ConfidentialCheckbox_20150828_omb

Supporting Statement for the
Confidential Treatment Checkboxes on the Financial Statements for Holding Companies
(FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES; OMB No. 7100-0128),
(FR Y-12; OMB No. 7100-0300), (FR Y-15, OMB No. 7100-0352),
(FR Y-11 and FR Y-11S; OMB No. 7100-0244),
(FR 2314 and FR 2314S; OMB No. 7100-0073),
(FR Y-7N, FR Y-7NS, and FR Y-7Q; OMB No. 7100-0125),
(FR 2320; OMB No. 7100-0345), (FR H-(b)11; OMB No.7100-0334), and
(FR 2886b; OMB No. 7100-0086)
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 financial statements for holding companies for
implementation in March 2016:
(1) Consolidated Financial Statements for Holding Companies (FR Y-9C), Parent Company
Only Financial Statements for Large Holding Companies (FR Y-9LP), Parent Company
Only Financial Statements for Small Holding Companies (FR Y-9SP), and Financial
Statements for Employee Stock Ownership Plan Holding Companies (FR Y-9ES)
(OMB No. 7100-0128),1
(2) Consolidated Holding Company Report of Equity Investments in Nonfinancial
Companies (FR Y-12; OMB No. 7100-0300),
(3) Banking Organization System Risk Report (FR Y-15; OMB No. 7100-0352),
(4) Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies (FR Y11) and Abbreviated Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding
Companies (FR Y-11S) (OMB No. 7100-0244),
(5) Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314)
and Abbreviated Financial Statements of Foreign Subsidiaries of U.S. Banking
Organizations (FR 2314S) (OMB No. 7100-0073),
(6) Financial Statements of U.S. Nonbank Subsidiaries Held by Foreign Banking
Organizations (FR Y-7N), Abbreviated Financial Statements of U.S. Nonbank
Subsidiaries Held by Foreign Banking Organizations (FR Y-7NS), and Capital and Asset
Report for Foreign Banking Organizations (FR Y-7Q) (OMB No. 7100-0125),
(7) Quarterly Savings and Loan Holding Company Report (FR 2320; OMB No. 7100-0345),
(8) Savings Association Holding Company Report (FR H-(b)11; OMB No.7100-0334), and
(9) Consolidated Report of Condition and Income for Edge and Agreement Corporations
(FR 2886b; OMB No. 7100-0086).
Pursuant to the Bank Holding Company Act of 1956, as amended, and the Home
Owners’ Loan Act (HOLA), the Federal Reserve requires bank holding companies (BHCs),
savings and loan holding companies (SLHCs), and securities holding companies (collectively,
holding companies (HCs)) to provide standardized financial statements to fulfill the Federal
Reserve’s statutory obligation to supervise these organizations. HCs file the FR Y-9C and FR Y9LP quarterly, the FR Y-9SP semiannually, and the FR Y-9ES annually.
1

The family of FR Y-9 reporting forms also contains the Supplement to the Consolidated Financial Statements for
Holding Companies (FR Y-9CS) which is not being revised.

The FR Y-12 collects information from certain domestic BHCs and SLHCs on their
equity investments in nonfinancial companies. The FR Y-12 data serve as an important riskmonitoring device for institutions active in this business line by allowing supervisory staff to
monitor an institution’s activity between review dates. They also serve as an early warning
mechanism, to identity institutions whose activities in this area are growing rapidly and therefore
warrant special supervisory attention. Respondents report the FR Y-12 either quarterly or semiannually based on reporting threshold criteria.
The FR Y-15 annual report collects systemic risk data from U.S. BHCs with total
consolidated assets of $50 billion or more, and any U.S.-based organizations identified as global
systemically important banks (GSIBs)2 that do not otherwise meet the consolidated assets
threshold for BHCs.3 The Federal Reserve uses the FR Y-15 data primarily to monitor, on an
ongoing basis, the systemic risk profile of the institutions which are subject to enhanced
prudential standards under section 165 of the Dodd-Frank Wall Street Reform and Consumer
Protection Act (DFA).4
The FR Y-11 and FR Y-11S reporting forms collect financial information for individual
non-functionally regulated U.S. nonbank subsidiaries of domestic HCs. HCs file the FR Y-11 on
a quarterly or annual basis or the FR Y-11S annually based on size thresholds, and for the FR Y11S, based on an additional threshold related to the percentage of consolidated assets of the toptier organization. The FR Y-11 family of reports data are used with other HC data to assess the
condition of HCs that are heavily engaged in nonbanking activities and to monitor the volume,
nature, and condition of their nonbanking operations.
The FR 2314 and FR 2314S reporting forms collect financial information for nonfunctionally regulated direct or indirect foreign subsidiaries of U.S. state member banks (SMBs),
Edge and agreement corporations, and HCs. Parent organizations (SMBs, Edge and agreement
corporations, or HCs) file the FR 2314 on a quarterly or annual basis or the FR 2314S annually
based on additional size thresholds. The FR 2314 family of reports data are used to identify
current and potential problems at the foreign subsidiaries of U.S. parent companies, to monitor
the activities of U.S. banking organizations in specific countries, and to develop a better
understanding of activities within the industry, in general, and of individual institutions, in
particular.
The FR Y-7N and FR Y-7NS collect financial information for non-functionally regulated
U.S. nonbank subsidiaries held by foreign banking organizations (FBOs) other than through a
U.S. BHC, U.S. financial holding company (FHC), or U.S. bank. FBOs file the FR Y-7N
quarterly or annually or the FR Y-7NS annually predominantly based on asset size thresholds.
The FR Y-7Q collects consolidated regulatory capital information from all FBOs either quarterly
or annually. The FR Y-7Q is filed quarterly by FBOs that have effectively elected to become
2

