Overlapping Cell Groups with line items 2.b.1 to 2.b.5 (FFIEC031/041, RC-C Memoranda)
(Doc ID 2689163.1)
Last updated on JULY 15, 2020
Applies to:Oracle Financial Services - Regulatory Reporting for US Federal Reserve - Lombard Risk Integration Pack - Version 8.0.9 and later
Information in this document applies to any platform.
REG REP USFED 22.214.171.124.0
Schedule RC-C Memoranda
Issue 1 : cell A572
This cell Reports 'CONLOANCREDCARD' (consumer loan credit card) twice in below Cell groups as per the HM linkage document
a. cell groups 6 and 7
b. cell groups 8 and 9
Issue 2 :
Floating Rate Credit Card exposures which cross the cap/floor rates should be treated as fixed rate exposures and these exposures must be reported in cell A572 (M.2.b.(3)).
However in the current configuration, such exposures are still getting reported within all Memo items 2.b.1 - 2.b.5
Instruction reference for Issue 2:
The above floating rate Credit cards given the fact that are treated as fixed rate exposures should follow the same logic as highlighted below-
Fixed rate 'Credit cards' and 'Other revolving credit plans' are considered to have a remaining maturity of over one year through three years and should be reported in
Memorandum item 2.b.(3), regardless of the actual maturity experience or expectation.
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