IHC_20160815_omb

Supporting Statement for the Requirements of
U.S. Intermediate Holding Companies of Foreign Banking Organizations
(FR 2314 and FR 2314S; OMB No. 7100-0073), (FR Y-6; OMB No. 7100-0297),
(FR Y-9C and FR Y-9LP; OMB No. 7100-0128),
(FR Y-11 and FR Y-11S; OMB No. 7100-0244),
(FR Y-12 and FR Y-12A; OMB No. 7100-0300),
(FR Y-14A, FR Y-14Q, and FR Y-14M; OMB No. 7100-0341),
(FR Y-15; OMB No. 7100-0352), (FR 4200; OMB No. 7100-0313), and
(FR 4201; OMB No. 7100-0314)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated
authority from the Office of Management and Budget (OMB), proposes to revise, without
extension, the following mandatory information collections, effective July 1, 2016:
 Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314)
and the Abbreviated Financial Statements of Foreign Subsidiaries of U.S. Banking
Organizations (FR 2314S) (OMB No. 7100-0073),
 Annual Report of Holding Companies (FR Y-6; OMB No. 7100-0297),
 Consolidated Financial Statements for Holding Companies (FR Y-9C) and the Parent
Company Only Financial Statements for Large Holding Companies (FR Y-9LP)
(OMB No. 7100-0128)1,
 Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies
(FR Y-11) and the Abbreviated Financial Statements of U.S. Nonbank Subsidiaries of
U.S. Holding Companies (FR Y-11S) (OMB No. 7100-0244),
 Consolidated Holding Company Report of Equity Investments in Nonfinancial
Companies (FR Y-12) and the Annual Report of Merchant Banking Investments Held for
an Extended Period (FR Y-12A) (OMB No. 7100-0300),
 Capital Assessments and Stress Testing (FR Y-14A, FR Y-14Q, and FR Y-14M;
OMB No. 7100-0341),
 Banking Organization Systemic Risk Report (FR Y-15; OMB No. 7100-0352),
 Recordkeeping and Disclosure Requirements Associated with the Capital Adequacy of
Board-Related Institutions (Regulation Q) (FR 4200; OMB No. 7100-0313), and
 Risk-Based Capital Guidelines: Market Risk (FR 4201; OMB No. 7100-0314).
The Board proposes to collect financial information for U.S. intermediate holding
companies (IHCs) of foreign banking organizations (FBOs) for the regulatory reporting forms
listed above to implement the enhanced prudential standards for FBOs adopted under Enhanced
Prudential Standards (Regulation YY). As applicable, an IHC must (1) begin filing certain
regulatory reports beginning with the reporting period ending on September 30, 2016, and other
reports beginning with the reporting period ending on December 31, 2016; and (2) comply with
1

The family of FR Y-9 reporting forms also contains the Parent Company Only Financial Statements for Small
Holding Companies (FR Y-9SP), the Financial Statements for Employee Stock Ownership Plan Holding Companies
(FR Y-9ES), and the Supplement to the Consolidated Financial Statements for Holding Companies (FR Y-9CS)
which are not being revised.

the information collections associated with the regulatory capital rules beginning on the
July 1, 2016, effective date (see tables on pages 3 and 4 for details).
The total current annual burden for these information collections would increase due to
IHCs being added to the respondent panel. For detailed annual burden information on each
report, see the burden tables under the Estimates of Respondent Burden section at the end of this
supporting statement.
Background and Justification
Section 165 of the Dodd-Frank Act directs the Board to establish enhanced prudential
standards for bank holding companies (BHCs) and FBOs with total consolidated assets of $50
billion or more and nonbank financial companies that the Financial Stability Oversight Council
has designated for supervision by the Board. In addition to certain statutorily enumerated
enhanced prudential standards, section 165 also permits the Board to establish other prudential
standards that the Board determines are appropriate.
On December 14, 2012, the Board invited comment on a notice of proposed rulemaking
that would have required an FBO with $10 billion in non-branch assets to establish a U.S. IHC,
impose enhanced prudential standards on the IHC, and require the IHC to submit any reporting
forms in the same manner and to the same extent as a bank holding company (BHC).2 The
Federal Register notice for the proposal provided the names and the OMB reporting numbers for
the proposed reporting forms that would be applicable to an IHC, listed above.3 On
February 18, 2014, the Board adopted a final rule implementing enhanced prudential standards
for FBOs (Regulation YY).4 As described in that rule, an IHC must submit information in the
manner and form prescribed by the Board.5 The Board indicated in the Federal Register notice
adopting Regulation YY that it would address the reporting requirements for IHCs at a later date.
Description of the Information Collection
At this time, the regulatory reports identified in this supporting statement collect
information pertaining to domestic or foreign-owned domestic firms that are in the form of
BHCs, domestically owned foreign subsidiaries of BHCs, commercial banks and their foreign
branches, non-banks, edge and agreement corporations, trust companies, and savings banks.

2

See 77 FR 76627 (December 28, 2012).