See Update of group of global systemically important banks (G–SIBs), available at
www.financialstabilityboard.org/publications/r_121031ac.pdf.
3
To allow additional time for compliance, the Federal Reserve limited the FR Y-15 reporting panel for the
December 31, 2012, as of date to the eight U.S. top-tier BHCs that were designated as GSIBs by the Financial
Stability Board on November 1, 2012 (77 FR 76484).
4
See 12 U.S.C. 5365.

2

FHCs and by FBOs that have total consolidated assets of $50 billion or more, regardless of FHC
status. All other FBOs file the FR Y-7Q annually.
The FR 2320 collects select parent only and consolidated balance sheet and income
statement financial data and organizational structure data from SLHCs exempt from initially
filing Federal Reserve regulatory reports.5 The FR 2320 is used by the Federal Reserve to
analyze the overall financial condition of exempt SLHCs to ensure safe and sound operations.
The FR H-(b)11 collects from exempt SLHCs information on filings with the Securities
and Exchange Commission (SEC), reports provided by the nationally recognized statistical rating
organizations and securities analysts, supplemental information for select questions from the
FR 2320, financial statements, and other materially important events and exhibits. The Federal
Reserve uses the FR H-(b)11 data to analyze the overall financial condition of SLHCs to ensure
safe and sound operations.
The FR 2886b collects quarterly financial data from banking Edge and agreement
corporations6 and investment (nonbanking) Edge and agreement corporations. Except for
examination reports, it provides the only financial data available for these corporations. The
Federal Reserve is solely responsible for authorizing, supervising, and assigning ratings to Edge
and agreement corporations. The Federal Reserve uses the data collected on the FR 2886b to
identify present and potential problems and monitor and develop a better understanding of
activities within the industry.
The Board proposes to add questions regarding confidential treatment in the form of
check boxes to all of the reports listed on page one so institutions may indicate whether they are
requesting confidential treatment for any portion of the data provided, and whether they are
submitting a formal justification with the data or separately. The proposed revision would
enhance existing processes related to the handling of data confidentiality requests. A sample of a
marked up reporting form page and general instructions is provided in the attachment. The
questions regarding confidential treatment in the form of check boxes would be effective
March 31, 2016.
The total current annual burden for these series of reports would remain unchanged since
there is currently a requirement that written requests be provided for confidential treatment. The
Board believes the change in burden associated with the change in procedures for processing
would be nominal. For detailed annual burden information on each report, see the burden tables
under the Estimates of Respondent Burden section at the end of this proposal.

5

An exempt SLHC meets one of the following criteria (1) formed under section 10(c)(9)(C) of the HOLA whose
saving association subsidiaries’ consolidated assets make up less than 5 percent of the total consolidated assets of
the SLHCs or (2) its top-tier HC is an insurance company that only prepares financial statements using statutory
accounting principles.
6
Regulation K defines an Edge corporation as being engaged in banking if it accepts deposits in the U.S. from
nonaffiliated parties as an ordinary part of its business.

