Recent changes beginning with the 03/31/2002 Call Report require that overnight Federal Home Loan Bank advances are no longer included with “Federal funds purchased” but with “Other borrowed money.”  Despite this change, this office is of the opinion that such overnight advances should be  considered in the same manner as purchases of excess reserves are in regard to the reporting requirements of LSA-R.S. 6:303(C).  LSA-R.S. 6:303(C) states, in part, “A state bank which…purchases excess reserves from any other bank or banks for thirty continuous calendar days shall immediately report such…purchases to the commissioner.”  Since it is the intent of this section to keep this office informed of our banks that are consistently borrowing on a short-term basis, we feel that the reporting of such overnight advances in the same way that excess reserves purchased are reported is appropriate and necessary.

This OFI interpretation does not override the Call Report instructions on how you report overnight Federal Home Loan Bank advances–just that these advances should be considered when reporting to the Commissioner after 30 continuous days in a short-term borrowing position.

The applicable section of the official call report instructions that report this revision is shown below:

Overnight Federal Home Loan Bank Advances

The Call Report revisions that take effect this quarter include changes to the definition of “Federal funds purchased,” which are reported on the Call Report balance sheet in Schedule RC, item 14.a. As a result, immediately available funds borrowed from a Federal Home Loan Bank for one business day no longer meet the definition of federal funds purchased. Accordingly, these so-called overnight advances should be reported on the Call Report balance sheet in Schedule RC, item 16, “Other borrowed money.” In addition, overnight Federal Home Loan Bank advances must be included in Schedule RC-M, item 5.a.(1), Federal Home Loan Bank advances “With a remaining maturity of one year or less.”

 If you have any questions, please contact Tim Robichaux, Deputy Chief Examiner, (225) 922-0878.