OMB Control No. 1550-0023
The Office of Thrift Supervision (OTS) collects financial data from insured savings associations, which are used to regulate and supervise the industry and to develop policy. The vehicle used to collect these data is the Thrift Financial Report (TFR). OTS collects financial data from insured savings associations, their subsidiaries, and their holding companies in order to assure their safety and soundness as depositories of the personal monies of the general public.
OTS NEEDS TO EXPLAIN THE REVISIONS FOR THIS SUBMISSION
On March 31, 2007, the Office of the Comptroller of the Currency (OCC), Treasury; Board of Governors of the Federal Reserve System (Board); Federal Deposit Insurance Corporation (FDIC); and the OTS introduced a revision and reduction in the overall reporting requirements related to deposit insurance assessments in Call Report Schedule RC-O and TFR Schedule DI, respectively, that was intended to simplify regulatory reporting. As part of these revised overall reporting requirements, the agencies provided an interim period covering the March 31, 2007, through December 31, 2007; report dates during which each institution had the option to submit its Call Reports or TFRs using either the current or revised formats for reporting the data used to measure their assessment base. The revised reporting format will take effect for all institutions on March 31, 2008, at which time the current reporting format will be eliminated.
The instructions issued in March 2007 for the revised reporting format state that an institution that becomes newly insured on or after April 1, 2008, would be required to report daily average balances beginning in the first quarterly Call Report or TFR that it files. However, these instructions do not conform to the language in Section 327.5(a)(1) of the FDIC’s assessment regulations (12 CFR 327.5(a)(1)) with respect to their treatment of institutions that become insured between April 1, 2007, and March 31, 2008. Therefore, the agencies proposed to revise the instructions to Call Report Schedule RC-O and TFR Schedule DI to require an institution that becomes insured after March 31, 2007, but on or before March 31, 2008, to begin reporting daily average balances in its Call Report or TFR for the March 31, 2008, report date.
On September 11, 2007, the banking agencies and the OTS requested comment on proposed revisions to the Call Report and the TFR (72 FR 51814), which are currently approved collections of information. All four agencies proposed to revise the Call Report and TFR instructions for reporting daily average deposit data by newly insured institutions for deposit insurance assessment purposes to conform the instructions with the FDIC’s assessment regulations (12 CFR Part 327). The revision would eliminate seven line items from TFR Schedule DI. This was the only revision proposed to the TFR.
The revisions to the Call Report and the TFR, which were approved for publication by the Federal Financial Institutions Examination Council (FFIEC), were proposed to take effect as of March 31, 2008. No comments were received on the instructional change for reporting daily average deposit data by newly insured institutions (the only proposed revision that also applied to the TFR). Thus, the revision for reporting daily average deposit data by newly insured institutions will be implemented as proposed.
On
July 31, 2006, OTS requested public comment for 60 days (71 FR 43286)
on proposed revisions to the Thrift Financial Report (TFR), which is
currently an approved collection of information. The proposed
revisions would eliminate ten line items from the TFR, revise six
existing items, add 16 new items, and eliminate confidential
treatment of Schedule HC data. After considering the comments
received, OTS has adopted the proposed revisions, with the exception
of the proposal to eliminate Schedule HC data from confidential
treatment, and is setting the effective date for the revisions at
March 31, 2007.
Subsequently,
on October 31, 2006, the Office of the Comptroller of the Currency
(OCC), Board of Governors of the Federal Reserve System (FRB),
Federal
Deposit
Insurance Corporation (FDIC), and OTS (collectively, the agencies)
requested comment on proposed revisions to the Call Report and
additional changes to the TFR (71 FR 63848). The agencies are
jointly proposing reductions in the data required to determine an
insured institution's deposit assessment base. For savings
associations, data collected would be reduced from eight items to no
more than six items. In addition, the FRB requested an addition of
two items to the TFR for a more accurate construction of monetary
aggregates and monetary policy purposes. These changes will also be
implemented with the March 31, 2007, TFR. There were no comments
directly relating to these proposed TFR changes.
OTS
is submitting the adopted revisions published in both the July 31st
and October 31st
notices to OMB for review and approval, with the exception of the
proposal to eliminate Schedule HC data from confidential treatment.
Overall, OTS has considered a range of potential information needs
and identified those additions to the TFR that are believed to be
most critical and relevant to OTS as it seeks to fulfill its
supervisory responsibilities. At the same time, OTS identified
certain existing TFR data that are no longer relevant or useful to
warrant their continued collection. OTS believes that the reporting
burden that would result from the new TFR items discussed herein
would slightly decrease, due to a small increase in individual
institution burden and a decrease in number of respondents. After
savings associations make any necessary changes to their systems and
records, OTS estimated that these reporting changes would produce an
average net increase of 0.5 hours per institution per year in the
ongoing reporting burden of the affected schedules. Nevertheless,
when viewing these proposed revisions to the TFR within a larger
context, they are intended to maintain the effectiveness of the on-
and off-site supervision activities of the OTS, which should help to
control the overall regulatory burden on institutions.
