form and contents of the revised reports. Sincerely yours, Arthur F. Burns