FRY14A_FRY14Q_FRY14M_20170117_omb

Supporting Statement for the
Capital Assessments and Stress Testing
(FR Y-14A/Q/M; OMB No. 7100-0341)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated
authority from the Office of Management and Budget (OMB), proposes to extend for three years,
with revision, the Capital Assessments and Stress Testing (FR Y-14A/Q/M; OMB No. 71000341) information collection applicable to bank holding companies (BHCs) with total
consolidated assets of $50 billion or more and U.S. intermediate holding companies (IHCs)
established by foreign banking organizations under 12 CFR 252.1531. This information
collection is composed of the following three reports:




The semi-annual FR Y-14A collects quantitative projections of balance sheet, income,
losses, and capital across a range of macroeconomic scenarios and qualitative information
on methodologies used to develop internal projections of capital across scenarios.2
The quarterly FR Y-14Q collects granular data on various asset classes, including loans,
securities, and trading assets, and pre-provision net revenue (PPNR) for the reporting
period.
The monthly FR Y-14M comprises three retail portfolio- and loan-level collections, and
one detailed address matching collection to supplement two of the portfolio and loanlevel collections.

Both the FR Y-14Q and the FR Y-14M are used to support supervisory stress test models
and for continuous monitoring efforts.
The Board proposes revising general FR Y-14 requirements and several schedules of the
FR Y-14A/Q/M reports. The revisions would be effective with the FR Y-14 reports as of
December 31, 2016, or December 31, 2017, as noted below. For reports as of December 31,
2017, the proposed changes include applying the attestation requirement to U.S. IHCs that are
part of the Large Institution Supervision Coordinating Committee (LISCC) framework (LISCC
U.S. IHCs)3. For reports as of December 31, 2016, the Board proposes formalizing the
requirement for BHCs and IHCs electing to undertake planned capital adjustments or
incremental capital distribution requests to provide updated submissions of the FR Y-14A
Schedule A (Summary - Capital) and Schedule C (Regulatory Capital Instruments, RCI)
reflecting these adjustments (as detailed below). To facilitate this collection, the Board proposes
adding additional items to the FR Y-14A Schedule C (RCI). Finally, the Board proposes to
update the FR Y-14A, Schedule A.1.d. (Summary - Capital) to collect items related to the
supplementary leverage ratio (SLR), remove and add sub-schedules to the FR Y-14A Schedule E
1

On June 1, 2016, the Board published a final notice in the Federal Register (81 FR 35016) requiring intermediate
holding companies of foreign banking organizations to file certain regulatory reports and comply with the
information collection requirements associated with regulatory capital requirements.
2
BHCs that must resubmit their capital plan generally also must provide a revised FR Y-14A in connection with
their resubmission.
3
Further information regarding the LISCC designation is available on the Board’s public website
http://www.federalreserve.gov/bankinforeg/large-institution-supervision.htm.

(Operational Risk) to align with applicable guidance, add one item to Schedule A.5 (Summary Counterparty), and modify items on the FR Y-14A/Q/M reports to address inconsistencies across
schedules and ensure the collection of accurate information. These changes are explained in
further detail in the schedule specific sections below.
The FR Y-14A Schedule A.1.d. (Summary - Capital) would be revised for December 31,
2016, to (1) add certain items used to calculate the SLR in alignment with the Board’s extension
of the initial application of the SLR requirement in the capital plan rule,4 (2) modify two items,
and (3) remove one item. In addition, one item to capture Other Counterparty Losses would be
added to Schedule A.5 (Summary - Counterparty) effective December 31, 2016. Finally,
Schedule E (Operational Risk) would be revised for December 31, 2016, to (1) remove subschedule E.1, BHC Operational Risk Historical Capital, (2) add two new sub-schedules: E.2,
Material Risk Identification and E.3, Operational Risk Scenarios, and (3) update outdated
methodologies and references.
The FR Y-14Q (quarterly collection) would be revised for December 31, 2016, to add a
new column to Schedule B (Securities) to collect the price of the security as a percent of par to
enhance supervisory modeling.
Finally, the FR Y-14M (monthly collection) would be revised for December 31, 2016, to
modify the definition of Gross Charge-Off Amount on Schedule D (Credit Cards) in order to
ensure proper reporting across firms.
These data are, or will be, used to assess the capital adequacy of BHCs and U.S. IHCs
using forward-looking projections of revenue and losses to support supervisory stress test models
and continuous monitoring efforts, as well as to inform the Board’s operational decision-making
as it continues to implement the Dodd-Frank Wall Street Reform and Consumer Protection Act.
The total current annual burden for the FR Y-14A/Q/M is estimated to be 928,387 hours
and with the changes proposed in this memorandum is estimated to increase by 23,477 hours to
951,864 hours.
Background and Justification
Prior to the financial crisis that emerged in 2007, many firms made significant
distributions of capital without due consideration of the effects that a prolonged economic
downturn could have on their capital adequacy and their ability to remain credit intermediaries
during times of economic and financial stress. In 2009, the Board conducted the Supervisory
Capital Assessment Program (SCAP), a “stress test” focused on identifying whether large,
domestic BHCs had capital sufficient to weather a more-adverse-than-anticipated economic
environment while maintaining their capacity to lend. In 2011, the Board continued its
supervisory evaluation of the resiliency and capital adequacy processes through the
Comprehensive Capital Analysis and Review (CCAR) 2011. Through the CCAR 2011, the
Board developed a deeper understanding of the processes by which large BHCs form and

