Reg Y-13_CapitalPlans_20111229_omb

Supporting Statement for the
Recordkeeping and Reporting Requirements Associated with Regulation Y
(Capital Plans) (Reg Y-13; OMB No. 7100-0342)
(Docket No. R-1425) (RIN 7100-AD77)
Summary
The Board of Governors of the Federal Reserve System, under delegated authority from
the Office of Management and Budget (OMB), proposes to implement, the Recordkeeping and
Reporting Requirements Associated with Regulation Y (Capital Plans) (Reg Y-13; OMB No.
7100-0342). Recent amendments to Regulation Y (12 CFR part 225) will require large bank
holding companies (BHCs) to submit capital plans to the Federal Reserve on an annual basis and
to require such BHCs to request prior approval from the Federal Reserve under certain
circumstances before making a capital distribution.1 Although there are additional data reporting
requirements, there are no required reporting forms associated with this information collection.
The Paperwork Reduction Act (PRA) classifies these requirements as an information collection
and the PRA mandates, subsequent to implementation, the Federal Reserve to renew these
requirements once every three years.
On December 1, 2011, the Federal Reserve published the Capital Plans notice of final
rulemaking (final rule) in the Federal Register for public comment (76 FR 74631). The final
rule revised the Board’s Regulation Y. Under section 165 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act of 2010 (Dodd-Frank Act or the Act), the Board is
required to impose enhanced prudential standards on large BHCs, including stress testing
requirements; enhanced capital, liquidity, and risk management requirements; and a requirement
to establish a risk committee.2 While the final rule is not mandated by the Dodd-Frank Act, the
Board believes that it is appropriate to hold large BHCs to an elevated capital planning standard
because of the elevated risk posed to the financial system by large BHCs and the importance of
capital in mitigating these risks.
Under the PRA, the Federal Reserve accounts for the paperwork burden associated with
Regulation Y for the BHCs supervised by the Federal Reserve that engage in the distribution of
capital covered by Regulation Y and, therefore, are “respondents” under the PRA. The final rule
applies to every top-tier BHC domiciled in the United States that has $50 billion or more in total
consolidated assets (large BHCs). As of September 30, 2011, there were approximately 34 large
BHCs. The asset threshold of $50 billion is consistent with the threshold established by section
165 of the Dodd- Frank Act relating to enhanced supervision and prudential standards for certain
BHCs.3 The annual burden for the 34 BHCs is estimated to be 432,764 hours.
1
2
3

Pub. L. No. 111-203, 124 Stat. 1376 (2010).
See generally section 165 of Pub. L. No. 111-203, 124 Stat. 1376 (2010) (Dodd-Frank Act); 12 U.S.C. 5365.

The Federal Reserve received a comment suggesting that the $50 billion asset threshold be measured over a four
quarter period in order to minimize the likelihood that temporary asset fluctuations will trigger the rule’s application.
In response to this comment, the Federal Reserve amended the proposal to measure ‘‘total consolidated assets’’ as
the average of a BHC’s total consolidated assets over the previous four calendar quarters, as reflected on the BHC’s

