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Call report instructions 051: its own book, pages and update cycle

The FFIEC 051 Call Report instructions are a separate book for domestic-only banks under $5 billion, with their own page numbers, their own Glossary and their own update cycle. The short form saves hours, but small teams still answer instruction questions against a book that changes; this guide shows where Call Report Instructions Search fits them and where it does not yet.

Updated · 12 min read

The call report instructions 051 are the FFIEC 051 instruction book: "Instructions for Preparation of Consolidated Reports of Condition and Income for a Bank with Domestic Offices Only and Total Assets Less than $5 Billion," posted each quarter by the FDIC and the FFIEC (FDIC, FFIEC 051 instructions). It is not an abridged copy of the FFIEC 031 and 041 book; the General Instructions of each book say "A separate instruction book covers" the other form (FFIEC 051 General Instructions). The two books share most rules, but the same rule sits on different page numbers, their Glossaries run to different lengths, and one book can change in a quarter when the other does not. For a community bank, where one or two people prepare the whole report, that means a question answered from the wrong book, or from last quarter's page, is easy to get and hard to spot. Botminds' Call Report Instructions Search answers from the instruction book for the form and quarter asked, with the page and its revision date; its sample configuration is a bank filing the FFIEC 031 and the FR Y-9C, and a bank filing the 051 loads the 051 book instead.

Two Call Report instruction books, compared as documents

FFIEC 031 and 041 bookFFIEC 051 book
Who uses itBanks with foreign offices or $100 billion or more (031); other domestic-only banks (041)Domestic-only banks under $5 billion, unless excluded or told by the regulator to file the 041
Glossary, September 2026137 pages128 pages
Schedule RC-E file, September 202634 pages29 pages
Updates, September 2025 to September 2026December 2025, June 2026, September 2026December 2025, September 2026
Same December 2025 change to RC-CPage RC-C-21Page RC-C-24
Brokered Deposits Glossary page replaced, December 2025A-20aA-14a
Schedule found only in this bookRC-S, RC-V, RC-D, RC-P, RC-Q and othersSU, Supplemental Information
FDIC instruction indexes for both books (read October 27, 2026); FFIEC 051 and FFIEC 031 and 041 Instructions Updates for December 2025 and September 2026; page counts of the September 2026 PDF files as posted by the FDIC; FFIEC 051 General Instructions. Which form a bank files is set out in Call Report Preparation's guide to the FFIEC 051 vs 041.

Where are the FFIEC 051 call report instructions?

On the FDIC's FFIEC 051 instructions page and the FFIEC's reporting forms page, as a set of files: a cover page, General Instructions, a Glossary and one file per schedule, each marked with the quarter it was last revised (FDIC, FFIEC 051 instructions). The quarter's FFIEC 051 Instructions Update, which lists the replaced pages, is posted on the FDIC's current-quarter page with the forms and the Supplemental Instructions (FDIC, current quarter).

Check the header of every page you rely on. On October 27, 2026, the FDIC's FFIEC 051 instructions page still listed its "Instructions Update" as of December 2025, although the September 2026 update for the 051 was posted on the current-quarter page, and its link for Schedule RC-E opened the file for the FFIEC 031 and 041 book, headed "FFIEC 031 and 041" (RC-E, FFIEC 031 and 041), while a separate FFIEC 051 RC-E file exists (RC-E, FFIEC 051). The rules in the two RC-E files overlap, but their page numbers do not, so a 051 preparer citing page RC-E-10 from the wrong file is citing a page that, in the 051 book, says something else.

How are the 051 instructions different from the 041 instructions?

Mostly in what they leave out, and in where they put what they keep. The 051 General Instructions describe the form as Schedules RC and RC-B through RC-T, the income schedules RI through RI-E, and Schedule SU, which gathers, in a few questions, what the longer forms ask about complex or specialised activities a small bank may have (FFIEC 051 General Instructions). Schedules such as RC-S on servicing and securitization and RC-V on variable interest entities exist only in the 031 and 041 book. The schedule-by-schedule comparison, and who may file which form, is covered in Call Report Preparation's guide to the FFIEC 051 vs 041.

For anyone answering questions, the difference that matters is that the books are paginated independently. When the agencies changed how long modified loans to borrowers in financial difficulty are reported, the December 2025 update replaced RC-C-21 in the 031 and 041 book and RC-C-24 in the 051 book (031 and 041 update; 051 update). A memo that says "see RC-C-21" is only meaningful with the book named beside it.

Do 051 and 041 instructions change at the same time?

Often, but not always, and not on the same pages. In June 2026 the 031 and 041 book was updated for two new FFIEC 031 data items, while the 051 book stayed as of December 2025 (FIL-33-2026). In September 2026 both books changed for the same three reasons, yet the replaced pages differ, and the 051 update includes a page of Schedule RC-N, RC-N-12, where the 031 and 041 update has none (FFIEC 051 update; FFIEC 031 and 041 update).