Additionally, this
submission implements Section 601 of the Financial Services
Regulatory Relief Act of 2006 (Relief Act), which removed several
statutory reporting requirements relating to insider lending by banks
and savings associations. One of these amendments, which became
effective on October 13, 2006, eliminated the requirement that an
institution include a separate report with its TFR each quarter on
any extensions of credit the institution has made to its executive
officers since the date of its last TFR. Accordingly, institutions
are no longer required to report on such extensions of credit
effective December 31, 2006, and the “Special Report” on
loans to executive officers, which has been included with the TFR in
previous quarters, is being discontinued. Because the reporting
burden of this “Special Report” has been included in the
burden for the TFR information collections, the agencies have
adjusted the burden of these collections in response to this
statutory change and the elimination of the reporting requirement.
OTS uses this information to monitor the condition, performance, and risk profile of individual institutions and systemic risk among groups of institutions and the industry as a whole.
Since 1993, all reporting associations file their TFRs electronically. Electronic transmission has significantly reduced the reporting burden and has improved data quality by reducing transcription errors and providing edit checks at the source of the data entry. OTS internally developed and maintains the electronic filing software and provides it free-of-charge to all savings associations in Microsoft Windows on a CDROM. The electronic software sums totals, brings forward beginning balances, and calculates certain fields, eliminating the need for data entry for approximately 20% of the fields in the TFR. There are over 900 edit checks in the electronic software that allow associations to self-edit their data prior to transmitting the report. The software allows associations to explain any valid deviations from the edits in a memorandum system called “User Notes.” These enhancements reduce the amount of time OTS staff has to spend in validating the data and reduce the number of phone calls made to the associations, thus reducing burden on the industry. OTS is currently exploring a web-based data collection application. A web-based application will achieve greater efficiencies in the data collection and report dissemination processes.
This information collection is not duplicative within the meaning of the PRA and OMB regulations. Information that is similar to or that corresponds to information that could serve OTS's purpose and need in this information collection is not being collected from OTS regulated institutions by any other means or for any other purpose; nor is this information otherwise available in the detail necessary to satisfy the purpose and need for which this collection of information is undertaken. However, the data gathered in this information collection are shared with the other Federal financial institution regulators, state financial institution regulators, and other Federal agencies.
Although the collection of information affects a significant number of small businesses, OTS does not anticipate that the net economic impact will be large.
Collection of this information less frequently than quarterly would hinder the ability of OTS to monitor the industry and perform its supervisory function.
This collection meets the guidelines in 5 C.F.R. Part 1320.
The banking agencies and the OTS has have jointly published the 60-day Federal Register Notice and comments are posted on our web page.
Changes to Schedule DIs SC, SO, LD, CF, SI, SQ, and HC
No comments were received on the instructional change for reporting daily average deposit data by newly insured institutions (the only proposed revision that also applied to the TFR). Thus, the revision for reporting daily average deposit data by newly insured institutions will be implemented as proposed.
ANY CHANGES
On
July 31, 2006, OTS requested public comment for 60 days (71 FR 43286)
on proposed revisions to the Thrift Financial Report (TFR), which is
currently an approved collection of information. The notice
described regulatory reporting revisions proposed for the TFR,
Schedule SC – Consolidated Statement of Condition, Schedule SO
– Consolidated Statement of Operations, Schedule LD –
Loan Data, Schedule CF – Consolidated Cash Flow Information,
Schedule SI – Supplemental Information, Schedule SQ –
Consolidated Supplemental Questions, and Schedule HC – Thrift
Holding Company. The proposed revisions would eliminate ten line
items from the TFR, revise six existing items, add 16 new items, and
eliminate confidential treatment of Schedule HC data.
OTS received four comment letters on the July 2006 proposal from the National Association of Home Builders (NAHB), a trade group whose members include savings associations, from the Bureau of Economic Analysis (BEA), an agency of the U.S. Department of Commerce, and from two OTS-supervised savings associations. The BEA was supportive of the proposed changes and indicated the changes would allow it to continue certain data and statistical series derived in part from TFR data.
The
NAHB supported the proposed changes and encouraged the addition of
line items to collect data on the volume and performance of loans for
the development of land for 1-4 family dwelling residential housing,
and loans for the development of land for multifamily housing. The
NAHB believes this additional reporting detail would assist in
improving efficiency and competition in the market for residential
acquisition and development loans, and would demonstrate different
performance characteristics between construction and land development
loans. After careful consideration of the NAHB comments, OTS has
decided to consider these additional line items in a future revision
of the TFR.
Both
comments from savings associations focused on the proposal to
eliminate confidential treatment of data filed by individual thrift
holding companies on Schedule HC. One savings association commenter
suggested permitting filers of Schedule HC data to opt to maintain
the confidentiality of the individual company’s data, citing
competitive concerns and privacy issues.