3

Background and Justification
The FR Y-9C, FR Y-9LP, and FR Y-9SP serve as standardized consolidated and/or
parent only financial statements for HC’s and the FR Y-9ES is a financial statement for HCs that
are Employee Stock Ownership Plans (ESOPs). The Board also has the authority to use the
FR Y-9CS (a free-form supplement) to collect additional information deemed to be (1) critical
and (2) needed in an expedited manner. On December 18, 2014, the President signed into law
Public Law 113-250 (the Act), which directed the Board to propose revisions to the Small Bank
Holding Company Policy Statement (Policy Statement) to raise the total consolidated asset limit
in the Policy Statement from $500 million to $1 billion, and expand the scope of the Policy
Statement to include SLHCs. On January 29, 2015, the Board announced revisions and proposed
reporting changes and capital requirements to the FR Y-9 reports effective in 2015. The interim
final rule and the notice of proposed rulemaking were published in the Federal Register notice
on February 3, 2015.7
The FR Y-9 family of reporting forms continues to be the primary source of financial
data for HCs on which examiners rely between on-site inspections and off-site assessments
through the Small Bank Holding Company Supervision Program. Financial data from these
reporting forms is used to detect emerging financial problems, to review performance and
conduct pre-inspection analysis, to monitor and evaluate capital adequacy, to evaluate HC
mergers and acquisitions, and to analyze an HC’s overall financial condition to ensure the safety
and soundness of its operations.
The FR Y-12 report was implemented in September 2001, in response to the GrammLeach-Bliley Act (GLB Act) of 1999, which substantially broadened the scope of permissible
investment in nonfinancial companies. These investments present the potential for additional
volatility and risk in banking organizations’ portfolios. The FR Y-12 data serve as an important
risk-monitoring device for institutions active in this business line by allowing supervisory staff to
monitor an institution’s activity between review dates. The data also serve as an early warning
mechanism to identify institutions whose activities in this area are growing rapidly and therefore
warrant special supervisory attention.
The FR Y-15 report was implemented in response to the financial crisis, the Basel
Committee on Banking Supervision (BCBS) adopted a series of reforms to improve the
resilience of banks and banking systems. Among those reforms is a capital surcharge (GSIB
surcharge) that increases for GSIBs the “capital conservation buffer” the BCBS included in the
revised international standards it published in 2010, Basel III: A Global Regulatory Framework
for More Resilient Banks and Banking Systems (Basel III).8
The FR Y-15 was implemented on December 31, 2012. In addition to (1) facilitating the
future implementation of the GSIB surcharge through regulation, (2) identifying institutions that
may be GSIBs under a future framework, and (3) analyzing the systemic risk implications of
proposed mergers and acquisitions, the Federal Reserve uses the FR Y-15 data to monitor, on an
7
8

See 80 FR 5666 and 5694.
The Basel III framework is available at www.bis.org/publ/bcbs189.htm.

4

ongoing basis, the systemic risk profile of the institutions which are subject to enhanced
prudential standards under section 165 of DFA. The Federal Reserve also submits data to the
BCBS for use in determining whether an institution is a GSIB and, if so, which GSIB surcharge
would be applicable to it.9
The FR Y-11 family of reports collects financial information for individual U.S. nonbank
subsidiaries of domestic HCs, which is essential for monitoring the subsidiaries’ potential impact
on the HC or its subsidiary banks’ condition. In addition to providing information used in the
supervision of HCs, the FR Y-11 family of reports provides essential information to assist the
Board in the formulation of regulations and supervisory policies. The data are also used by the
Board to respond to requests from Congress and the public for information on HCs.
The FR 2314 family of reports is the only source of comprehensive and systematic data
on the assets, liabilities, and earnings of foreign subsidiaries of U.S. banking organizations and
the data are used to monitor the growth, profitability, and activities of these foreign companies.
The data help the Federal Reserve identify present and potential problems of these companies,
monitor their activities in specific countries, and develop a better understanding of activities
within the industry and within specific institutions. This information, coupled with information
from the Foreign Branch Reports of Condition (FFIEC 030; OMB No. 7100-0071), provides a
picture of the breadth and scope of international banking operations for U.S. banking
organizations both individually and in the aggregate.
The FR Y-7N, FR Y-7NS, and FR Y-7Q continues to be the primary source of financial
data for non-functionally regulated U.S. nonbanks subsidiaries held by FBOs other than through
a HC, FHC, or U.S. bank. With the enactment of the International Banking Act of 1978 (IBA),
the Congress established a framework for federal regulation of foreign banks operating in U.S.
financial markets. The Federal Reserve System uses information collected on the FR Y-7N,
FR Y-7NS, and FR Y-7Q reports to assess an FBO’s ability to be a continuing source of strength
to its U.S. operations and to determine compliance with U.S. laws and regulations. This
information is not available from other sources.
The Federal Reserve uses the FR 2320 and FR H-(b)11 data to analyze the overall
financial condition of exempt SLHCs to ensure safe and sound operations. The information is
also used to assess the SLHC’s ability to be a continuing source of strength to its savings
association operations and in determining whether an institution is in compliance with applicable
laws and regulations. These reports assist the Federal Reserve in the evaluation of a diversified
HC and in determining whether an institution is in compliance with applicable laws and
regulations.
The FR 2886b continues to be the primary source of financial data for Edge and
agreement corporations. The Federal Reserve has the sole supervisory and regulatory authority
over all Edge and agreement corporations, under sections 25 and 25A of the Federal Reserve
Act, regardless of whether they are owned by U.S. banking organizations, foreign banks, or
9