The same September 2026 changes, in two books

FFIEC 031 and 041 bookFFIEC 051 book
Reciprocal and custodial deposits

FFIEC 031 and 041 book: RC-E-6; RC-E-8a to RC-E-10d; RC-E-19 to RC-E-20b; RC-O-8 to RC-O-8b

FFIEC 051 book: RC-E-7; RC-E-10 to RC-E-12a; RC-E-14a; RC-E-23 to RC-E-25; RC-O-7 to RC-O-8

Community bank leverage ratio at 8 percent

FFIEC 031 and 041 book: RC-R-1 to RC-R-2b

FFIEC 051 book: RC-R-1 to RC-R-2b; RC-R-13 to RC-R-14

Weekend and holiday due dates

FFIEC 031 and 041 book: General Instructions, pages 10 to 10a

FFIEC 051 book: General Instructions, pages 9 to 10

Glossary

FFIEC 031 and 041 book: A-20a; A-78; A-102; A-118a to A-119

FFIEC 051 book: A-14 to A-14a; A-67; A-83

Other

FFIEC 031 and 041 book: RC-S-1

FFIEC 051 book: RC-N-12

FFIEC 031 and 041 and FFIEC 051 Call Report Instructions Updates, September 2026. The grouping of pages by topic is ours, from FIL-62-2026.

How many hours does a small bank spend on the call report?

About 35 hours a quarter on the agencies' own estimate for the FFIEC 051, against about 56 for the FFIEC 041 and 86 for the FFIEC 031. The December 2025 Paperwork Reduction Act notice gives "86.25 (FFIEC 031), 55.56 (FFIEC 041), and 34.99 (FFIEC 051)" as the estimated average burden hours per quarter by form (90 FR, December 11, 2025). Those are averages across banks of very different sizes and complexity, and they count filing work, not the time spent finding out what an instruction means.

Estimated hours per quarter to file each Call Report form

FFIEC 031
86.25 hours
FFIEC 041
55.56 hours
FFIEC 051
34.99 hours
OCC, Federal Reserve and FDIC, Proposed Agency Information Collection Activities, Federal Register, December 11, 2025 (FR Doc 2025-22481): estimated average burden hours per quarter by form, across the three agencies.

The short form saves about 21 hours a quarter against the 041 on those averages, and the reduced reporting the agencies introduced in 2019 for first- and third-quarter reports saves more. But the instruction work does not fall in the same proportion. A 051 bank still reads the same quarterly letter and Supplemental Instructions as a $90 billion bank; in September 2026 that meant the same deposit and capital changes, in a book of 128 Glossary pages instead of 137. The rules a small bank has to apply are not a third smaller, even if the report is.

Is compliance cost higher for small banks?

As a share of expenses, yes, by a wide margin, on the best public evidence. A Federal Reserve Bank of St. Louis study of 469 commercial banks under $10 billion that answered the Conference of State Bank Supervisors' 2015 survey found that banks under $100 million in assets reported compliance costs averaging 8.7 percent of noninterest expense, against 2.9 percent for banks of $1 billion to $10 billion, and that personnel was by far the largest compliance cost in every size group (Dahl, Meyer and Neely, "Scale Matters," 2016). The study covers all compliance, not the Call Report alone, and it is a decade old; its direction, that fixed rules cost small banks proportionally more, is what matters here.

The short form is shorter; the rulebook behind it is not proportionally smaller

34.99hrs

estimated hours per quarter to file the FFIEC 051, the agencies' average

8.7%

compliance cost as a share of noninterest expense, banks under $100 million (2015 survey)

2.9%

the same share for banks of $1 billion to $10 billion

128

pages in the FFIEC 051 Glossary, September 2026, against 137 in the 031 and 041 book

Source: 90 FR, December 11, 2025; St. Louis Fed, Scale Matters (2016); FDIC, FFIEC 051 instructions

Will the agencies simplify the call report?

They have asked how, and said they plan to propose changes; no proposal had been published by October 27, 2026. The December 2025 request for information asked "In what ways, if any, should the agencies consider modifying the Call Report forms or instructions, including their layout, structure, and availability, to improve their usability," and said the agencies want views on opening the FFIEC 051 to larger banks (Request for Information: Streamlining the Call Report). The second-quarter 2026 letter said the agencies are reviewing the comments and, together with the regulatory review under the Economic Growth and Regulatory Paperwork Reduction Act and "results of the 2027 statutorily mandated full review," plan to put proposed changes to the forms and instructions out for comment where they see fit (FIL-33-2026; FFIEC 051 vs 041 follows what that could mean for the short form).

The statute behind that review requires the agencies, every five years, to review the schedules and "reduce or eliminate any requirement to file information or schedules" no longer necessary or appropriate (12 U.S.C. 1817(a)(11)). One result has already arrived: the option, from September 2026, to file on the next business day when the due date falls on a weekend or holiday was given "in response to" comments on the request for information. For an instruction reader, simplification means more change, not less, for a while: every revised form brings a revised book, and every revised book a round of memo checks.

Which questions does a small reporting team ask most?

