FFIEC009_FFIEC009a_20160720_omb

Supporting Statement for the
Country Exposure Report (FFIEC 009; OMB No. 7100-0035) and
Country Exposure Information Report (FFIEC 009a; OMB No. 7100-0035)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
mandatory Federal Financial Institutions Examination Council (FFIEC) Country Exposure
Report (FFIEC 009; OMB No. 7100-0035) and the Country Exposure Information Report
(FFIEC 009a; OMB No. 7100-0035). The reporting and disclosure provisions of the
International Lending Supervision Act of 1983 (the Act) authorize the Board to require these
reports. The FFIEC mandates both reports and the Federal Deposit Insurance Corporation
(FDIC) and the Office of the Comptroller of the Currency (OCC) collect identical reports from
institutions under their supervision. The FDIC and the OCC have also submitted a similar
request for OMB review for banks under their supervision.
U.S. commercial banks, savings associations, and bank holding companies (BHCs) that
meet certain criteria file quarterly the Country Exposure Report (FFIEC 009) with the Board, the
FDIC, and the OCC (the agencies) and provide information on international claims of U.S.
banks, savings associations, holding companies, and savings and loan holding companies
(SLHCs) that is used for supervisory and analytical purposes. The information is used to
monitor country exposure of banks to determine the degree of country risk and transfer risk in
their portfolios and the possible impact on U.S. banks of adverse developments in particular
countries. The Country Exposure Information Report (FFIEC 009a) is a supplement to the
FFIEC 009 and provides publicly available information on material foreign country exposures
(all exposures to a country in excess of 1 percent of total assets or 20 percent of capital,
whichever is less) of U.S. banks, savings associations and holding companies that file the
FFIEC 009 report. As part of the Country Exposure Information Report, reporting institutions
must also furnish a list of countries in which they have lending exposures between 0.75 percent
and 1 percent of total assets or between 15 and 20 percent of total capital, whichever is less.
The agencies propose to revise these collections effective September 30, 2016, to (1)
have institutions provide their Legal Entity Identifier (LEI) on both reporting forms, only if they
already have one and (2) add Intermediate Holding Companies (IHCs) to the Board’s respondent
panel and effective March, 31, 2018, to (3) add General Electric Capital Corporation (GECC) to
the Board’s respondent panel. The current annual burden for the FFIEC 009 and the FFIEC 009a
is estimated to be 21,632 and would increase 2,740 hours to 24,372 hours.
Background and Justification
The banking agencies use the FFIEC 009 report in carrying out their supervisory and
regulatory responsibilities to collect information on overseas lending activities of U.S. banks to
customers in individual countries. The information is used to monitor and analyze banks’
country exposure in order to determine the possible impact on individual banks and on the entire
U.S. banking system of adverse developments in particular countries. It is a basic source of