Data for BHCs with total exposures in excess of 100 billion euros are submitted to the BCBS for potential
inclusion in the GSIB assessment methodology.

5

nonbank companies. Edge and agreement corporations have been operating since 1919 and
during most of that time have been required to provide some type of financial information to the
Federal Reserve.
Information collected on the FR 2886b is used to help plan and target the scope of
examinations of Edge and agreement corporations and in the evaluation of applications. Data
from the FR 2886b are also used to monitor aggregate institutional trends, such as growth in
assets and the number of offices, changes in leverage, and the types and locations of customers.
Description of the Information Collection
FR Y-9C
The FR Y-9C consists of standardized financial statements similar to the Call Reports
filed by commercial banks. It collects consolidated data from HCs and is filed quarterly by toptier HCs with total consolidated assets of $1 billion or more.10
FR Y-9LP
The FR Y-9LP includes standardized financial statements filed quarterly on a parent
company only basis from each HC that files the FR Y-9C. In addition, for tiered HCs, a separate
FR Y-9LP must be filed for each lower-tier HC.
FR Y-9SP
The FR Y-9SP is a parent company only financial statement filed semiannually by
smaller HCs. Respondents include HCs with total consolidated assets of less than $1 billion.
This form is a simplified or abbreviated version of the FR Y-9LP. This report is designed to
obtain basic parent company balance sheet and income data, data on intangible assets, and data
on intercompany transactions.
FR Y-9ES
The FR Y-9ES collects annual financial data from ESOPs, which are also HCs, on their
benefit plan activities. It consists of four schedules: a Statement of Changes in Net Assets
Available for Benefits, a Statement of Net Assets Available for Benefits, Memoranda, and Notes
to the Financial Statements.
FR Y-12
The FR Y-12 collects information on the types of investments made by BHCs, SLHCs
and their subsidiaries in nonfinancial companies (excluding investments held in trading
accounts). The FR Y-12 reporting panel comprises a subset of top-tier domestic HCs that file the
FR Y-9C or the FR Y-9SP and meet the FR Y-12 reporting threshold criteria. A screening
10

Under certain circumstances described in the General Instructions, HCs with assets under $1 billion may be
required to file the FR Y-9C.

6

question on both FR Y-9 reports is used to determine whether the HC is required to complete the
FR Y-12. The FR Y-12 reporting form comprises four schedules: Schedule A - Type of
Investments, Schedule B - Type of Security, Schedule C - Type of Entity within the Banking
Organization, and Schedule D – Nonfinancial Investment Transactions During Reporting Period.
FR Y-15
The FR Y-15 report collects consolidated systemic risk data from large U.S. BHCs. The
data items collected in this report mirror those developed by the Basel Committee on Banking
Supervision (BCBS) to assess the global systemic importance of banks. The FR Y-15 reporting
form comprises six schedules each consisting of one or more systemic risk indicators: Schedule
A - Size Indicator, Schedule B - Interconnectedness Indicators, Schedule C - Substitutability
Indictors, Schedule D - Complexity Indicators, Schedule E - Cross-Jurisdictional Activity
Indicators, and Schedule F - Ancillary Indicators.
FR Y-11 and FR 2314
Domestic BHCs file the FR Y-11 for their U.S. nonbank subsidiaries. The FR 2314
collects financial information for direct or indirect foreign subsidiaries of U.S. SMBs, Edge and
agreement corporations, and BHCs. The FR Y-11 and FR 2314 consists of an income statement
and balance sheet, schedules that collect information on changes in equity capital, the allowance
for loan and lease losses, off-balance-sheet data items, loans, and a memoranda section. These
reports are filed quarterly, as of the last calendar day of March, June, September, and December.
The FR Y-11 and FR 2314 are filed annually, as of December 31, for each individual subsidiary
(that does not meet the criteria for filing quarterly) with total assets of at least $500 million, but
less than $1 billion.
The FR Y-11S and FR 2314S are abbreviated reporting forms that collect four data items:
net income, total assets, equity capital, and total off-balance-sheet data items. These reporting
forms are filed annually, as of December 31, for each individual subsidiary with total assets of at
least $250 million, but less than $500 million.
FR Y-7N/NS and FR Y-7Q
The FR Y-7N consists of an income statement and a balance sheet, schedules that collect
information on changes in equity capital, changes in the allowance for loan and lease losses, offbalance-sheet data items, loans, and a memoranda section. All FBOs file the FR Y-7N quarterly
for their significant nonbank subsidiaries, or annually, as of December 31, for each individual
nonbank subsidiary that does not meet the criteria for filing quarterly. The FR Y-7NS is an
abbreviated reporting form that collects net income, total assets, equity capital, and total offbalance-sheet data items. The FR Y-7NS is filed annually, as of December 31 by top-tier FBOs
for each individual nonbank subsidiary that does not meet the filing criteria for filing the FR Y7N report.
The FR Y-7Q collects consolidated capital and asset information from all FBOs. The
reporting form collects tier 1 capital, total risk-based capital, risk-weighted assets, total assets