3

The Federal Register notice for the proposal also listed the FFIEC 101 (Regulatory Capital Reporting for
Institutions Subject to the Advanced Capital Adequacy Framework), FFIEC 009 and FFIEC 009a (Country
Exposure Report and Country Exposure Information Report) and FR Y-10 (Report of Changes in Organizational
Structure). The FFIEC 009, FFIEC 009a, and the FR Y-10 approvals are currently out for public comment. In
addition, the FR Y-10 would be filed by the FBO parent of the IHC and not the IHC itself. Further, IHCs are not
required to calculate risk-weighted assets under the advanced approaches risk-based capital rule, and thus, staff did
not propose to add intermediate holding companies to the reporting panel for the FFIEC 101 through the proposal.
4

See 79 FR 17239 (March 27, 2014).

5

See 12 CFR 252.153(b)(2).

2

Proposed Revisions
The Board proposes to require IHCs to file regulatory reports applicable to bank holding
companies, and comply with the information collection requirements associated with regulatory
capital requirements. The proposed information collection would provide the Board with
information regarding the financial condition of the IHC, foreign and domestic legal entities, and
intercompany transactions between legal entities. In addition, the proposal would require an IHC
to provide U.S. financial information in support of the Board’s supervisory programs, including
its capital assessment and stress testing programs.
The addition of IHCs in the reporting panel for the proposed reporting forms would be
effective according to the following table:

Report Title
Financial Statements of
Foreign Subsidiaries of
U.S. Banking
Organizations and
Abbreviated Financial
Statements of Foreign
Subsidiaries of U.S.
Banking Organizations
Annual Report of
Holding Companies
Consolidated Financial
Statements for Holding
Companies and Parent
Company Only
Financial Statements for
Large Holding
Companies
Financial Statements of
U.S. Nonbank
Subsidiaries of U.S.
Holding Companies and
Abbreviated Financial
Statements of U.S.
Nonbank Subsidiaries of
U.S. Holding
Companies

Applicability
All IHCs

Agency
Form
Number
FR 2314
and
FR 2314S

All IHCs

FR Y-6

All IHCs

FR Y-9C
and
FR Y-9LP

All IHCs

FR Y-11
and
FR Y-11S

3

OMB
Reporting Date
Control
(as applicable)
Number
7100September 30,
0073
2016, for the
quarterly
FR 2314
(December 31,
2016, for the
annual FR 2314
and FR 2314S)
7100December 31,
0297
2016
7100September 30,
0128
2016

Reporting
Frequency (as
applicable)
Quarterly,
annually

71000244

Quarterly,
annually

September 30,
2016, for the
quarterly
FR Y-11
(December 31,
2016, for the
annual FR Y-11
and FR Y-11S)

Annually
Quarterly,
annually

Report Title

Applicability

Consolidated Holding
All IHCs
Company Report of
Equity Investments in
Nonfinancial Companies
and the Annual Report
of Merchant Banking
Investments Held for an
Extended Period
Capital Assessments and All IHCs
Stress Testing

Banking Organization
Systemic Risk Report

All IHCs

Agency
Form
Number
FR Y-12
and
FR Y-12A

OMB
Reporting
Reporting Date
Control
Frequency (as
(as applicable)
Number
applicable)
7100September 30,
Quarterly,
0300
2016
annually
(December 31,
2016, for the
FR Y-12A)

FR Y-14A,
FR Y-14Q,
and
FR Y-14M
FR Y-15

71000341

December 31,
2016

Semiannually,
quarterly,
monthly

71000352

September 30,
2016

Quarterly

The information collections related to the regulatory capital rules (FR 4200 and FR 4201)
would be effective on July 1, 2016, which corresponds to the effective date of the requirements
under Regulation YY. This is reflected in the following table:

Information Collection

Applicability

Recordkeeping and
Disclosure
Requirements
Associated with the
Capital Adequacy of
Board-Related
Institutions
(Regulation Q)
Risk-Based Capital
Guidelines: Market Risk

All IHCs (to
the extent
subject to the
corresponding
requirement)

FR 4200

Effective
Date of
Information
Collection
7100-0313 July 1, 2016

All IHCs (to
the extent
subject to the
corresponding
requirement)

FR 4201

7100-0314 July 1, 2016

Agency
Form
Number

OMB
Control
Number

Reporting
Frequency
On occasion

On occasion

Frequency
The Board recommends no changes to the reporting frequency of the FR 2314,
FR 2314S, FR Y-6, FR Y-9C, FR Y-9LP, FR Y-11, FR Y11S, FR Y-12, FR Y-12A, FR Y-14A,
FR Y-14M, FR Y-14Q, FR Y-15, FR 4200, or FR 4201. The current reporting frequencies
provide adequate timely data to meet the analytical and supervisory needs of the Board.