Background and Justification
During the years leading up to the recent financial crisis, many BHCs made significant
distributions of capital, in the form of stock repurchases and dividends, without due
consideration of the effects that a prolonged economic downturn could have on their capital
adequacy and ability to continue to operate and remain credit intermediaries during times of
economic and financial stress. The final rule addresses such practices, building upon the Federal
Reserve’s existing supervisory expectation that large BHCs have robust systems and processes
that incorporate forward-looking projections of revenue and losses to monitor and maintain their
internal capital adequacy.4
The Federal Reserve has long held the view that BHCs generally should operate with
capital positions well above the minimum regulatory capital ratios, with the amount of capital
held commensurate with the BHC’s risk profile.5 The BHCs should have internal processes for
assessing their capital adequacy that reflect a full understanding of their risks and ensure that
they hold capital corresponding to those risks to maintain overall capital adequacy.6 The BHCs
that are subject to the Board’s advanced approaches risk-based capital requirements must satisfy
specific requirements relating to their internal capital adequacy processes in order to use the
advanced approaches to calculate their minimum risk-based capital requirements.7
The final rule is also consistent with the Federal Reserve’s recent supervisory practice of
requiring capital plans from large, complex BHCs. In 2009, the Federal Reserve conducted the
Supervisory Capital Assessment Program (SCAP), a “stress test” of large, domestic BHCs. The
SCAP was focused on identifying whether large BHCs had capital sufficient to weather a moreadverse-than-anticipated economic environment while maintaining their capacity to lend. The
Federal Reserve required BHCs identified as having capital shortfalls to raise specific dollar
amounts of capital within six months of the release of the SCAP results. The Department of the
Consolidated Financial Statements for Bank Holding Companies (FR Y–9C; OMB No. 7100-0128). This calculation
will be effective as of the due date of the BHC’s most recent FR Y–9C. The final rule also applies to any institution
that the Board determines, by order, shall be subject in whole or in part to the rule’s requirements based on the
institution’s size, level of complexity, risk profile, scope of operations, or financial condition. The final rule provides
that a BHC that becomes subject to the final rule by operation of the asset threshold after the 5th of January of a
calendar year will not be subject until January 1 of the next calendar year to the final rule’s requirement to file a
capital plan with the Federal Reserve, resubmit a capital plan under certain circumstances, or to obtain prior
approval of capital distributions in excess of those described in the firm’s capital plan.
4
See SR letter 09-4 (Revised March 27, 2009), available at
http://www.federalreserve.gov/boarddocs/srletters/2009/SR0904.htm; see also Revised Temporary Addendum to SR
letter 09-4 (November 17, 2010) (SR 09-04), available at
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20101117b1.pdf.
5

See 12 CFR part 225, Appendix A; see also SR letter 99-18 (July 1, 1999), available at
http://www.federalreserve.gov/boarddocs/srletters/1999/SR9918.HTM.
6

See SR letter 09-4 (Revised March 27, 2009), available at
http://www.federalreserve.gov/boarddocs/srletters/2009/SR0904.htm.
7

See 12 CFR part 225, Appendix G, section 22(a); see also, Supervisory Guidance: Supervisory Review Process of
Capital Adequacy (Pillar 2) Related to the Implementation of the Basel II Advanced Capital Framework, 73 FR
44620 (July 31, 2008).

2

Treasury established a government backstop available to BHCs unable to raise the required
capital from private markets.8
In 2011, the Federal Reserve continued its supervisory evaluation of the resiliency and
capital adequacy processes of the same BHCs (that participated in the SCAP) through the
Comprehensive Capital Analysis and Review (CCAR). The CCAR involved the Federal
Reserve’s forward-looking evaluation of the internal capital planning processes of the BHCs and
their anticipated capital actions in 2011, such as increasing dividend payments or repurchasing or
redeeming stock.9 In the CCAR, the Federal Reserve evaluated whether these BHCs had
satisfactory processes for identifying capital needs and held adequate capital to maintain ready
access to funding, continue operations and meet their obligations to creditors and counterparties,
and continue to serve as credit intermediaries, even under stressful conditions.
As part of their fiduciary responsibilities to a BHC, the board of directors and senior
management bear the primary responsibility for developing, implementing, and monitoring a
BHC’s capital planning strategies and internal capital adequacy processes. The final rule does
not diminish that responsibility. Rather, it is intended to (i) establish minimum supervisory
standards for such strategies and processes for certain large BHCs; (ii) describe how boards of
directors and senior management of these BHCs should communicate the strategies and
processes, including any material changes thereto, to the Federal Reserve; and (iii) provide the
Federal Reserve with an opportunity to review BHCs’ capital distributions under certain
circumstances. The final rule is designed to be flexible enough to accommodate BHCs of
varying degrees of complexity and to adjust to changing conditions over time.
In the Board’s view, the analytical techniques and other requirements set forth in the final
rule are necessary to identify, measure, and monitor risks to the financial stability of the United
States. An elevated capital planning standard for large BHCs is appropriate because of the
heightened risk they pose to the financial system and the importance of capital in mitigating
these risks. Under section 165 of the Dodd-Frank Act, the Board is required to impose enhanced
prudential standards on large BHCs, including stress testing requirements; enhanced capital,
leverage, liquidity, and risk management requirements; and a requirement to establish a risk
committee. The Board expects that large BHCs will reflect these enhanced prudential standards,
including the results of any required stress tests, in their capital planning strategies and internal
capital adequacy processes.
The Dodd-Frank Act also requires the Board to implement early remediation
requirements on large BHCs under which a large BHC experiencing financial distress must take
specific remedial actions in order to minimize the probability that the BHC will become
insolvent and minimize the potential harm of such insolvency to the United States. These early
remediation requirements must impose limitations on capital distributions in the initial stages of
financial decline and increase in stringency as the financial condition of the company declines.
8