7

and total combined assets of U.S. operations, net of intercompany balances and transactions
between U.S. domiciled affiliates, branches, and agencies. In addition, FBOs that file the FR Y7Q because of the FHC designation also must provide separate capital schedules quarterly for
each lower-tier FBO operating a branch, agency, Edge or agreement corporation, or commercial
lending company in the United States. The FR Y-7Q is filed quarterly by FBOs if the top-tier
FBO or any FBO in its tiered structure has effectively elected to be an FHC, and by FBOs with
total consolidated assets of $50 billion or more, regardless of FHC status. The FR Y-7Q is filed
annually if the FBO or any FBO in its tiered structure has not effectively elected to be a FHC and
the FBO has total consolidated assets of less than $50 billion.
FR 2320
The FR 2320 collects select balance sheet and income statement, a total of 31 data
items,11 from parent only and consolidated financial data and organizational structure data from
SLHCs exempt from initially filing Federal Reserve regulatory reports.
FR H-(b)11
The FR H-(b)11 collects from exempt top-tier SLHCs information on filings with the
Securities and Exchange Commission (SEC), reports provided by the nationally recognized
statistical rating organizations and securities analysts, supplemental information for select
questions from FR 2320, financial statements, and other materially important events and
exhibits.
FR 2886b
The FR 2886b comprises a balance sheet, income statement, two schedules reconciling
changes in capital and reserve accounts, and 11 supporting schedules. This information is
collected from all Edge and agreement corporations, although investment Edges file only four of
the 11 supporting schedules: Trading Assets and Liabilities; Derivatives and Off-Balance-Sheet
Items; Claims on and Liabilities to Related Organizations; and Past Due and Nonaccrual Loans,
Leases, and Other Assets.
Proposed Revisions
The Board proposes to add questions regarding confidential treatment in the form of
check boxes to page 1 of these regulatory reports so that reporting institutions can indicate
whether they are requesting confidential treatment for any portion of the data provided and, if so,
whether they are submitting a written justification with or separate from the data. By indicating
“yes,” a reporter provides notice that the reporter is requesting confidential treatment. Further,
indicating whether the written justification is accompanying the data or has been submitted
separate from the data alerts Reserve Bank staff to the way in which it should expect to receive
the written justification and, thereby, is intended to facilitate the Reserve Bank staff’s review of
the request. Requiring institutions to indicate their request for confidential treatment in the
check boxes reduces the risk of public disclosure of data for which confidential treatment has
11

The Federal Reserve regards information submitted in response to line items 24, 25, and 26 as confidential.