4

Time Schedule for Information Collection
The Board recommends no changes to the time schedule for the FR 2314, FR 2314S,
FR Y-6, FR Y-9C, FR Y-9LP, FR Y-11, FR Y11S, FR Y-12, FR Y-12A, FR Y-14A, FR Y-14M,
FR Y-14Q, FR Y-15, FR 4200, or FR 4201. The current time schedule provides adequate timely
data to meet the analytical and supervisory needs of the Board.
Legal Status
The Board’s Legal Division has determined these reports are authorized under:
FR 2314 and FR 2314S: 12 U.S.C. §§ 324, 602, 625, 1844(c), 1467a(b), section 165 of
the Dodd-Frank Act (12 U.S.C. § 5365), and section 252.153(b)(2) of Regulation YY (12 CFR
252.153(b)(2)).
FR Y-6: Section 5(c) of the Bank Holding Company Act (12 U.S.C. § 1844(c)), sections
8(a) and 13(a) of the International Banking Act (12 U.S.C. §§ 3106 and 3108(a)), sections
11(a)(1), 25, and 25A of the Federal Reserve Act (12 U.S.C. §§ 248(a), 602, and 611a), sections
113, 312, 618, and 809 of the Dodd-Frank Act (12 U.S.C. §§ 5361, 5412, 1850a(c)(1), and
5468(b)(1)), section 165 of the Dodd-Frank Act (12 U.S.C. § 5365), and section 252.153(b)(2) of
Regulation YY (12 CFR 252.153(b)(2)).
FR Y-9 family of reports, FR Y-11, and FR Y-11S: Section 5(c) of the Bank Holding
Company Act (12 U.S.C. § 1844(c)), section 10 of Home Owners’ Loan Act (12 U.S.C. §
1467a(b)), 12 U.S.C. § 1850a(c)(1), section 165 of the Dodd-Frank Act (12 U.S.C. § 5365), and
section 252.153(b)(2) of Regulation YY (12 CFR 252.153(b)(2)).
FR Y-12 and FR Y-12A: Section 5(c) of the Bank Holding Company Act (12 U.S.C.
§ 1844(c)), section 10 of HOLA (12 U.S.C. § 1467a(b)), section 165 of the Dodd-Frank Act
(12 U.S.C. § 5365), and section 252.153(b)(2) of Regulation YY (12 CFR 252.153(b)(2)).
FR Y-14A, FR Y-14M, and FR Y-14Q: Section 5(c) of the Bank Holding Company Act
(12 U.S.C. § 1844(c)), section 165 of the Dodd-Frank Act (12 U.S.C. § 5365), and section
252.153(b)(2) of Regulation YY (12 CFR 252.153(b)(2)).
FR Y-15: Section 5(c) of the Bank Holding Company Act (12 U.S.C. § 1844(c)),
section 10 of HOLA (12 U.S.C. § 1467a(b)), sections 8(a) and 13(a) of the International
Banking Act (12 U.S.C. §§ 3106 and 3108(a)), sections 163 and 165 of the Dodd-Frank Act
(12 U.S.C. §§ 5363, 5365), section 604 of the Dodd-Frank Act, which amended section 5(c) of
the BHC Act (12 U.S.C. § 1844(c)), and section 252.153(b)(2) of Regulation YY (12 CFR
252.153(b)(2))
FR 4200: Section 38(o) of the Federal Deposit Insurance Act (12 U.S.C. § 1831o(c)),
section 908 of the International Lending Supervision Act of 1983 (12 U.S.C. § 3907(a)(1)), the
Federal Reserve Act (12 U.S.C. § 324), and section 5(c) of the Bank Holding Company Act
(12 U.S.C. § 1844(c)), and section 252.153(b)(2) of Regulation YY (12 CFR 252.153(b)(2)).

5

FR 4201: 12 U.S.C. § 324, 12 U.S.C. § 1844(c), section 165 of the Dodd-Frank Act
(12 U.S.C. § 5365), and section 252.153(b)(2) of Regulation YY (12 CFR 252.153(b)(2)).
The confidentiality status remains unchanged for all the affected reports.
Consultation Outside the Agency
On February 5, 2016, the Board published a notice in the Federal Register (81 FR 6265)
requesting public comment for 60 days on the revision, without extension, of the reports listed in
this document.6 The comment period for this notice expired on April 5, 2016. The Board
received one joint comment letter on the proposal. The commenters generally supported the
proposal, but provided views on the FR Y-14 series of reports relating to the collection of
financial data for previous years, the FR Y-15 report related to timing, and the FR 4200 and
FR 4201 requirements regarding the purpose and presentation of the information collections.
The commenters also requested clarity on specific items on the reports.
In response to the comments, the Board notes that it will consider requests relating to the
requirement that an IHC report financial data for previous years on the FR Y-14 series of reports
on a case-by-case basis. The Board also extends the filing date for the first FR Y-15 filing and
clarifies that the FR 4200 and FR 4201 requirements relate to the recordkeeping and reporting
requirements of the regulatory capital rules, and do not relate to a separate reporting form.
Detailed Discussion of Public Comments
Comments on the FR Y-14 Series of Reports
The FR Y-14 series of reports enables the Board to assess the capital adequacy of firms
using forward-looking projections of revenue and losses and supports supervisory stress test
models and continuous monitoring efforts. In the proposal, an IHC would have been required to
complete the FR Y-14 series of reports in the same manner as a BHC and would have been
subject to requirements to report financial data for previous years with respect to its U.S. bank
and nonbank operations. However, the preamble to the proposal noted that many IHCs would
have difficulty reporting these historical data for periods prior to the formation of the IHC and
invited comment specifically on the ability of IHCs to report historical data.
Historical PPNR data
The commenter provided views on the requirement to report pre-provision net revenue
(PPNR) data for previous years, and recommended that the submission of any historical IHCspecific data be on a best estimates basis with a look-back period limited to the prior seven
quarters, rather than to the first quarter of 2009 as proposed. Additionally, the commenters
suggested that IHCs not be required to submit any industry market size information for previous
years.
6