information on the geographic distribution of bank claims that is provided to other U.S.
government agencies and to the Bank for International Settlements (BIS). The information
collected in the report is not available from any other source.
The FFIEC 009 report originated in 1977 in response to concerns about the lack of
information on banks’ country risk exposures, in view of the substantial growth in international
lending by U.S. banks in the mid-1970s. In 1984 the FFIEC increased the frequency from
semiannual to quarterly, implementing reporting requirements of the International Lending
Supervision Act, to obtain more frequent and timely data on changes in the composition and
maturity of banks’ loan portfolios subject to transfer risk. The FFIEC revised the report in 1985
to provide greater sector detail on third-country guarantors for country redistribution of
guaranteed claims and to obtain information on trade finance.
The FFIEC 009a report was implemented in 1984 as a supplement to the FFIEC 009
report to provide public disclosure of information regarding material country risk exposure in
accordance with the Act. Section 907 of the Act provides that the federal banking agencies shall
require and publicly disclose certain reports from banking institutions with foreign country
exposure. The FFIEC 009a is available to the public and requires respondents to report all
exposures to a country in excess of 1 percent of the total assets or 20 percent of capital of the
reporting institution, whichever is less. In addition, each institution furnishes a list of the
countries in which exposures are between 0.75 percent and 1 percent of total assets or between
15 and 20 percent of capital, whichever is less. Data are reported net of adjustments for transfers
of exposure, for example through guarantees. The FFIEC initially established this reporting
basis, which is consistent with the approach taken by the Securities and Exchange Commission,
following consultation with bankers.
Effective with the March 31, 1997, report date, the agencies incorporated the following
revisions to the FFIEC 009: added a new schedule to collect information on the respondent’s
country exposure resulting from revaluation gains on foreign exchange and derivative contracts
held in the trading account; added a new item, Assets Held for Trading (new column 20); deleted
an item, Amount of Claims that Represent Guarantees Issued by the U.S. Government and its
Agencies (old column 13); combined three columns, Commercial Letters of Credit (old
column 20), Standby Letters of Credit and Risk Participations Purchased (old column 21), and
All Other Commitments (old column 22), into one column Commitments (new column 15);
redefined the column Trade Financing to contain all items reported in column 9, Trade Financing
and column 20, Commercial Letters of Credit and renumbered as column 21; combined columns
for the breakdown of time remaining to maturity for total claims on foreign residents for Over
One Year to Two Years and Over Two Years to Five Years into a single column for Over One
Year to Five Years; and revised the instructions to require all claims consisting of available-forsale securities to be reported at amortized cost rather than at fair value. In addition, minor
instructional clarifications and a revision of the reporting form to reflect country code changes
were changed. The revisions to the FFIEC 009a report included the addition of a new column to
collect the Amount of Cross-border Claims Outstanding from Derivative Products after
Mandated Adjustments for Transfer of Exposure and Amount of Net Local Country claims from
Derivative Products (new column 3).

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Effective with the March 31, 2003, report date, the agencies required electronic
submission of all FFIEC 009 and FFIEC 009a reports.
Effective with the March 31, 2006, report date, the agencies revised the FFIEC 009 in
order to harmonize U.S. data with data on cross-border exposures collected by other countries
and disseminated by the BIS as their “consolidated banking statistics.” The revisions provided
additional information about U.S. banks’ exposure to country risk, transfer risk, and foreignexchange risk. The revisions collected additional detail on foreign-office claims of U.S. banks
on local residents, including sector breakdowns and a currency split; a split between
commitments and guarantees plus credit derivatives; additional detail on foreign-office
liabilities; and trade finance after adjustments for collateral and guarantees. The definition of the
public (i.e., government) sector was brought into agreement with the definition used in the Call
Report that banks file quarterly. The instructions were changed to collect data on exposures
arising from all derivatives contracts, not just those held in the trading account. There were no
changes to the FFIEC 009a, although the change in the definition of the public sector on the
FFIEC 009 changed the amounts reported in columns 6 and 7 on the FFIEC 009a by
corresponding amounts. The instructions to the FFIEC 009a reporting form were changed to
reflect column changes on the FFIEC 009.
Effective with the December 31, 2013, report date for current filers and the
March 31, 2014, report date for SLHC filers, the agencies proposed revisions that assisted in
ensuring consistency of reporting across institutions for a number of important components of
foreign country exposure and allowed for improved analysis of the aggregate exposure of U.S.
banks to foreign creditors. The proposed changes included (1) increasing the number of
counterparty categories, (2) adding additional information on the type of claim being reported,
(3) providing details on a limited number of risk mitigants to help provide perspective to
currently reported gross exposure numbers, (4) adding more detailed reporting of credit
derivatives, (5) eliminating voluntary data items for net foreign office claims on local residents,
(6) adding the United States as a country row to allow reconciliation between a reporting
institution’s FFIEC 009 report and its Consolidated Financial Statements for Holding Companies
(FR Y-9C; OMB No. 7100-0128) or Consolidated Reports of Condition and Income (FFIEC 031
and FFIEC 041; OMB No. 7100-0036) (Call Report), as appropriate, (7) expanding the entities
that must report to include savings and loan holding companies, (8) delaying the year-end due
date by five days, and (9) updating the list of countries included on the report to be consistent
with Treasury International Capital (TIC)1 reports. In addition, the proposed changes included
modifying the FFIEC 009a reporting requirement for exposures to individual countries.
Description of Information Collection
The FFIEC 009 is filed as of the last business day of each quarter by any state member
bank, savings association or BHC that (a) has at least one of the following: (1) a branch in a
foreign country; (2) a subsidiary in a foreign country; (3) an Edge or agreement subsidiary;
1