See Board of Governors of the Federal Reserve System, The Supervisory Capital Assessment Program: Overview
of Results (May 7, 2009), available at http://www.federalreserve.gov/bankinforeg/bcreg20090507a1.pdf.
9

See Board of Governors of the Federal Reserve System, Comprehensive Capital Analysis and Review: Objectives
and Overview (March 18, 2010), available at
http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20110318a1.pdf.

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Depending on a large BHC’s financial condition, early remediation requirements imposed under
the Dodd-Frank Act may result in limitations on a BHC’s capital distributions in addition to the
requirements that are imposed by the final rule.
Description of Information Collection
The recordkeeping and reporting requirements are found in §§225.8(d), (e), and (f). The
Federal Reserve believes that the requirements will help ensure that large BHCs have appropriate
capital plans in place to address their capital adequacy and their ability to continue operating and
to remain credit intermediaries during times of economic and financial stress. Compliance with
the information collections is mandatory. No other federal law mandates these recordkeeping
and reporting requirements.
General Requirements
Section 225.8(d)(1)(i) - This section requires a BHC to develop and maintain an initial
capital plan. The level of detail and analysis expected in a capital plan will vary based on the
BHC’s size, complexity, risk profile, scope of operations, and the effectiveness of its processes
for assessing capital adequacy.
The final rule defines a capital plan as a written presentation of a large BHC’s capital
planning strategies and capital adequacy process that includes certain mandatory elements.
These mandatory elements are organized into four main components:
 An assessment of the expected uses and sources of capital over the planning horizon (at
least nine quarters, beginning with the quarter preceding the quarter in which the BHC
submits its capital plan) that reflects the BHC’s size, complexity, risk profile, and scope
of operations, assuming both expected and stressful conditions;
 A detailed description of the BHC’s process for assessing capital adequacy;
 The BHC’s capital policy; and
 A discussion of any expected changes to the BHC’s business plan that are likely to have
a material impact on the firm’s capital adequacy or liquidity.
The mandatory elements under each component are described in section 225.8(d)(2).
Sections 225.8(d)(1)(ii) - This section requires a BHC to submit its complete capital
plan to the appropriate Reserve Bank and the Board each year by the 5th of January, or such later
date as directed by the appropriate Reserve Bank after consultation with the Board.
Section 225.8(d)(1)(iii) - This section requires the BHC’s board of directors or a
designated committee to review and approve the BHC’s capital plan prior to its submission to the
appropriate Federal Reserve Bank.
Section 225.8(d)(3) - In connection with submissions of capital plans to the Federal
Reserve, BHCs will be required to provide certain data to the Federal Reserve, including:


The BHC’s financial condition, including its capital;

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






The BHC’s structure;
Amount and risk characteristics of the BHC’s on- and off-balance sheet exposures,
including exposures within the BHC’s trading account, other trading-related exposures
(such as counterparty-credit risk exposures) or other items sensitive to changes in market
factors, including, as appropriate, information about the sensitivity of positions to
changes in market rates and prices;
The BHC’s relevant policies and procedures, including risk management policies and
procedures;
The BHC’s liquidity profile and management; and
Any other relevant qualitative or quantitative information requested by the Board or the
appropriate Reserve Bank to facilitate review of the BHC’s capital plan under this
section.