The proposal had also proposed to expand the respondent panel for the Recordkeeping and Reporting
Requirements Associated with Regulation Y (Capital Plans) (Reg Y-13; OMB No. 7100-0342). However, IHCs
were added to the reporting panel for Reg Y-13 in October 2014. See 79 FR 64026, 64039 (October 27, 2014).

6

In order to develop credible estimates of a firm’s PPNR, the Board and the firm itself
must have several years of data in order to understand the firm’s businesses in various
macroeconomic environments. Therefore, the Board is adopting the requirement for IHC
respondents to report PPNR information from 2009 to the present on the FR Y-14Q report as
outlined in the instructions. However, in recognition of the challenges in providing these data,
the Board will consider requests to modify the requirement for an IHC to report financial data for
previous years or extend the time period by which an IHC must report historical data on the
FR Y-14 series of reports, including the inclusion of best estimates for data prior to 2015, on a
case-by-case basis. Requests should include a description of any data gaps or deficiencies, an
overview of the approach to address the issues, and the timeframe for completion. To ensure
proper routing of requests for extension or plans for remediation for these specific data, these
requests should be submitted to the firm’s designated Board contact.
In regards to the comment that IHCs should not be required to submit industry market
size information for previous years, the proposal does not include this proposed change for IHCs.
Attestation requirement
The commenters also noted that the proposal was silent on how the attestation
requirement, which applies to U.S. bank holding companies subject to the Large Institution
Supervision Coordinating Committee (LISCC) framework, would apply to IHC subsidiaries of
FBOs subject to the LISCC framework. The commenters asked for guidance on the application
of the attestation requirement to these IHCs and offered suggestions on transition periods.
The Board has not proposed to apply the attestation requirement to these IHCs; however,
the Board will consider the commenters’ views on any future proposal.
Comments on the FR Y-15 Report
The FR Y-15 report collects consolidated systemic risk data from large banking
organizations. In the proposal, an IHC would have been required to complete the FR Y-15 report
in the same manner as a BHC, effective September 30, 2016. The commenter requested that all
IHCs be allowed 65 days following September 30, 2016, for the initial filing, and to file on a
reasonable estimates basis. The commenter noted that the resources and personnel involved in
the formation of the IHC are substantially the same as those personnel involved in implementing
the FR Y-15 report, and also noted that the Board recently revised the frequency of the FR Y-15
report from an annual to a quarterly report.
In response to the commenter, the proposal permits all IHCs (including an existing BHC
designated as an IHC) to file their first FR Y-15 report by December 5, 2016 (65 days after the
September 30, 2016 as-of date). This additional time will enable foreign banking organizations
to efficiently allocate resources and facilitate the accurate reporting of data on the FR Y-15
report. To the extent that the IHC had not previously filed the FR Y-15 report (i.e., was not an
existing BHC designated as an IHC), the proposal permits institutions to file reasonable
estimates, consistent with the FR Y-15 report instructions. Except where otherwise noted in
those instructions, reported data will be made available to the public.