See TIC Form BC (OMB No. 1505-0017), TIC Form BL-1 (OMB No. 1505-0019), TIC Form BL-2 (OMB No.
1505-0018), TIC Form BQ-1 (OMB No. 1505-0016), TIC Form BQ-2 (OMB No. 1505-0020), TIC Form BQ-3
(OMB No. 1505-0189), TIC Form CQ-1 and CQ-2 (OMB No. 1505-0024), TIC Form D (OMB No. 1505-0199),
and TIC Form S (OMB No. 1505-0001).

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(4) an International Banking Facility (IBF) subsidiary; or (5) a branch in Puerto Rico or any U.S.
territory or possession; and (b) has, on a fully consolidated basis, total outstanding claims of at
least $30 million on residents of foreign countries.
The FFIEC 009 collects information, by country2, on three schedules. Schedule 1
collects information on the respondent’s country exposure excluding claims resulting from the
positive fair value of derivatives contracts, which are reported in Schedule 2. Specifically,
Schedule 1 collects information on the respondent’s cross-border claims on residents of foreign
countries and their foreign-office claims on local residents. These claims are reported on an
immediate-counterparty basis and on an ultimate-risk basis (i.e., after adjustments for guarantees
and collateral), and inward and outward risk transfers are also reported. The sector (bank,
public, and other) of the borrower is broken out, as are claims with a remaining maturity up to
and including one year. Cross-border and foreign-office commitments to and guarantees
(including credit derivatives) on foreigners are reported on an ultimate-risk basis. Schedule 1.a
collects information on the respondent’s foreign-office liabilities in non-local currency and in
local currency by country of the foreign office and total liabilities booked at the respondent’s
foreign offices by country of the liability-holder. Schedule 1.a also includes memorandum items
for net liabilities due from own related offices in other countries, assets held for trading, and
trade finance. Schedule 2 collects information on the respondent’s cross-border claims on
foreigners that result from the positive fair value of all the respondent’s derivative contracts.
This information includes the sector (bank, public, and other) of the obligor and optional
information on the positive and negative fair value of derivatives contracts of foreign offices visà-vis local residents. In addition, claims on bank branches that are not formally guaranteed by
the head offices of the branches are identified by country of the location of the branch.
The FFIEC 009a is a quarterly supplement to the FFIEC 009 and implements public
disclosure provisions of the Act. Respondents provide detail on all exposures to a country in
excess of 1 percent of the total assets or 20 percent of capital of the reporting institution,
whichever is less. Each FFIEC 009a respondent also furnishes a list of the countries in which
exposures are between 0.75 percent and 1 percent of total assets or between 15 and 20 percent of
capital, whichever is less. In addition, Section 910(a)(1) of the Act authorizes the federal
banking agencies to interpret and define the terms used in the Act. Thus, the agencies have the
right to order a banking institution to file the FFIEC 009 and FFIEC 009a quarterly, even if the
specified reporting criteria are not met, if the agencies deem the institution’s country exposure to
be material in relation to its capital and assets.
Proposed Revisions to the FFIEC 009 and FFIEC 009a
Legal Entity Identifier
The LEI is a 20-digit alpha-numeric code that uniquely identifies entities that engage in
financial transactions. The recent financial crisis spurred the development of a Global LEI
2

Country names and country codes used for reporting FFIEC 009 data are based on the geographical classification
published by the Department of the Treasury. The reporting form may be modified, from time to time, to reflect
country consolidations or countries that have recently gained independence.