Section 225.8(d)(4) - This section requires the BHC to update and resubmit its capital
plan within 30 calendar days of the occurrence of certain events.
Review of Capital Plans by the Federal Reserve
Sections 225.8(e)(3) - Within 10 calendar days of receipt of a notice of objection by the
Board of the BHC’s capital plan, pursuant to section 225.8(e)(3), the BHC may submit a written
request for reconsideration, including an explanation of why reconsideration should be granted.
Prior Approval Request Requirements
Sections 225.8(f)(1), (2), and (3) - In certain circumstances, large BHCs will be required,
pursuant to section 225.8(f)(1), to obtain prior approval from the Federal Reserve before making
capital distributions. The final rule provides an exception to the prior approval requirements
section 225.8(f)(2) for an institution that is well capitalized and meets certain other requirements.
As listed in section 225.8(f)(3), such an approval request will be required to contain the
following information: the BHC’s current capital plan or an attestation that there have been no
changes to its current capital plan; the purpose of the transaction; a description of the capital
action, including for redemptions or repurchases of securities, the gross consideration to be paid
and the terms and sources of funding for the transaction, and for dividends, the amount of the
dividend(s); and any additional information requested by the appropriate Reserve Bank or Board,
which may include, among other information, an assessment of the BHC’s capital adequacy
under a revised stress scenario provided by the Federal Reserve, a revised capital plan, and
supporting data.
Section 225.8(f)(5) - If the Federal Reserve disapproves of a BHC’s capital distribution,
under section 225.8(f)(5), the BHC within 10 calendar days of receipt of a notice of disapproval
by the Board may submit a written request for a hearing.

5

Time Schedule for Information Collection
Information collection pursuant to the recordkeeping requirements is event-generated and
must be maintained on sight. The reporting of an initial or resubmission of a revised capital
plan, the submission of data pursuant to section 225.8(d)(3), and the submission of prior
approval requests must be provided to the Federal Reserve within the time periods established by
the regulation:









Sections 225.8(d)(1)(ii) - This section requires a BHC to submit its complete capital
plan to the appropriate Reserve Bank and the Board each year by the 5th of January, or
such later date as directed by the appropriate Reserve Bank after consultation with the
Board.
Section 225.8(d)(1)(iii) - This section requires the BHC’s board of directors or a
designated committee to review and approve the BHC’s capital plan prior to its
submission to the appropriate Federal Reserve Bank.
Section 225.8(d)(3) – This section requires BHCs to provide certain data to the Federal
Reserve, upon the request of the Board or appropriate Reserve Bank.
Section 225.8(d)(4) - This section requires the BHC to update and resubmit its capital
plan within 30 calendar days of the occurrence of certain events.
Sections 225.8(e)(3) - The BHC may submit a written request for reconsideration within
10 calendar days of receipt of a notice of objection by the Board of the BHC’s capital
plan.
Sections 225.8(f)(1) - In certain circumstances, large BHCs will be required to obtain
prior approval from the Federal Reserve before making capital distributions.
Section 225.8(f)(5) – The BHC may submit a written request for a hearing within 10
calendar days of receipt of a notice of disapproval (of a capital plan) by the Board,.

Consultation Outside of the Agency and Discussion of Public Comments
On June 17, 2011, a notice of proposed rulemaking was published in the Federal Register
(76 FR 35351) requesting comment on the implementation of the recordkeeping and reporting
requirements for the Capital Plans. The comment period expired on August 5, 2011.
The Federal Reserve received 16 comment letters none specifically addressed the PRA
analysis. Commenters included financial trade associations, BHCs, policy institutions, and
individuals. Commenters generally expressed support of the proposed rule. Several commenters
recommended one or more changes to specific provisions of the proposed rule. For instance,
many commenters provided suggestions on the timeframe under which the Federal Reserve will
review and act on a BHC’s capital plan. Commenters asked for more information related to the
data submissions that accompany the capital plan submission. In addition, many of the
commenters asked for clarification on the content of the capital plans and provided views on the
standards under which the Federal Reserve could object to capital plans. Other commenters
provided suggestions on whether BHCs should be able to make capital distributions not specified
in their capital plans without providing prior notice to the Federal Reserve and how such a
standard should be crafted. In addition, three commenters raised issues that will be relevant to

6

savings and loan holding companies should the final rule’s requirements extend to these
institutions at a future date. In developing this final rule, the Board has carefully considered the
comments received on the proposed rule. In response to these comments, the Board has clarified
the requirements of the rule and modified the proposed rule in certain respects. For example, the
Board:






Clarified in the preamble that a notice of a non-objection to a capital plan will extend
through the first quarter of the subsequent year;
Clarified in the preamble that large BHCs will remain subject to SR letter 09–4, which
provides guidance regarding capital distributions;
Revised the final rule to provide that, if the Federal Reserve objects to a BHC’s capital
plan, the BHC may not make any capital distribution (other than a capital distribution
with respect to which the Federal Reserve did not object) until such time as the Federal
Reserve issues a non-objection to the BHC’s capital plan; and
Added a limited exception that permits well capitalized large BHCs that are performing
in accordance with baseline projections to make modest capital distributions in excess of
the amount described in the BHC’s capital plan under certain circumstances.