8

been requested. Reporting institutions would continue to be required to submit a written
justification with the request, and that request must be received by the Reserve Bank prior to or
included with the submission of the associated data to the Reserve Bank. If an institution does
not fulfill both requirements, the request for confidential treatment cannot be fully considered by
Reserve Bank staff. Accordingly, associated data would be available for immediate public
release. The dual controls of the check boxes and written justification will mitigate the risk of
public release of confidential data while also imposing minimal burden on the reporter. The
response to the check boxes regarding the request for confidential treatment will be considered
public information. The questions regarding confidential treatment in the form of check boxes
would be effective March 31, 2016.
Frequency
The Board recommends no changes to the reporting frequency of the FR Y-9 family of
reports, FR Y-12, FR Y-15, FR Y-11, FR Y-11S, FR 2314, FR 2314S, FR Y-7N, FR Y-7NS,
FR Y-7Q, FR 2320, FR H-(b)11, or FR 2886b reports. The current reporting frequencies provide
adequate timely data to meet the analytical and supervisory needs of the Federal Reserve.
Time Schedule for Information Collection
The Federal Reserve recommends no changes to the time schedule for the FR Y-9 family
of reports, FR Y-12, FR Y-15, FR Y-11, FR Y-11S, FR 2314, FR 2314S, FR Y-7N, FR Y-7NS,
FR Y-7Q, FR 2320, FR H-(b)11, or FR 2886b reports. The current time schedule provides
adequate timely data to meet the analytical and supervisory needs of the Federal Reserve.
Legal Status
The Board’s Legal Division has determined these reports are authorized under:
FR Y9 family of reports, FR Y-12, FR Y-15, FR Y-11, and FR Y-11S: Section 5(c) of
the Bank Holding Company Act (12 U.S.C. 1844(c)) and section 10 of HOLA (12 U.S.C.
1467a(b)) and 1850a(c)(1)(A).
FR 2314 and FR 2314S: Section 5(c) of the Bank Holding Company Act (12 U.S.C.
1844(c) and sections 9(6), 25(7), and 25A(17) of the Federal Reserve Act (12 U.S.C. 324, 602,
and 625).
FR Y-7N, FR Y-7NS, and FR Y-7Q: Section 5(c) of the Bank Holding Company Act (12
U.S.C. 1844(c)) and sections 8(c) and 13 of the International Banking Act (12 U.S.C. 3106(c)
and 3108).
FR 2320: Section 312 of the DFA and section 10 of HOLA, as amended by section 369
of the DFA, (12 U.S.C. 1467a(b)(2)), as amended by Pub. L. No. 111-201, 369(8). The Board’s
Legal Division has also determined that a few of the data items that OTS had deemed
confidential, specifically the FR 2320 counterparts to items C572, C573, and C574 on Schedule

9

HC, may be protected from disclosure under exemption 4 of the Freedom of Information Act
(FOIA).
FR H-(b)11: Section 10 of the Home Owners’ Loan Act (12 U.S.C. 1467a(b)(2)(A)).
Item 3 consists of supplemental information for any questions on the FR 2320 to which the
SLHC answered “yes.” Furthermore, Board Legal has determined that supplemental information
in response to a yes answer for the FR 2320’s questions 24, 25, and 26 may be protected from
disclosure under exemption 4 of FOIA, which covers “trade secrets and commercial or financial
information obtained from a person [that is] privileged or confidential” (5 U.S.C. 522(b)(4)).
FR 2886b: Sections 25 and 25A of the Federal Reserve Act authorize the Federal
Reserve to require the FR 2886b (12 U.S.C. 602 and 625). In addition, with respect to the
contact information collected in the Patriot Act Contact Information section, the Board’s
regulation’s (12 CFR Part 211.5(m)) instruct Edge and agreement corporations to comply with
the information sharing regulations that the Department of the Treasury issued pursuant to
section 314(a) of the USA Patriot Act of 2001, Pub L 107-56, 115 Stat. 307 (31 U.S.C. 5318(h))
and implemented at 31 CFR Part 1010.520(b). Edge corporations engaged in banking, current
Schedules RC-M (with the exception of item 3) and RC-V are held confidential pursuant to
section (b)(4) of FOIA (5 U.S.C. 552(b)(4)). For investment Edge corporations, only
information collected on Schedule RC-M (with the exception of item 3) are given confidential
treatment pursuant to section (b)(4) of FOIA (5 U.S.C. 552(b)(4)). In addition, it appears that the
information provided in the Patriot Act Contact Information section may be withheld as
confidential under FOIA to prevent unauthorized individuals from falsely posing as an
institution’s point-of-contact in order to gain access to the highly sensitive and confidential
communications sent by e-mail between the Financial Crimes Enforcement Network or federal
law enforcement officials and the Patriot Act point-of-contact. The identity and contact
information of private individuals, which is collected and maintained for law enforcement
purposes under the Patriot Act, appears exempt from disclosure pursuant to exemption 7(C) of
FOIA (5 USC 552(b)(7)).
Respondents may request such treatment for any information that they believe is subject
to an exemption from disclosure pursuant to sections (b)(4), (b)(6), or (b)(8) of FOIA (5 U.S.C.
522(b)(4), (b)(6), and (b)(8)).
Consultation Outside the Agency
On March 27, 2015, the Federal Reserve published an initial notice in the Federal
Register (80 FR 16386) requesting public comment for 60 days on the revision, without
extension, of the mandatory financial statements for holding companies. The comment period
for this notice expired on May 26, 2015. The Board did not receive any public comments
addressing the proposed revisions to these information collections. However, due to delays in
enhancements to the Federal Reserve’s automated systems, the Board extended the
implementation date from June 30, 2015, to March 31, 2016. On August 28, 2015, the Board
published a final notice in the Federal register (80 RFR 52282).