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System (GLEIS). Internationally, regulators and market participants have recognized the
importance of the LEI as a key improvement in financial data systems. The Group of Twenty
(G-20) nations directed the Financial Stability Board to lead the coordination of international
regulatory work and deliver concrete recommendations on the GLEIS by mid-2012, which in
turn were endorsed by the G-20 later that same year. In January 2013, the LEI Regulatory
Oversight Committee (ROC), including participation by regulators from around the world, was
established to oversee the GLEIS on an interim basis. With the establishment of the full Global
LEI Foundation in 2014, the ROC continues to review and develop broad policy standards for
LEIs. The Board, the FDIC, and the OCC are all members of the ROC.
The LEI system is designed to facilitate several financial stability objectives, including
the provision of higher quality and more accurate financial data. In the United States, the
Financial Stability Oversight Council (FSOC) has recommended that regulators and market
participants continue to work together to improve the quality and comprehensiveness of financial
data both nationally and globally. In this regard, the FSOC also has recommended that its
member agencies promote the use of the LEI in reporting requirements and rulemakings, where
appropriate.3
Effective beginning October 31, 2014, the Board started requiring holding companies to
provide their LEI on the cover pages of the FR Y-6, FR Y-7, and FR Y-10 reports4 only if a
holding company already has an LEI. Thus, if a reporting holding company does not have an
LEI, it is not required to obtain one for purposes of these Board reports. Additionally, effective
for December 2015, the Board expanded the collection of the LEI to all holding company
subsidiary banking and nonbanking legal entities reportable on certain schedules of the FR Y-10
and in one section of the FR Y-6 and FR Y-7 if an LEI has already been issued for the reportable
entity. With respect to the FFIEC 009 and FFIEC 009a, the agencies are proposing to have
reporting institutions provide their LEI on the cover page of each report beginning
September 30, 2016, only if an institution already has an LEI. As with the Board reports, an
institution that does not have an LEI would not be required to obtain one for purposes of
reporting it on the FFIEC 009 and FFIEC 009a.
Intermediate Holding Companies
On December 14, 2012, the Board invited comment on a notice of proposed rulemaking
(proposed Regulation YY)5 that would have required a Foreign Banking Organization (FBO)
with $50 billion in non-branch assets to establish a U.S. IHC, imposed enhanced prudential
standards on the IHC, and required the IHC to submit any reporting forms in the same manner
and to the same extent as a bank holding company. On February 18, 2014, the Board adopted a
final rule implementing enhanced prudential standards for FBOs (Regulation YY),6 with certain
revisions in response to comments. The Board indicated in the preamble to Regulation YY that
3

Financial Stability Oversight Council 2015 Annual Report, page 14, at
http://www.treasury.gov/initiatives/fsoc/studies-reports/Documents/2015%20FSOC%20Annual%20Report.pdf.
4
Annual Report of Holding Companies (FR Y-6), Annual Report of Foreign Banking Organizations (FR Y-7); and
Report of Changes in Organizational Structure (FR Y-10) (OMB No. 7100-0297).
5
See 77 FR 76628 (December 28, 2012).
6
See 79 FR 17240 (March 27, 2014).