In addition, in response to commenters’ requests for additional guidance on the nature
and scope of the data requirements (as required by section 225.8(d)(3)(i)-(vi)), that data
templates be provided at the time that the final rule becomes effective, and that the Federal
Reserve be mindful to avoid duplicative data requests the Federal Reserve published a separate
final information collection notice in the Federal Register that clarified the nature and scope of
the data requirements, including the data templates. In doing so, the Federal Reserve transferred
the majority of the burden for the data reporting requirements found in 225.8(d)(3) to the Capital
Assessments and Stress Testing (FR Y-14A/Q; OMB No. 7100-0341) information collection.
Aside from the transfer of the majority of the data reporting requirements found in
section 225.8(d)(3)(i)-(vi) and the change of the prior notice requirement to a prior approval
request found in sections 225.8(f)(1), (2), and (3), the paperwork requirements are largely being
implemented as proposed.
The entire discussion addressing all comment letters received is available in the Capital
Plans final rulemaking. After assessing the public comment letters, a press release was published
on November 22, 2011, announcing the launch of the 2012 CCAR review,10 the implementation
of the Capital Plans information collection (Reg Y-13), and the implementation of the FR Y14A/Q information collection. The press release included links to the FR Y-14A/Q Federal
Register notice (76 FR 73634), the Capital Plans final rulemaking (76 FR 74631), a Frequently
Asked Questions document, and instructions.
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.
10

The press release and attachments are available on the Board’s public website:
http://www.federalreserve.gov/newsevents/press/bcreg/20111122a.htm

7

Legal Status
The Board’s Legal Division has determined that Section 616(a) of the Dodd-Frank Act
amended section 5(b) of the Bank Holding Company Act (BHC Act) (12 U.S.C. § 1844(b)) to
specifically authorize the Board to issue regulations and orders relating to capital requirements
for BHCs. The Board is also authorized to collect and require reports from BHCs pursuant to
section 5(c) of the BHC Act (12 U.S.C. § 1844(c)). Additionally, the Board’s rulemaking
authority for the information collection and disclosure requirements associated with the Reg Y13 is found in sections 908 and 910 of the International Lending Supervision Act, as amended
(12 U.S.C. §§ 3907 and 3909). Additional support for Reg Y-13 is found in sections 165 and
166 of the Dodd-Frank Act (12 U.S.C. §§ 5365 and 5366).11
The capital plan information submitted by the covered BHC will consist of confidential
and proprietary modeling information and highly sensitive business plans, such as acquisition
plans submitted to the Federal Reserve for approval. Therefore, it appears the information will
be subject to withholding under exemption 4 of the Freedom of Information Act (5 U.S.C.
§552(b)(4)).
Estimate of Respondent Burden
The estimated total annual burden for the recordkeeping and reporting requirements of
this information collection is 432,764 hours, as shown in the table below. The final rule will
apply to every top-tier BHC domiciled in the United States with $50 billion or more in average
total consolidated assets.12 As of September 30, 2011, 34 BHCs will be required to comply with
the approved information collection.
The Federal Reserve estimates that each BHC will take, on average, 12,000 hours to
comply with the section 225.8(d)(1)(i) recordkeeping requirement to develop and maintain the
capital plan and with the section 225.8(d)(1)(ii) reporting requirement to submit the capital plan.
The burden for these requirements is estimated to be 408,000 hours, which includes the one-time
implementation burden for development of an initial capital plan.
The Federal Reserve estimates that the board of directors or a designated committee of
each BHC will take, on average, 100 hours annually to comply with the section 225.8(d)(1)(iii)
recordkeeping requirement to review and approve its capital plan and to correct any deficiencies
with the capital plan. The annual burden for this recordkeeping requirement is estimated to be
3,400 hours.