7

Comments on the FR 4200 and FR 4201 Requirements
The commenters requested additional information on the purpose and presentation of the
FR 4200 and FR 4201 information collection requirements. The FR 4200 and FR 4201
requirements are the information collections that are embedded within the regulatory capital
requirements, and do not impose reporting, recordkeeping, or disclosure requirements beyond
those already applicable to IHCs under Regulation YY. These information collections are
categorized separately from Regulation YY to facilitate compliance with the Paperwork
Reduction Act and its implementing regulations, which require the Board to assure that approved
collections of information are reviewed not less frequently than once every three years.7
Specifically, the FR 4200 requirement reflects the reporting, recordkeeping and disclosure
requirements applicable to advanced approaches banking organizations and the FR 4201
requirement reflects the reporting, recordkeeping, and disclosure requirements of the market risk
rule. The proposal also revises the FR 4200 requirement to delete references to three information
collections, the “old written implementation plan,” “old prior written approvals,” and “old
disclosures,” because these requirements were eliminated in connection with amendments to
Regulation Q.
Given that the FR 4201 and FR 4200 requirements do not impose new requirements on
these institutions in addition to the requirements applicable under Regulation YY, the Board is
adopting these information collection requirements as proposed.
Requests for Clarification
The commenters also requested guidance on how IHCs should report formation of the
IHC for purposes of the FR Y-9C and FR Y-11 reports. Specifically, the commenter asked
whether the issuance of the stock should be treated as a “sale” on Schedule HI-A, Changes in
Holding Company Equity Capital, and how the firm should report net income for the first six
months of the year for a U.S. entity that will become part of the IHC on July 1, 2016. In
addition, the commenters asked for guidance on how to report equity capital and changes in
equity capital for purposes of the FR Y-11 report.
Each IHC’s reporting of these items will depend on the structure of the FBO parent’s
U.S. operations prior to the effective date of the IHC requirement. For example, an FBO with an
existing BHC that it designates as the IHC should reflect any issuance of the stock to be treated
as a sale for purposes of the FR Y-9C report. However, an FBO that creates a new IHC above an
existing BHC should treat the creation of the U.S. top-tier holding company as a reorganization
for purposes of line item 6a on Schedule HI-A of the FR Y-9C report, and an IHC without an
insured depository institution should treat the item as though it were a de novo filer. With
respect to line item 1 of Schedule IS-A of the FR Y-11 report, the IHC should carry forward the
entry from the line item reported for the end of the previous calendar year on the FR Y-7N
report, Schedule IS-A, including, for example, adjustments from amended income statements.
In addition, commenters requested that the Board advise on the current status of the
7

See 44 U.S.C. § 3501; 12 CFR 1320.10, Appendix A.1(a)(3)(iii).

8

FFIEC 009, FFIEC 009a, FFIEC 102, and the FR Y-10 reports. The FFIEC 009 and FFIEC 009a
reports are currently out for comment with a period ending on June 13, 2016. The FFIEC Task
Force on Reports intends to seek notice and comment to add IHCs to the reporting panels for the
FFIEC 102 report. The Board does not intend to modify the reporting panel for the FR Y-10
report, however, a proposal is currently out for public comment that would add items to the
FR Y-10 reporting form and instructions to identify IHCs.
In addition to adding IHCs as respondents to the list of forms described in this proposal,
the proposal incorporates modifications to the information collection requirements in the
FR 4200. Specifically, on December 7, 2007, the Office of the Comptroller Currency (OCC), the
Board, the Federal Deposit Insurance Corporation, and the Office of Thrift Supervision issued
the joint final rule titled Risk-Based Capital Standards: Advanced Capital Adequacy Framework
implementing a risk-based regulatory capital framework for institutions in the United States (72
FR 69288) (FR 4200). This rule adopted a written implementation plan, prior written approvals
and disclosure requirements. On October 11, 2013, the OCC and the Board adopted a final rule
that revised the FR 4200 information collection requirements. As of the October 2013 final rule,
the previous written implementation plan, previous prior written approvals, and previous
disclosures are being deleted in connection with amendments to Regulation Q. No comments
were received regarding the deletion of these specific items from the FR 4200.
On June 1, 2016, the Board published a final notice in the Federal Register
(81 FR 35016).
Estimates of Respondent Burden8
Regulation YY requires an IHC to calculate its risk-based capital requirements using only
the standardized approach, and not the advanced approaches risk-based capital rule (advanced
approaches rule), even if it meets the advanced approaches applicability threshold. For purposes
of the Y-9C regulatory report form, an IHC that meets the applicability threshold for the
advanced approaches rule will be responsible for filing Schedule HC-R except with respect to
calculation of risk-weighted assets under the advanced approaches rule or where items that
require a successful exit from parallel run are requested.9

8

Except where otherwise indicated, initial or implementation burden for the new filers is negligible or already
included in the burden hours per response for ongoing filers.
9

Regulation YY requires all IHCs to calculate and meet all applicable capital adequacy standards in Regulation Q
or any successor regulation, other than Subpart E of regulation Q, and comply with all restrictions associated with
applicable capital buffers, in the same manner as a bank holding company. Thus, even if an IHC does not have a
subsidiary insured depository institution in the United States, it would still be subject to the information collection
requirements proposed for bank holding companies through this proposal.

9

The current annual burden for the FR 2314 and FR 2314S reports is 21,461 hours and
would increase to 21,547 hours due to the additional respondents being added to the panel. The
revised annual burden for the FR 2314 would represent less than 1 percent of total Federal
Reserve System paperwork burden.
Number of
respondents10

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current
FR 2314 (quarterly)
FR 2314 (annual)
FR 2314S
Total

698
387
480

4
1
1

6.6
6.6
1.0

18,427
2,554
480
21,461

Proposed
FR 2314 (quarterly)
FR 2314 (annual)
FR 2314S
Total

698
400
480

4
1
1

6.6
6.6
1.0

18,427
2,640
480
21,547

Change

86

The total annual cost to the public for the FR 2314 and FR 2314S reports is estimated to
increase by $4,571 to $1,145,223 from the current level of $1,140,652.

10

Of the respondents required to comply with the FR 2314 and FR 2314S information collection, 597 are estimated
to be small entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total
assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-smallbusiness-size-standards.