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Estimates of Respondent Burden
The current annual reporting burden for the FR Y-9 family of reports is estimated to be
193,321 hours as shown in the following table. The Board believes that no additional burden
would be required since the institutions are familiar with the confidentiality requirements. The
annual burden for the FR Y-9 family of reports would represent less than 1.21 percent of total
Federal Reserve System paperwork burden.
Number of
respondents12

FR Y-9
FR Y-9C - non AA BHCs
FR Y-9C - AA BHCs
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Total

Annual
frequency

644
12
818
4,390
86
236

4
4
4
2
1
4

Estimated
Estimated
average hours annual burden
per response
hours
48.84
125,812
50.09
2,404
5.25
17,178
5.40
47,412
0.50
43
0.50
472
193,321

The total annual cost to the public for the FR Y-9 family of reports is estimated to be $9,840,039.
The current annual reporting burden for the FR Y-12 is estimated to be 1,716 hours. The
Board believes that no additional burden would be required since the institutions are familiar
with the confidentiality requirements. The total burden for the FR Y-12 represents less than 1
percent of total Federal Reserve System annual burden.

FR Y-12
FR Y-9C filers
FR Y-9SP filers

Number of
respondents13

Annual
frequency

24
4

4
2

Estimated
average hours
per response
16.5
16.5

Total

Estimated
annual burden
hours
1,584
132
1,716

The total annual cost to the public for the FR Y-12 is estimated to be $87,344.
The total annual burden for the FR Y-15 report is estimated to be 9,735 hours as shown in
the following table. The Board believes that no additional burden would be required since the
institutions are familiar with the confidentiality requirements. These reporting requirements
12

Of these respondents, 132 FR Y-9C (non AA BHCs), 0 FR Y-9C (AA BHCs), 158 FR Y-9LP, 3,839 FR Y-9SP,
86 FR Y-9ES, and 0 FR Y-9CS are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets) www.sba.gov/content/small-business-size-standards. AA BHCs
are institutions that are subject to the Advanced Capital Adequacy Framework to determine their capital
requirements.
13
Of these respondents, 4 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets).

11

represent less than 1 percent of total Federal Reserve System paperwork burden.
Number of
respondents14

FR Y-15
FR Y-15

Annual
frequency

33

1

Estimated
average hours
per response
295

Estimated
annual burden
hours
9,735

The total annual cost to the public for the FR Y-15 is estimated to be $495,512.
As shown in the following table, the current annual burden for the FR Y-11 reports is
18,836 hours and 21,461 hours for the FR 2314 reports. The Board believes that no additional
burden would be required since the institutions are familiar with the confidentiality requirements.
The reporting requirements for the FR Y-11, FR Y-11S, FR 2314, and FR 2314S reports
represent less than 1 percent of total Federal Reserve System annual burden.

FR Y-11 and FR 2314
Current
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S

Number of
respondents15

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

587
359
429

4
1
1

6.8
6.8
1.0

15,966
2,441
429
18,836

698
387
480

4
1
1

6.6
6.6
1.0

18,427
2,554
480
21,461

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

The total annual cost to the public for the FR Y-11 reports is estimated to be $958,752. The total
annual cost to the public for the FR 2314 reports is estimated to be $1,092,365.
As shown in the following table, the current annual reporting burden for the FR Y-7N,
FR Y-7NS, and FR Y-7Q family of reports is estimated to be 6,452 hours. The Board believes
that no additional burden would be required since the institutions are familiar with the
confidentiality requirements. The reporting requirements for the FR Y-7 family of reports
represent less than 1 percent of total Federal Reserve System annual burden.

14

Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets).
15
Of these respondents, 605 for the FR Y-11 family of reports and 594 for the FR 2314 family of reports are
considered small entities as defined by the Small Business Administration (i.e., entities with less than $550 million
in total assets).