The same kinds a large bank asks, with fewer people to ask. On the solution's sample data at a large bank, the lines that draw the most questions are loans to nondepository financial institutions, deposits of states and political subdivisions, and loans to public bodies secured by real estate; a community bank with a municipal deposit base and a few lines to non-bank lenders meets the same instructions on a smaller scale. What differs is who answers: at a small bank the person who prepares the Call Report may also be the person everyone else asks, and the CFO who signs it may be the only reviewer.

What people ask, by line and by team, in one quarter

The Insights screen, What people ask, acting as the Regulatory Reporting Manager, for Q3 2026, October 1 to 22. Counters: 468 questions, against 611 the quarter before, from 31 of 34 preparers; 90% answered with citations, 421 questions with all three layers; 47 sent to the Policy Lead, 39 ruled; median 38 seconds to a cited answer against a target of under 1 minute. A suggestion: RC-C item 9.a drew 31 questions from 7 people in 4 teams, 9 went to the Policy Lead; a one-page note would answer most of them, with a Draft the note button. Lines asked most: RC-C 9.a 31, RC-E 3 deposits of states and political subdivisions 19, RC-C 1 or 8 loans to public bodies secured by real estate 17, HC-C 9.a 12, RC-N past due status of restructured loans 11, RC-C 8 or 10.b leases to municipalities 6. Questions by team across nine finance teams.
Call Report Instructions Search on sample data about a fictional $92 billion bank. Names and accounts typed into questions are masked on this screen.

Where Call Report Instructions Search fits a 051 bank, and where it does not yet

It fits where questions are frequent and the answerer is scarce. The agents search the instruction book for the form and quarter asked, check every cited page's revision date against the bank's own memo, show what the bank filed on the line before, and route what the sources do not settle; on a small team that routed queue is the CFO's or controller's, with a clock. The design target is a cited answer in under a minute, measured in the live solution.

Two limits are worth saying plainly. The solution's described corpus, and everything shown on this page, is the FFIEC 031 and 041 book and the FR Y-9C; a 051 filer's corpus is the FFIEC 051 book, loaded and approved by quarter like any other, and the bank should see it answer its own last-quarter questions from that book before relying on it. And a bank with a handful of instruction questions a quarter, all answered by one experienced preparer, may get more from a good quarterly routine than from software; the quarterly routine for instruction updates works on paper as well.

The agents' plan, step by step, before any answer is shown

An answer in progress for 'Where do we report the $240M of leases to municipalities?' on the FFIEC 031 for Q3 2026. A line says the agents are working and nothing is shown until every layer is cited. Steps with timings: the Answer agent read the question, leases, lessees are municipalities, FFIEC 031 and FR Y-9C, Q3 2026, in 0.9 seconds; searched 1,410 pages and found 9 passages, RC-C items 10, 10.b and 8 decide it, in 6.2 seconds; the Change agent found RC-C-20a revised (12-24) before the bank's memo and no mention of item 10 in the March, June and September 2026 supplemental instructions; the Precedent agent found the memo approved December 15, 2025 and filings in item 10.b for three quarters; the Mapping agent and the citation check, 7 of 7 quoted sentences matching, still to finish.
Call Report Instructions Search on sample data about a fictional bank filing the FFIEC 031. The form and quarter in the question decide which book is searched.

Before trusting any 051 answer, from a person or a tool

  1. The page header says FFIEC 051

    Not "FFIEC 031 and 041"; the same schedule letter does not mean the same page.

  2. The page date is in force for the report date

    Compare the footer date with the quarter's Instructions Update for the 051.

  3. The quarter's Supplemental Instructions were read

    They apply to all three forms and carry topics the book has not absorbed.

  4. The reduced-reporting quarter is known

    Since 2019 some FFIEC 051 items are not collected in the first and third quarters.

  5. The answer names the line and the sentence

    A line without the sentence that decides it cannot be checked by the CFO who signs.

Our checklist, from the FFIEC 051 instructions, the FFIEC 051 Instructions Updates and the 2025 request for information's description of reduced reporting.

Questions people ask

Is the FFIEC 051 Glossary the same as the 041 Glossary?

The definitions largely match, but the books are separate documents with their own page numbers: 128 pages in the 051 Glossary against 137 in the 031 and 041 book in September 2026. The Brokered Deposits page replaced in December 2025 was A-14a in the 051 book and A-20a in the other.

Can a bank under $5 billion be required to file the 041?

Yes. The 051 General Instructions let the bank's primary federal supervisor, jointly with the state chartering authority where applicable, require a bank otherwise eligible for the 051 to file the 041 based on supervisory needs.

When did the FFIEC 051 start?

The agencies introduced the FFIEC 051 in March 2017 and, in September 2019, added reduced reporting for the first and third quarters for respondents with total assets under $5 billion, as the 2025 request for information recounts.

Do the supplemental instructions apply to the 051?

Yes. Each quarter's Supplemental Instructions cover the FFIEC 031, 041 and 051 together; in September 2026 they described the reciprocal and custodial deposit changes and the 8 percent community bank leverage ratio for all three forms.

Why did my 051 page reference stop matching?

Most often because the citation came from the 031 and 041 book, whose page numbers differ, or because the page was replaced in a later update. Check the header and the revision date in the footer against the current 051 Instructions Update.

Call Report Instructions Search.
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