10

The current annual reporting burden for the structure reporting forms and instructions is
estimated to be 70,363 hours and would increase to 70,565 hours due to the additional
respondents being added to the panel. This information collection would represent less than 1
percent of the total Federal Reserve System paperwork burden.
Number of
respondents11
Current
FR Y-6
FR Y-7
FR Y-10 initial
FR Y-10 ongoing
FR Y-10E

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

4,814
243
530
5,298
5,298

1
1
1
3
1

5.50
4
1
2.50
0.50

26,477
972
530
39,735
2,649
70,363

13
4,827
243
530
5,298
5,298

1
1
1
1
3
1

10
5.50
4
1
2.50
0.50

Total

130
26,549
972
530
39,735
2,649
70,565

Change

202

Total
Proposed
FR Y-6 initial
FR Y-6 ongoing
FR Y-7
FR Y-10 initial
FR Y-10 ongoing
FR Y-10E

The total cost to the public for the structure reports is estimated to increase by $10,737 to
$3,750,530 from the current level of $3,739,793.

11

Of the respondents required to comply with the structure information collection, 3,356 FR Y-6 filers , 0 FR Y-7
filers, 369 FR Y-10 (initial) filers, 3,693 FR Y-10 (ongoing) filers, and 3,693 FR Y-10E filers are estimated to be
small entities as defined by the Small Business Administration (i.e., entities with $550 million or less in total assets)
www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-small-businesssize-standards.

11

The current annual reporting burden for the FR Y-9 family of reports is estimated to be
198,569 hours and would increase to 199,466 due to the additional respondents being added to
the panel. The revised annual burden for the FR Y-9 family of reports would represent
approximately 1.5 percent of total Federal Reserve System paperwork burden.
Number of
respondents12
Current
FR Y-9C – non advanced
approaches HCs
FR Y-9C – advanced
approaches HCs
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Total
Proposed
FR Y-9C – non advanced
approaches HCs or other
respondents
FR Y-9C – advanced
approaches HCs or other
respondents
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Total

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

644

4

50.84

130,964

12

4

52.09

2,500

818
4,390
86
236

4
2
1
4

5.25
5.4
0.5
0.5

17,178
47,412
43
472
198,569

648

4

50.84

131,777

12

4

52.09

2,500

822
4,390
86
236

4
2
1
4

5.25
5.4
0.5
0.5

17,262
47,412
43
472
199,466

Change

897

The total cost to the public is estimated to increase by $47,676 to $10,601,618 from the
current level of $10,553,942.

12

Of the respondents required to comply with the FR Y-9 family of reports, 132 FR Y-9C non AA HCs filers, 0
FR Y-9C AA HCs filers, 158 FR Y-9LP filers, 3,839 FR Y-9SP filers, 86 FR Y-9ES filers, and 0 FR Y-9CS filers
are estimated to be small entities as defined by the Small Business Administration (i.e., entities with less than $550
million in total assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-sizestandards/table-small-business-size-standards.

12

The current annual burden for the FR Y-11and FR Y-11S reports is 19,273 hours and
would increase to 22,233 hours due to the additional respondents being added to the panel. The
revised annual burden for the FR Y-11 would represent less than 1 percent of total Federal
Reserve System paperwork burden.
Number of
respondents13

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S
Total

617
302
437

4
1
1

6.8
6.8
1.0

16,782
2,054
437
19,273

Proposed
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S
Total

717
332
473

4
1
1

6.8
6.8
1.0

19,502
2,258
473
22,233

Change

2,960

The total annual cost to the public for the FR Y-11and FR Y-11S reports is estimated to
increase by $157,324 to $1,181,684 from the current level of $1,024,360.

13

Of the respondents required to comply with the FR Y-11 and FR Y-11S information collection, 615 are estimated
to be small entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total
assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-smallbusiness-size-standards.

13

The current annual reporting burden for the FR Y-12 and FR Y-12A reports is 1,849
hours and would increase to 3,409 due to the additional respondents being added to the panel.
The revised annual burden for the FR Y-12 and FR Y-12A would represent less than 1 percent of
total Federal Reserve System paperwork burden.
Number of
respondents14
Current
FR Y-12 – FR Y-9C filers
FR Y-12 – FR Y-9SP filers
FR Y-12A

Estimated
Annual
average hours
frequency
per response

24
4
19

4
2
1

16.5
16.5
7.0

1,584
132
133
1,849

13
37
4
13
32

1
4
2
1
1

33.0
16.5
16.5
14.0
7.0

429
2,442
132
182
224
3,409

Total
Proposed
FR Y-12 – FR Y-9C filers initial
FR Y-12 – FR Y-9C filers ongoing
FR Y-12 – FR Y-9SP filers
FR Y-12A initial
FR Y-12A ongoing

Estimated
annual burden
hours

Total

1,560

Change

The total annual reporting cost to the public for the FR Y-12 and FR Y-12A is estimated
to increase by $82,914 to $181,188 from the current level of $98,274.

