On May 22, 2024, the US federal banking regulators finalized a new set of reporting requirements for bank loans and commitments to fund finance facilities, private credit lenders, and other nonbank financial entities.1 This change reflects not only the rapid growth in this sector but also the regulators’ desire to better understand and supervise concentrations of credit and risk in the US banking system.
The new reporting requirements will take effect for the reporting period ending December 31, 2024 (i.e., reports filed in the first quarter of 2025). These requirements will apply to all insured depository institutions with $10 billion or more in total assets—approximately 160 banks.2 While banks will not be required to report the individual names of direct or underlying obligors, banks and intermediaries should understand how they may be affected by the ways in which regulators and investors use this new information.
BACKGROUND
Banks are required to file several types of reports with their regulators, including those with respect to the bank’s financial condition, the results of its operations, and risk exposure.3 One of the most common regulatory reports is the quarterly Consolidated Reports of Condition and Income (the “call report”), which banking regulators, including the Office of the Comptroller of the Currency (OCC), use to assess a bank’s financial condition.
Banks are required to sort credit exposures into many categories for reporting purposes—including loans secured by real estate, credit cards, and loans to foreign governments—and report the amount outstanding each quarter. Since 2010, banks have been required to report aggregate loans to nondepository financial institutions, which includes loans to direct lenders and other private credit intermediaries. In December 2023, the federal banking regulators proposed requiring banks to disaggregate this category.
FINAL REPORTING REQUIREMENTS
The final reporting requirements largely adopt the proposal, with minor...