11

Section 165 requires the Board to impose enhances prudential standards on large BHCs, including stress testing
requirements; enhanced capital, liquidity, and risk management requirements; and a requirement to establish a risk
committee. Section 166 requires the Board to impose early remediation requirements on large BHCs under which a
large BHC experiencing financial distress must take specific remedial actions in order to minimize the probability
that the company will become insolvent and to minimize the potential harm of such insolvency the United States.
12
The final rule also will apply to any institution that the Board has determined, by order, shall be subject in whole
or in part to the proposed rule’s requirements based on the institution’s size, level of complexity, risk profile, scope
of operations, or financial condition.

8

The Federal Reserve estimates that the 19 CCAR BHCs will take, on average, 100 hours
annually to comply with the section 225.8(d)(3) reporting requirement to provide additional data
to the Federal Reserve in connection with the submission of capital plans. Further, the Federal
Reserve estimates that the 15 non-CCAR BHCs will take, on average, 1,000 hours annually to
comply with the section 225.8(d)(3) reporting requirement. The annual burden for these
reporting requirements is estimated to be 16,900 hours.
Upon written request from the Federal Reserve, each BHC will be required to revise and
resubmit its capital plan to the Federal Reserve. It is estimated that 10 BHCs will be requested to
provide revised capital plans. The Federal Reserve estimates that it will take this subset of
BHCs, on average, 100 hours to comply with the section 225.8(d)(4) reporting requirements to
revise and resubmit their capital plans. Of the 10 BHCs, it is estimated that 2 will provide
written request for reconsideration regarding the disapproval of its capital plan. These BHCs
will take, on average, 16 hours to comply with the section 225.8(e)(3) reporting requirement.
The annual burden for these reporting requirements is estimated to be 1,032 hours.
Each BHC will be required to request prior approval before giving capital distributions.
The 34 BHCs will take, on average, 100 hours to comply with the sections 225.8(f)(1), (2), and
(3) reporting requirements. Of the 34 BHCs, it is estimated that 2 will provide written request
for a hearing regarding the disapproval of its prior approval. The 2 BHCs will take, on average,
16 hours to comply with the section 225.8(f)(5) reporting requirement. The annual burden for
these reporting requirements is estimated to be 3,432 hours.
These Regulation Y recordkeeping and reporting requirements represent 3.75 percent of
total Federal Reserve System paperwork burden. The total cost to the public is estimated to be
$21,724,753.13

13

Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rate (10% Office & Administrative Support @ $16, 65% Financial Managers @
$50, 15% Legal Counsel @ $54, and 10% Chief Executives @ $80). Hourly rate for each occupational group are
the median hourly wages (rounded up) from the Bureau of Labor and Statistics (BLS), Occupational Employment
and Wages 2010, www.bls.gov/news.release/ocwage.nr0.htm. Occupations are defined using the BLS Occupational
Classification System, www.bls.gov/soc/.

9

Number of
respondents14

Estimated
annual
frequency

Estimated
average hours
per response

34

1

11,920

Reporting

34

1

80

2,720

Recordkeeping

34

1

100

3,400

§225.8(d)(3), Data collections
§225.8(d)(3)(i)-(vi)
CCAR BHCs Reporting
Non-CCAR BHCs Reporting

19
15

1
1

100
1,000

1,900
15,000

Reporting

10

1

100

1,000

§225.8(e), Review of capital plans
by the Federal Reserve
§225.8(e)(3)
Reporting

2

1

16

32

§225.8(f), Prior approval request
requirements
§225.8(f)(1), (2), and (3)
Reporting

34

1

100

3,400

2

1

16

32

§225.8(d)(1), Annual capital
planning
§225.8(d)(1)(i)
Recordkeeping

Estimated
annual
burden hours

405,280

§225.8(d)(1)(ii)

§225.8(d)(1)(iii)

§225.8(d)(4)

§225.8(f)(5)
Reporting

432,764

Total

Estimate of Cost to the Federal Reserve System
The cost to the Federal Reserve System for the reporting requirements associated with the
Reg Y-13 information collection is estimated to be $106,400. This is equivalent to one full time
employee on an annual basis. The other capital plan requirements, associated with the Reg Y-13,
have been integrated into the Federal Reserve’s existing supervisory process.
14

None of the respondents required to comply with the rule are small entities as defined by the Small Business
Administration (i.e., entities with less than $175 million in total assets)
www.sba.gov/contractingopportunities/officials/size/table/index.html.

10