Regulatory Filing Extensions in Response to COVID-19

Document Properties

  • Type of Publication: Letter
  • Date: April 9, 2020
  • To: Federally Regulated Financial Institutions (FRFIs)

The data reported by federally regulated financial institutions (FRFIs) is essential for prudential supervision, monitoring of financial stability, formulation of monetary policy and supporting Government policy. The provision of timely and accurate FRFI information is vital, especially in the current environment, and essential to the Government’s ability to respond to events as they rapidly unfold. As such, it is imperative that key prudential information on FRFIs’ liquidity, financial position, capital and risks continue to be made available on a timely basis.

As noted in our March 27 letters, OSFI is prepared to offer some flexibility for FRFIs that may need additional time to meet upcoming deadlines for filing regulatory returns, recognizing the operational challenges they may face.

The Bank of Canada (BoC) is prepared to offer similar flexibility in relation to returns where it is the contact agency. Please refer to the following links for more on regulatory returns and relevant contact agencies –

As well, the Canada Deposit Insurance Corporation (CDIC) announced measures to provide flexibility with respect to annual premiums administration and select member compliance requirements (see link). This guidance is intended to balance FRFIs’ operational realities against the need for timely and accurate data provided via regulatory returns.

Extensions for regulatory returns

The following regulatory returns will be subject to extended filing deadlines on a temporary basis for deposit-taking institutions:

  • The new BoC Balance Sheet by Booking Location (Z4) return filing deadline will be extended from 31 days to 45 days for the reference periods of March, April and May 2020.
  • The BoC Geographic Distribution of Assets and Liabilities Booked In/Outside of Canada (GR/GQ) returns filing deadline for the reference period of March 31, 2020 will be extended. For the GQ return, the filing deadline will be extended from 40 days to 45 days. The GR and the Geographical Reconciliation Return with Consolidated Monthly Return of Assets & Liabilities (T2) returns will be extended from 60 days to 75 days.

FRFIs should be proactive, wherever possible, in informing their OSFI lead supervisor of any operational or technical challenges they encounter as a result of the current environment. Recognizing that some FRFIs may encounter difficulties in meeting deadlines for certain regulatory filings, OSFI is prepared to offer flexibility on a case-by-case basis. Where circumstances prevent a FRFI from filing on time, the FRFI should contact their lead supervisor, indicating the regulatory return(s) they are seeking an extension for, including the rationale necessitating the request. In relation to returns where BoC is the contact agency, FRFIs requesting flexibility should contact BoC directly through their regular contacts.

Late & erroneous filing penalties

In appropriate circumstances, OSFI may grant a FRFI an extension to file a return that does not have a statutory due date. Once OSFI has granted such an extension, a Notice of Violation for a Late & Erroneous Filing Penalty (LEFP) will not be issued so long as the FRFI files on or before the revised due date. If the FRFI does not file on or before the revised due date, a Notice of Violation may be issued or any other actions may be taken by OSFI. When determining whether to issue a Notice of Violation or take any other actions, OSFI will take into consideration the circumstances and any representations provided by the FRFI.

OSFI does not have authority to provide filing extensions for those returns that have statutory due dates. If the FRFI does not file on or before the due date, a Notice of Violation may be issued or any other actions may be taken by OSFI. When determining whether to issue a Notice of Violation or take any other actions, OSFI will take into consideration the circumstances and any representations provided by the FRFI.

Finally, in those cases where a FRFI has attempted to file its regulatory returns within the required timeframe, and unforeseen technical difficulties arose that prevented the filing to occur, the FRFI should immediately notify its lead supervisor. OSFI will review the particular circumstances experienced by the FRFI in the filing process and the representations of the FRFI when determining whether to issue a Notice of Violation or take any other actions.

OSFI disclosures of FRFIs’ financial results

OSFI publicly discloses the monthly and quarterly financial results sourced from several regulatory returns (Disclosure website) for FRFIs. Extended delays in regulatory returns reporting may impact OSFI’s ability to disclose this information to the public and other market participants, as per its regularly scheduled timelines. As such, it is imperative that FRFIs make the necessary efforts to continue to submit their regulatory returns as scheduled, unless exceptional circumstances preclude this from occurring.

Implementation timelines of returns changes and new returns

On an annual basis, changes are made to applicable regulatory returns and new returns are introduced as needed that FRFIs are expected to implement. Given the current environment, the implementation of changes to certain regulatory returns will be delayed. The following section provides the updated implementation timelines for regulatory returns by industry.

Deposit-Taking Institutions

Regulatory Return Changes with Implementations Delays

  • Interbank and Major Exposures Return (EB/ET 2L) – formal reporting postponed from Q3 2020 to Q1 2021. As well, the test data submission scheduled for Q2 2020 will be postponed to Q4 2020.
  • HELOC return (J2) – formal reporting postponed from September 30, 2020 to March 31, 2021. Deposit-taking institutions will be expected to participate in an ad-hoc test based on September 2020 data to be submitted by November 15, 2020.
  • Trading Income & GoC Securities Trading Income Return – formal reporting postponed from Q1 2021 to Q1 2022. As well, test data will be postponed from Q2 2020 to Q1 2021.

Regulatory Return Implementations that will continue as scheduled in Q1 2021

All other return changes under consideration for implementation in fiscal 2021 will be deferred to fiscal 2022.

Insurance Companies

No changes are planned to the insurance financial returns until the implementation of IFRS 17.