14

Of the respondents required to comply with the FR Y-12 and FR Y-12A information collection, none are
estimated to be small entities as defined by the Small Business Administration (i.e., entities with less than $550
million in total assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-sizestandards/table-small-business-size-standards.

14

The current annual burden for the FR Y-14 family of reports is 800,653 hours and would
increase to 1,065,187 due to the additional respondents being added to the panel. The revised
annual burden for the FR Y-14 family of reports would represent approximately 8.5 percent of
total Federal Reserve System paperwork burden.
Number of
respondents15

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden

Current FR Y-14A
Summary
Macro scenario
Operational risk
Regulatory capital transitions
Regulatory capital instruments
Retail repurchase
Business plan changes
Current FR Y-14A Total

33
33
33
33
33
33
33

2
2
1
1
1
2
1

987
31
12
23
20
20
10

65,142
2,046
396
759
660
1,320
330
70,653

Current FR Y-14Q
Securities Risk
Retail risk
PPNR
Wholesale
Trading
Regulatory capital transitions
Regulatory capital instruments
Operational risk
MSR Valuation
Supplemental
Retail FVO/HFS
Counterparty
Balances
Current FR Y-14Q total

33
33
33
33
6
33
33
33
12
33
22
6
33

4
4
4
4
4
4
4
4
4
4
4
4
4

13
16
711
152
1,926
23
52
50
24
4
16
508
16

1,716
2,112
93,852
20,064
46,224
3,036
6,864
6,600
1,152
528
1,408
12,192
2,112
197,860

28
27
18

12
12
12

515
515
510

173,040
166,860
110,160
450,060

Current FR Y-14M
Retail Risk:
1st lien mortgage
Home equity
Credit card
Current FR Y-14M total

15

Of the respondents required to comply with the FR Y-14A, FR Y-14Q, and FR Y-14M information collection,
none are estimated to be small entities as defined by the Small Business Administration (i.e., entities with less than
$550 million in total assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-sizestandards/table-small-business-size-standards.

15

Implementation and On-going
Automation
Implementation
On-going revisions
Implementation and On-going
Automation total

0
33

1
1

7,200
480

0
15,840
15,840

Attestation
Implementation
On-going revisions
Attestation total

9
9

1
1

4,800
2,560

43,200
23,040
66,240
800,653

Current Collection total
Proposed FR Y-14A
Summary
Macro scenario
Operational risk
Regulatory capital transitions
Regulatory capital instruments
Retail repurchase
Business plan changes
Proposed FR Y-14A total

39
39
39
39
39
39
39

2
2
1
1
1
2
1

987
31
12
23
20
20
10

76,986
2,418
468
897
780
1,560
390
83,499

Proposed FR Y-14Q
Securities risk
Retail risk
PPNR
Wholesale
Trading
Regulatory capital transitions
Regulatory capital instruments
Operational risk
MSR Valuation
Supplemental
Retail FVO/HFS
Counterparty
Balances
Proposed FR Y-14Q total

39
39
39
39
6
39
39
39
18
39
28
6
39

4
4
4
4
4
4
4
4
4
4
4
4
4

13
16
711
152
1,926
23
52
50
24
4
16
508
16

2,028
2,496
110,916
23,712
46,224
3,588
8,112
7,800
1,728
624
1,792
12,192
2,496
223,708

37
32
25

12
12
12

515
515
510

228,660
197,760
153,000
579,420

Proposed FR Y-14M
Retail Risk:
1st lien mortgage
Home equity
Credit card
Proposed FR Y-14M total

16

Proposed Implementation and
On-going Automation
Implementation
On-going revisions
Proposed Automation total

13
39

1
1

7,200
480

93,600
18,720
112,320

9
9

1
1

4,800
2,560

43,200
23,040
66,240

Attestation
Implementation
On-going revisions
Attestation total
Proposed Collection total

1,065,187

Change

264,534

The total cost to the public for the FR Y-14 family of reports is estimated to increase by
$14,059,982 to $56,614,689 from the current level of $42,554,707.
The total annual burden for the FR Y-15 report is estimated to be 54,536 hours as shown
in the following table and would increase to 64,952 due to the additional respondents being
added to the panel. These reporting requirements represent less than 1 percent of total Federal
Reserve System paperwork burden.
Number of
respondents16
Current
FR Y-15
Proposed
FR Y-15 Initial
FR Y-15 Ongoing
Total

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

34

4

401

54,536

4
38

1
4

1,000
401

4,000
60,952
64,952

Change

10,416

The total annual cost to the public for the FR Y-15 report is estimated to increase by $553,611 to
$3,452,199 from the current level of $2,898,588.

16

Of the respondents required to comply with the FR Y-15 information collection, none are estimated to be small
entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total assets)
www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-small-businesssize-standards.