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it would address the reporting requirements for IHCs at a later date. Based on the background
provided above, the agencies propose to add IHCs to the FFIEC 009 and FFIEC 009a panel of
Board respondents beginning September 30, 2016.
General Electric Capital Corporation
In July 2013, the FSOC determined that material financial distress at General Electric
Capital Corporation (GECC) could pose a threat to U.S. financial stability and that GECC should
be subject to supervision by the Board and to enhanced prudential standards. The FSOC’s basis
for its final determination noted GECC’s interconnections with financial intermediaries through
its financing activities and its funding model as well as a large portfolio of on-balance-sheet
assets comparable to those of the largest U.S. bank holding companies. In particular, FSOC
noted GECC’s significant use of wholesale funding, including short-term wholesale funding
(commercial paper), and use of long-term debt and securitization debt, which could expose other
large financial institutions to GECC’s distress, among other reasons for its determination. GECC
became subject to the Board’s supervision immediately upon the FSOC’s final determination.
As a result GECC is required to submit the FFIEC 009 and the FFIEC 009a in the same manner
as a bank holding company beginning March 31, 2018.
Time Schedule for Information Collection
The time schedule for filing both reports is quarterly as of the end of March, June,
September, and December. Each report should be submitted within 45 days of the reporting date
for the March, June, and September quarters, and within 50 days of the reporting date for the
December quarter. The Board is responsible for collecting, editing, and compiling the data on
behalf of all three banking agencies.
The agencies publishes aggregate data from the FFIEC 009 in the quarterly E.16
statistical release, Country Exposure Lending Survey. In addition, the agencies makes aggregate
data available to the BIS. The BIS then publishes statistical data on consolidated bank claims on
foreign borrowers as its “consolidated international banking statistics” on its website and in its
Quarterly Review. Data from the FFIEC 009a are published on the FFIEC website.
Legal Status
The Board’s Legal Division has determined that section 11(a) of the Federal Reserve Act
(12 U.S.C. § 248(a)(1) and (2)), section 5(c) of the Bank Holding Company Act of 1956
(12 U.S.C. § 1844(c)), section 907 of the International Lending Supervision Act of 1983
(12 U.S.C. § 3906) authorize the Board to collect the FFIEC 009 and the FFIEC 009a from banks
and bank holding companies. The Board is authorized to collect information from SLHCs
pursuant to section 10(b) of the Home Owners’ Loan Act (12 U.S.C. § 1467a(b)(2)(A)) and from
IHCs pursuant to section 165(a) of the Dodd-Frank Act (12 U.S.C. § 5365(a)). The obligation to
respond is mandatory. Individual respondent data reported on the FFIEC 009 is entitled to
confidential treatment are exempt from disclosure under the Freedom of Information Act (FOIA)
(5 U.S.C. § 552(b)(4) and (b)(8)). The information collected on the FFIEC 009a is publicly
available, and accordingly, would not be exempt from disclosure under FOIA

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Consultation Outside the Agency and Discussion of Public Comments
On April 14, 2016, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (81 FR 22163) requesting public comment for 60 days on the
extension, with revision, of the FFIEC 009 and FFIEC 009a (adding LEI and IHCs). The
comment period for this notice expired on June 13, 2016. The agencies received one comment
letter from a bankers’ association indicating that it would submit data on certain divergent
reporting practices observed across institutions with respect to the FFIEC 009 and FFIEC 009a in
a supplemental submission. The letter did not comment on either of the changes proposed by the
agencies. Any forthcoming data and comments on the FFIEC 009 and FFIEC 009a reporting
requirements from this association would be considered for possible inclusion in a separate
future notice of agency information collection activities. On July 20, 2016, the agencies
published a final notice in the Federal Register (81 FR 47237).
On December 3, 2014, the Board published a notice in the Federal Register
(79 FR 71768) requesting public comment for 60 days on the revision of the FFIEC 009 and
FFIEC 009a (adding GECC). The comment period for this notice expired on February 2, 2015.
The Board did not receive any comments. On July 24, 2015, the Board published a final notice
in the Federal Register (80 FR 44111).
Estimate of Respondent Burden
The current annual reporting burden for the FFIEC 009 and FFIEC 009a is estimated to
be 21,362 hours and would increase to 24,372 hours. The change in the number of respondents
reflects the addition of four IHCs and GECC to the Board’s respondent panel. These reporting
requirements represent less than 1 percent of the total Federal Reserve System paperwork
burden.
Number of
respondents7

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

40
28

4
4

131
6

20,960
672
21,632

45
33

4
4

131
6

Total

23,580
792
24,372

Change

2,740

Current
FFIEC 009
FFIEC 009a
Total
Proposed
FFIEC 009
FFIEC 009a

7

Of these respondents, none are considered a small entity as defined by the Small Business Administration (i.e.,
entities with $550 million or less in total assets) www.sba.gov/contracting/getting-started-contractor/make-sure-youmeet-sba-size-standards/table-small-business-size-standards.

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The current total cost to the public is estimated to be $1,149,741 and with the proposed revisions
would increase to $1,295,372 for the FFIEC 009 and the FFIEC 009a.8
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The current annual cost to the Federal Reserve System for collecting and processing the
FFIEC 009 and FFIEC 009a is estimated to be $102,021.

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

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