2- Reg Y-13_CapitalPlan_R1492_20141208_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-1492) (RIN 7100-AE20)
Summary
The Board of Governors of the Federal Reserve System, under delegated authority from
the Office of Management and Budget (OMB), proposes to extend, with revision, the
Recordkeeping and Reporting Requirements Associated with Regulation Y (Capital Plans)
(Reg Y-13; OMB No. 7100-0342). Regulation Y (12 CFR part 225) requires 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 July 1, 2014, a notice of proposed rulemaking was published in the Federal Register
(79 FR 37420) requesting comment on the proposed amendments to the capital plan and stress
test rules. The proposed amendments to the capital plan and stress test rules would modify,
following a transition period, the start date of the capital plan and stress test cycles from October
1 of a calendar year to January 1 of the following calendar year. The proposed rule would make
other changes to the rules, including amending the capital plan rule to limit a bank holding
company’s ability to make capital distributions to the extent that the bank holding company’s
actual capital issuances are less than the amount indicated in its capital plan under baseline
conditions, measured on a quarterly basis. The proposed rule would clarify application of the
capital plan rule to a bank holding company that is a subsidiary of a U.S. intermediate holding
company of a foreign banking organization and the characteristics of a stressed scenario to be
included in company run stress tests. The proposed rule also would revise the Board’s Policy
Statement on the Scenario Design Framework for Stress Testing and the Board’s Regulation YY
to reflect the revisions to the start date of the stress test cycle. The comment period expired on
August 11, 2014. The Federal Reserve received 18 comments on the proposed amendments. On
October 27, 2014, a notice of final rulemaking was published in the Federal Register (79 FR
64026) implementing the revisions largely as proposed.
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) and U.S. intermediate holding companies with total
consolidated assets of $50 billion or more. As of March 31, 2014, there were approximately 52
large BHCs. The asset threshold of $50 billion is consistent with the threshold established by

1

Pub. L. No. 111-203, 124 Stat. 1376 (2010).

section 165 of the Dodd- Frank Act relating to enhanced supervision and prudential standards for
certain BHCs. 2
The current annual PRA burden for the 52 BHCs is estimated to be 687,464 hours and
with the final amendments would decrease to 685,156 hours.
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. 3
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. 4 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. 5 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. 6
2

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
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.
3
See SR letter 09-4 (Revised March 27, 2009), available at
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
www.federalreserve.gov/newsevents/press/bcreg/bcreg20101117b1.pdf
4

See 12 CFR part 225, Appendix A; see also SR letter 99-18 (July 1, 1999), available at:
www.federalreserve.gov/boarddocs/srletters/1999/SR9918.htm
5

See SR letter 09-4 (Revised March 27, 2009), available at:
www.federalreserve.gov/boarddocs/srletters/2009/SR0904.htm
6

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

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
Treasury established a government backstop available to BHCs unable to raise the required
capital from private markets. 7
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. 8 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,
7

See Board of Governors of the Federal Reserve System, The Supervisory Capital Assessment Program: Overview
of Results (May 7, 2009), available at: www.federalreserve.gov/bankinforeg/bcreg20090507a1.pdf.
8

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

3

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.
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.
On December 1, 2011, the Federal Reserve published the Capital Plans notice of final
rulemaking (final rule) in the Federal Register (76 FR 74631) revising 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. 9 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.
Description of Information Collection
The recordkeeping and reporting requirements are found in §§225.8(e), (f), and (g). 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(e)(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
9

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

4

•
•
•

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(e)(2).
Sections 225.8(e)(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. 10
Section 225.8(e)(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(e)(3) - In connection with submissions of capital plans to the Federal
Reserve, BHCs are required to provide certain data to the Federal Reserve, including:
i.
ii.
iii.

iv.
v.
vi.

vii.

The BHC’s financial condition, including its capital;
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;
The loss, revenue, and expense estimation models used by the bank holding
company for stress scenario analysis, including supporting documentation
regarding each model’s development and validation; 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(e)(4) - This section requires the BHC to update and resubmit its capital
plan within 30 calendar days of the occurrence of certain events.

10

For the capital plan cycle beginning October 1, 2014, the capital plan must be submitted by January 5, 2015, or
such later date as directed by the Board or by the appropriate Reserve Bank with concurrence of the Board. For
each capital plan cycle beginning thereafter, the capital plan must be submitted by April 5, or such later date as
directed by the Board or by the appropriate Reserve Bank with concurrence of the Board.