17

The total annual burden for the FR 4200 is estimated to be 257,439 hours as shown in the
following table and would decrease to 250,512 hours due to the addition of IHCs to the
respondent panel and deleting the old advanced approach reporting, recordkeeping, and
disclosure requirements. These paperwork requirements would represent approximately 2
percent of total Federal Reserve System paperwork burden.
Number of
respondents17

FR 4200
Current
Advanced Approach
Ongoing
(Old Written Implementation
Plan)
Advanced Approach
Ongoing
(Old Prior Written
Approvals)
Advanced Approach
Ongoing
(Old Disclosures)
Minimum Capital Ratios
(Ongoing Recordkeeping)
Standardized Approach
(Ongoing Recordkeeping)
Standardized Approach
(One-time Recordkeeping)
Standardized Approach
(Ongoing Disclosure)
Standardized Approach
(One-time Disclosure)
Advanced Approach
(Ongoing Recordkeeping)
Advanced Approach
(One-time Recordkeeping)
Advanced Approach
(Ongoing Disclosure)
Advanced Approach
(One-time Disclosure)
Disclosure Table 13

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

17

1

404.77

6,881

17

1

40

680

17

1

5.78

98

1,427

1

16

22,832

1,427

1

20

28,540

1,427

1

122

174,094

25

1

131.25

3,281

25

1

226.25

5,656

17

1

146

2,482

17

1

420

7,140

17

1

35

595

17

1

280

4,760

20

4

5

400

Total

257,439

17

Of the respondents required to comply with the FR 4200 information collection, 628 are estimated to be small
entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total assets)
www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-small-businesssize-standards.

18

Proposed
Minimum Capital Ratios
(Ongoing Recordkeeping)
Standardized Approach
(Ongoing Recordkeeping)
Standardized Approach
(One-time Recordkeeping)
Standardized Approach
(Ongoing Disclosure)
Standardized Approach
(One-time Disclosure)
Advanced Approach
(Ongoing Recordkeeping)
Advanced Approach
(One-time Recordkeeping)
Advanced Approach
(Ongoing Disclosure)
Advanced Approach
(One-time Disclosure)
Disclosure Table 13

1,431

1

16

22,896

1,431

1

20

28,620

1,431

1

122

174,582

25

1

131.25

3,281

25

1

226.25

5,656

17

1

146

2,482

17

1

420

7,140

17

1

35

595

17

1

280

4,760

25

4

5

500

Total

250,512

Change

-6,927

The total cost to the public is estimated to decrease by $368,170 to $13,314,713 from the
current level of $13,682,883.

19

The total annual burden for the FR 4201 requirements is estimated to be 54,992 hours as
shown in the following table and would increase to 70,704 due to the additional respondents
being added to the panel. These requirements would represent less than one percent of total
Federal Reserve System paperwork burden.

FR 4201
Current
Reporting
Prior Written Approvals
Recordkeeping
Policies and Procedures
Trading and Hedging Strategy
Internal Models
Backtesting and Stress
Testing
Section 4(b)
Sections 5(c) and 9(c)
Securitizations
Disclosure Policy
Disclosure
Quantitative
Qualitative
Total
Proposed
Reporting
Prior Written Approvals
Recordkeeping
Policies and Procedures
Trading and Hedging Strategy
Internal Models
Backtesting and Stress
Testing
Section 4(b)
Sections 5(c) and 9(c)
Securitizations
Disclosure Policy

Annual
frequency

Estimated
average hours
per response

28

1

960

26,880

28
28
28

1
1
1

96
16
128

2,688
448
3,584

28
28
28
28

4
1
4
1

16
104
120
40

1,792
2,912
13,440
1,120

28
28

4
1

16
12

1,792
336
54,992

36

1

960

34,560

36
36
36

1
1
1

96
16
128

3,456
576
4,608

36
36
36
36

4
1
4
1

16
104
120
40

2,304
3,744
17,280
1,440

Number of
respondents18

18

Estimated
annual burden
hours

Of the respondents required to comply with the FR 4201 information collection, none are estimated to be small
entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total assets)
www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-small-businesssize-standards.

20

Disclosure
Quantitative
Qualitative

36
36

4
1

16
12

Total

2,304
432
70,704

Change

15,712

The total cost to the public is estimated to increase by $835,093 to $3,757,918 from the
current level of $2,922,825.
The total annual cost to the public for all of the information collections above is
estimated to increase by $15,383,738 to $93,999,762 from the current level of $78,616,024.19
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
Current costs to the Federal Reserve System for collecting and processing the FR 2314
and FR 2314S are estimated to be $32,500 per year; the FR Y-6 are estimated to be $16,800 per
year; the FR Y-9 family of reports are estimated to be $1,922,600 per year; the FR Y-11 and
FR Y-11S are estimated to be $54,800 per year; the FR Y-12 and FR Y-12A reports are
estimated to be $16,900 per year; the FR Y-14A, FR Y-14Q, and FR Y-14M reports are
estimated to be $5,580,000 per year; the FR Y-15 are estimated to be $12,600 per year; and the
FR 4200 and FR 4201 cost to the Federal Reserve System is negligible and no further estimates
will be obtained for these information collections.

19

Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $17, 45% Financial Managers at
$65, 15% Lawyers at $66, and 10% Chief Executives at $89). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2015, published March 30, 2016 www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

21