Banks to Keep Filing Same Old Trading Reports, Yawn
Published Date: 4/30/2026
Notice
Summary
The Office of the Comptroller of the Currency (OCC) is renewing its paperwork rules for banks about their trading activities and relationships with certain investment funds. This renewal keeps the same reporting and recordkeeping requirements, helping the OCC keep an eye on risky trading while reducing unnecessary paperwork. Banks and financial firms must send comments by June 1, 2026, but no new fees or big changes are coming.
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Analyzed Economic Effects
5 provisions identified: 0 benefits, 5 costs, 0 mixed.
Paperwork Renewal Keeps Same Bank Burden
The OCC is renewing the existing information collection (OMB Control No. 1557-0309) without changes, so banks and other for‑profit firms must continue the same reporting, recordkeeping, and disclosure obligations. The OCC estimates 39 respondents, 2,242 total annual responses, and 20,410 total annual burden hours under the collection.
Quarterly Metrics Reporting Requirement
Banking entities with significant trading assets and liabilities must report the metrics specified in Appendix A to the OCC within 30 days after the end of each calendar quarter.
Compliance Program, CEO Attestation, 5-Year Records
Banking entities with significant trading assets and liabilities must maintain a compliance program demonstrating compliance with section 13 and part 44, obtain a CEO attestation, retain records for no less than 5 years (or longer if the OCC requires), and promptly provide these records to the OCC upon request.
Documentation for Market‑Making With Very Large Firms
If another banking entity has trading assets and liabilities of $50 billion or more, a trading desk relying on the market‑making exemption is not considered to have that entity as a client, customer, or counterparty unless the trading desk documents how and why that unit should be treated as a client, customer, or counterparty.
Specific Recordkeeping for Liquidity Management Trades
Recordkeeping requirements apply to excluded liquidity management activities, including security transactions, foreign exchange forwards, foreign exchange swaps, and cross‑currency swaps, as described in section 44.3(d)(3).
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