5

Review of Capital Plans by the Federal Reserve
Sections 225.8(f)(3)(i) - 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(f)(3), the BHC may submit a written
request for reconsideration, including an explanation of why reconsideration should be granted.
Prior Approval Request Requirements for certain capital actions
Sections 225.8(g)(1), (2), and (3) - In certain circumstances, large BHCs will be
required, pursuant to section 225.8(g)(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(g)(2) for an institution that is well capitalized and meets certain other
requirements. As listed in section 225.8(g)(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(g)(6) - If the Federal Reserve disapproves of a BHC’s capital distribution, under
section 225.8(g)(6), the BHC within 10 calendar days of receipt of a notice of disapproval by the
Board may submit a written request for a hearing.
Amendments 11
Section 225.8(e)(3)(vi) - General requirements; Annual capital planning; Data collection.
Upon the request of the Board or appropriate Reserve Bank, the bank holding company shall
provide the Federal Reserve with information regarding: loss, revenue, and expense estimation
models used by the bank holding company for stress scenario analysis, including supporting
documentation regarding each model’s development and validation. This information is needed
by supervisors in order to properly assess a bank holding company’s capital adequacy and capital
planning processes. In this regard, the information helps facilitate cross-firm comparisons of
bank holding companies’ loss, revenue, and expense estimation models and their approaches to
model validation.
Section 225.8(g)(1) - Approval requirements for certain capital actions; Circumstances
requiring approval. The final rule removes prior approval and prior notice requirements for
11

The following Sections were renumbered: Old - Section 225.8(d)(1)(i) New - Section 225.8(e)(1)(i); Old - Section
225.8(d)(1)(ii) New - Section 225.8(e)(1)(ii); Old - Section 225.8(d)(1)(iii) New - Section 225.8(e)(1)(iii); Old Section 225.8(d)(3) New - Section 225.8(e)(3); Old - Section 225.8(d)(3)(i)-(vi) New - Section 225.8(e)(3)(i)-(vii);
Old - Section 225.8(d)(4) New - Section 225.8(e)(4); Old - Sections 225.8(e)(3)(i); New - Section 225.8(f)(3)(i);
Old - Sections 225.8(f)(1), (2), and (3) New Sections - 225.8(g)(1), (2), and (3); Old - Section 225.8(f)(5) New
Section - 225.8(g)(6).

6

distributions involving incremental issuances of instruments that would qualify for inclusion in
the numerator of regulatory capital ratios (i.e., common equity tier 1, additional tier 1, and tier
2 capital). As mentioned in the preamble, the Board believes that removing the requirement
would reduce unnecessary efforts by a bank holding company to submit requests for distributions
outside of the capital plan that are associated with issuances of regulatory capital.
Section 225.8(g)(3)(iii)(A) Net distribution limitation exceptions. To the extent that the Board
or the appropriate Reserve Bank indicates in writing its non-objection pursuant to section
225.8(g)(5), following a request for non-objection from the bank holding company that includes
all of the information required to be submitted under section 225.8(g)(4).
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(e)(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(e)(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(e)(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(e)(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(e)(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(f)(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(g)(1) - In certain circumstances, large BHCs will be required to obtain
prior approval from the Federal Reserve before making capital distributions.
Section 225.8(g)(6) – 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
On July 1, 2014, a notice of proposed rulemaking was published in the Federal Register
(79 FR 37420) requesting comment on the proposed amendments to the capital plan and stress
test rules. The comment period expired on August 11, 2014. The Federal Reserve received 18
comments on the proposed amendments, however, none specifically addressed the PRA analysis.
One commenter, however, did express general concerns regarding their ability to provide
supporting documentation, due to third party legal and physical impediments, required by section
225.8(e)(3)(vi). In response to this comment, the Federal Reserve adjusted its PRA burden

7

estimate associated with this requirement. Details addressing the comments are included in the
final rule published October 27, 2014 (79 FR 64026), implementing the revisions largely as
proposed.
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.
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). 12
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 current total annual burden for the recordkeeping and reporting requirements of this
information collection is estimated to be 687,464 hours, as shown in the table below. The
Federal Reserve estimates that with the final amendments the total annual burden would decrease
by 2,308 hours to 685,156 hours.
The final rule contains requirements subject to the PRA. The collection of information
revised by this final rule is found in section 225.8 of Regulation Y (12 CFR part 225). Section
225.8(e)(3)(vi) requires a bank holding company to be capable of providing to the Board its loss,
revenue, and expense estimation models used by the bank holding company for stress scenario
analysis, including supporting documentation regarding each model’s development and
validation status. This information is needed by supervisors in order to properly assess a bank
holding company’s capital adequacy and capital planning processes. In this regard, the
12
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.