The
other savings association commenter requested maintaining the
confidentiality of individual companies’ Schedule HC data,
citing the already extensive reporting and disclosure requirements of
companies with registered securities. This commenter also asserted
that much of the consolidated financial information required by
Schedule HC is included in the financial statements filed by public
savings and loan holding companies with the Securities and Exchange
Commission (SEC) pursuant to the Securities Act of 1934. The
commenter stated that quarterly parent company only information is
not normally available to the public. He noted that parent company
only financial data of large bank holding companies collected by the
Federal Reserve Board on Form FR Y-9LP may be released by the Board
upon special request on an individual basis, but that any data
released is limited to financial information.
OTS
presently does not publicly release Schedule HC data filed by holding
companies. However, public requests are received for these data. In
addition, some rating agencies have indicated thrift holding company
debt ratings suffer due to the lack of publicly available data.
After careful consideration of the comments related to Schedule HC,
OTS has decided to maintain the confidentiality of individual company
Schedule HC data. OTS-supervised holding companies with outstanding
debt rated by the rating agencies, or considering issuing such debt,
are encouraged to discuss information needs with the rating agencies.
OTS has considered these
comments and has decided to proceed with the proposed changes to
Schedules SC, SO, LD, CF, SI, SQ, and HC, but will not eliminate the
confidential treatment of Schedule HC. These changes will become
effective on March 31, 2007.
Changes to Schedule DI
ANY REVISIONS
On
October 31, 2006, the agencies requested comment on proposed
revisions to the Call Report and the TFR (71 FR 63848). All four
agencies proposed to replace certain information currently collected
in the Call Report and TFR for deposit insurance assessment purposes
with the information described in proposed amendments to Part 327 of
the FDIC’s regulations (71 FR 28790, May 18, 2006).1
The agencies also proposed to revise the information collected in
the Call Report and TFR on time deposits, particularly with respect
to certain retirement accounts affected by the FDIC’s amended
deposit insurance regulations.
These revisions to the Call Report and the TFR, which were approved for publication by the FFIEC, were proposed to take effect as of March 31, 2007, and, for certain deposit insurance assessment revisions, March 31, 2008. After considering the comments and other actions since the publication of the proposal, the agencies approved certain modifications to the initial set of proposed revisions. The agencies will move forward with these modified reporting changes on March 31, 2007, and March 31, 2008, as proposed. For the March 31, 2007, report date only, institutions may provide reasonable estimates for any new or revised Call Report or TFR item for which the requested information is not readily available. None of the comments received directly related to the proposed TFR changes.
OTS provides no payment or gift to respondents.
OTS does not include in the TFR instructions any explicit guarantee of confidentiality of this information. All but a very limited number of TFR data items, are available to the general public. Data from Schedules LD and HC, including the proposed changes, are confidential. Other data revisions proposed in this notice are available to the general public. For a complete listing of TFR confidential data, please see http://www.ots.treas.gov/docs/7/78196.pdf.
The TFR form does not request any information that could be considered personally sensitive.
OTS estimates 838 savings associations (“respondents”). The total annual hour burden to the respondents is estimated at 122,348, representing 4 submissions per respondent at 36.5 hours each submission.
838 savings associations x 36.5 hours = 30,587 hours per response
30,587 hours x 4 submissions per year = 122,348 hours.*
*The estimate applies to Schedules SC, SO, VA, PD, CC, CF, DI, SI, and SQ only. The proposed total estimate for the entire TFR is 193,881 hours. Please refer to the attached chart for burden detail by schedule.
13. Estimate of Annual Cost
The cost to the thrift industry for the reporting burden of these quarterly TFR schedules would be $3,058,700.
The burden per report was derived by multiplying the number of items requiring input by the number of reports per year, with appropriate adjustment of especially difficult items. Variation in burden among reporting associations exists depending on the extent to which their activities require an entry in every item requested on the reporting form, the complexity of calculating the entry for an individual association, and the extent to which their own accounting systems conform to the requirements of the reporting form.
The total annualized cost to the federal government will be minimal.
This submission reflects a decrease in the number of respondents (from 845 to 838) resulting in an adjustment of -1,600 hours. Also an increase in the form of a program change in the amount of 2,342 hours.
OTS publishes a series of statistical reports of aggregate data on a national and geographical area basis. Financial institutions, investment consultants, real estate consultants, brokers, and appraisers as well as other Federal and state government agencies and institutions of higher learning use the publications. These statistical reports are an adjunct to the data collected, which are primarily for supervisory purposes.
OTS has received permission to not display the expiration date on this form. This form is revised and issued annually. The expiration date will not assist the public in determining if this is the correct form to be used when filing with OTS. In addition, OTS distributes copies of the current form to all institutions and other interested parties and posts it on the OTS web site whenever the report is changed.
There are no exceptions to the certification statement on OMB Form 83-I.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.
1
On November 30,
2006, the FDIC published a final rule amending Part 327 of its
regulations to improve and modernize its operational systems for
deposit insurance assessments (71 FR 69270).
| File Type | application/msword |
| File Title | THRIFT FINANCIAL REPORT |
| Author | Ira Mills |
| Last Modified By | Ira Mills |
| File Modified | 2008-02-11 |
| File Created | 2008-02-11 |