12

FR Y-7N, FR Y-7NS,
and FR Y-7Q

Number of
respondent16

Annual
frequency

FR Y-7N (quarterly)
FR Y-7N (annual)
FR Y-7NS
FR Y-7Q (quarterly)
FR Y-7Q (annual)
Total

190
90
74
62
109

4
1
1
4
1

Estimated
average hours
per response
6.8
6.8
1
1.75
1.5

Estimated
annual burden
hours
5,168
612
74
434
164
6,452

The total annual cost to the public for the FR Y-7N, FR Y-7NS, and FR Y-7Q is estimated to be
$328,407.
The annual burden for the FR 2320 is estimated to be 180 hours as shown in the
following table. The Board believes that no additional burden would be required since the
institutions are familiar with the confidentiality requirements. The FR 2230 reporting
requirements represent less than 1 percent of the total Federal Reserve System paperwork
burden.

FR 2320

Number of
respondents17

Annual
frequency

FR 2320

18

4

Estimated
average hours
per response
2.5

Estimated
annual burden
hours
180

The total annual cost to the public for the FR 2320 is estimated to be $9,162.
The current annual burden for the FR H-(b)11 is estimated to be 264 hours as shown in
the following table. The estimated number of proposed respondents includes (1) grandfathered
unitary SLHCs whose assets are primarily commercial and whose thrifts make up less than 5
percent of its consolidated assets and (2) SLHCs whose assets are primarily insurance-related
and who do not otherwise submit financial reports with the SEC pursuant to section 13 or 15(d)
of the Securities Exchange Act of 1934. The estimated hours per response is based on the hourly
estimate currently associated with the FR H-(b)11 and would not change. The Board believes
that no additional burden would be required since the institutions are familiar with the
confidentiality requirements. The FR H-(b)11 reporting requirements represent less than 1
percent of the total Federal Reserve System burden.

16

Of these respondents, 116 of the FR Y-7N/NS respondents and none of the FR Y-7Q respondents are small
entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total assets).
17
Of these respondents, 4 are small entities as defined by the Small Business Administration (i.e., entities with less
than $550 million in total assets).

13

FR H-(b)11

Number of
respondent18

Annual
frequency

FR H-(b)11

33

4

Estimated
average hours
per response
2

Estimated
annual burden
hours
264

The total annual cost to the public for the FR H-(b)11 is estimated to be $13,438.
As shown in the following table, the current annual burden for the FR 2886b is estimated
to be 1,389 hours. The FR 2886b respondent panel is comprised of 47 Edge and agreement
corporations, 8 banking corporations (deposit taking institutions), and 39 investment
corporations. The estimated reporting burden is lower for investment Edges, which file only 4
supporting schedules, than for banking Edges, which file all 11 supporting schedules. The Board
believes that no additional burden would be required since the institutions are familiar with the
confidentiality requirements. These reporting requirements represent less than 1 percent of the
total Federal Reserve System paperwork burden.

FR 2886b
Banking:
Edge and agreement
corporations
(quarterly)
Edge and agreement
corporations (annual)
Investment:
Edge and agreement
corporations
(quarterly)
Edge and agreement
corporations (annual)
Total

Number of
respondents19

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

7

4

15.15

424

1

1

15.15

15

20

4

9.60

768

19

1

9.60

182
1,389

The total annual cost to the public for the FR 2886b is estimated to be $70,700.

18

Of these respondents, 4 are small entities as defined by the Small Business Administration (i.e., entities with less
than $550 million in total assets).
19
Of these respondents, 21 are small entities as defined by the Small Business Administration (i.e., entities with less
than $550 million in total assets).

14

The total annual cost to the public for all of the information collections above is estimated to be
$12,895,719.20
Sensitive Questions
This collection of information contains 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 Y-9
reports are estimated to be $1,922,600 per year; the FR Y-12 are estimated to be $16,900 per
year; the FR Y-15 are estimated to be $12,600; the FR Y-11 and FR Y-11S are estimated to be
$54,800 per year; the FR 2314 and FR 2314S are estimated to be $32,500 per year; the FR Y-7N,
FR Y-7NS, and FR Y7Q reports are estimated to be $16,800 per year; the FR 2320 are estimated
to be $21,100 per year; the costs associated with the processing of the FR H-(b)11 are minimal;
and the FR 2886b are estimated to be $14,700 per year.

20

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 $18, 45% Financial Managers at
$61, 15% Lawyers at $63, and 10% Chief Executives at $86). Hourly rate for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2013, published April 1, 2014 www.bls.gov/news.release/ocwage.nr0.htm. Occupations are defined using the
BLS Occupational Classification System, www.bls.gov/soc/

15