8

information helps facilitate cross-firm comparisons of bank holding companies’ loss, revenue,
and expense estimation models and their approaches to model validation. The Federal Reserve
estimates that, on average, respondents would take an additional 5 hours to comply with the
requirements in section 225.8(e)(3)(vi).
Section 225.8(g)(1) removes prior approval and prior notice requirements for
distributions involving incremental issuances of instruments that would qualify for inclusion in
the numerator of regulatory capital ratios (i.e., common equity tier 1, additional tier 1, and tier 2
capital). As mentioned in the final rule, the Federal Reserve believes that removing the
requirement would reduce unnecessary efforts by a bank holding company to submit requests for
distributions outside of the capital plan that are associated with issuances of regulatory capital.
The Federal Reserve estimates that respondent burden associated with section 225.8(g)(1) would
be reduced by approximately 50 percent.
Section 225.8(g)(3)(iii)(A)—Net distribution limitation exceptions—To the extent that
the Board or the appropriate Reserve Bank indicates in writing its non-objection pursuant to
section 225.8(g)(5), following a request for non-objection from the bank holding company that
includes all of the information required to be submitted under section 225.8(g)(4). The Board
estimates that, on average, respondents would take 16 hours to comply with the requirement in
section 225.8(g)(3)(iii)(A).
The current total cost to the public for these recordkeeping and reporting requirements is
estimated to be $34,991,918 and with the amendments would decrease to $34,874,440. These
recordkeeping and reporting requirements represent 4.29 percent of total Federal Reserve System
paperwork burden. 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 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
2013, www.bls.gov/news.release/ocwage.nr0.htm Occupations are defined using the BLS Occupational
Classification System, www.bls.gov/soc/

9

Number
of
respondents 14

Estimated
annual
frequency

Estimated
average
hours
per response

§225.8(d)(1)(i) Recordkeeping

52

1

11,920

§225.8(d)(1)(ii) Reporting

52

1

80

4,160

§225.8(d)(1)(iii) Recordkeeping

52

1

100

5,200

§225.8(d)(3)(i)-(vi) Reporting

52

1

1,000

52,000

§225.8(d)(4) Reporting

10

1

100

1,000

§225.8(e)(3)(i) Reporting

2

1

16

32

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

52

1

100

5,200

§225.8(f)(5) Reporting

2

1

16

32

Current

Estimated
annual
burden hours

§225.8(d)(1)
Annual capital planning
619,840

§225.8(d)(3), Data collections

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

687,464

Total

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 $550 million in total assets)
www.sba.gov/contractingopportunities/officials/size/table/index.html.

10

Number
of
respondents 15

Estimated
annual
frequency

Estimated
average
hours
per response

§225.8(e)(1)(i) Recordkeeping

52

1

11,920

§225.8(e)(1)(ii) Reporting

52

1

80

4,160

§225.8(e)(1)(iii) Recordkeeping

52

1

100

5,200

§225.8(e)(3)(i)-(vii) Reporting

52

1

1,005

52,260

§225.8(e)(4) Reporting

10

1

100

1,000

2

1

16

32

§225.8(g)(1), (3), & (4) Reporting

26

1

100

2,600

§225.8(g)(3)(iii)(A) Exceptions

2

1

16

32

§225.8(g)(6) Reporting

2

1

16

32

Proposed

Estimated
annual
burden
hours

§225.8(e)(1)
Annual capital planning
619,840

§225.8(e)(3), Data collections

§225.8(f), Review of capital
plans by the Federal Reserve
§225.8(f)(3)(i) Reporting
§225.8(g), Prior approval
request requirements

Total

685,156

Change

-2,308

15

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 $550 million in total assets)
www.sba.gov/contractingopportunities/officials/size/table/index.html.

11

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.

12