4

See 12 CFR 225.8(c)(3), 12 CFR 252.53(b)(3).

2

monitor their assessments and expectations for maintaining adequate capital and the
appropriateness of their planned actions and policies for returning capital to shareholders.
The capital plan rule requires BHCs with total consolidated assets of $50 billion or more
to submit capital plans to the Federal Reserve annually and to require such firms to request prior
approval from the Federal Reserve under certain circumstances before making a capital
distribution.5 In connection with submissions of capital plans to the Federal Reserve, firms are
required, pursuant to 12 CFR 225.8(d)(3), to provide certain data to the Federal Reserve.
On December 1, 2011, the Federal Reserve published a final rule (Capital Plan rule) in
the Federal Register (76 FR 74631) to require BHCs with total consolidated assets of $50 billion
or more to submit capital plans to the Federal Reserve annually and to require such firms to
request prior approval from the Federal Reserve under certain circumstances before making a
capital distribution. In connection with submissions of capital plans to the Federal Reserve,
firms are required, pursuant to 12 CFR 225.8(d)(3), to provide certain data to the Federal
Reserve.
The Federal Reserve’s stress test rules establish stress testing requirements for certain
BHCs, state member banks, savings and loan holding companies, and foreign banking
organizations.6 The final rules implement sections 165(i)(1) and (i)(2) of the Dodd-Frank Wall
Street Reform and Consumer Protection Act. Section 165(i)(1) of the Dodd-Frank Act requires
the Board to conduct an annual stress test of each covered company7 to evaluate whether the
covered company has sufficient capital, on a total consolidated basis, to absorb losses as a result
of adverse economic conditions (supervisory stress tests). Section 165(i)(2) requires the Board
to issue regulations that require covered companies to conduct stress tests semi-annually and
require financial companies with total consolidated assets of more than $10 billion that are not
covered companies and for which the Federal Reserve is the primary federal financial regulatory
agency to conduct stress tests on an annual basis (collectively, company-run stress tests).
On June 1, 2016, the Board published a final notice in the Federal Register (81 FR
35016) requiring intermediate holding companies of foreign banking organizations to file certain
regulatory reports and comply with the information collection requirements associated with
regulatory capital requirements, including the FR Y-14 reports. IHCs will begin filing the FR Y14 reports with submissions as of December 31, 2016.
Description of Information Collection
The data collected through the FR Y-14A/Q/M schedules provide the Board with the
additional information to ensure that large BHCs have strong, firm‐wide risk measurement and
management processes supporting their internal assessments of capital adequacy and that their
capital resources are sufficient given their business focus, activities, and resulting risk exposures.
The annual CCAR exercise also is complemented by other Board supervisory efforts aimed at
enhancing the continued viability of large firms, including continuous monitoring of firms’
5
6
7

See 12 CFR 225.8.
See 12 CFR 252, subparts B, E, F, and O.
See 12 U.S.C. 5365(a).

3

planning and management of liquidity and funding resources and regular assessments of credit,
market and operational risks, and associated risk management practices. Information gathered in
this data collection is also used in the supervision and regulation of these financial institutions.
In order to fully evaluate the data submissions, the Board may conduct follow-up discussions
with or request responses to follow up questions from respondents, as needed.
Respondent firms are currently required to complete and submit up to 18 filings each
year: two semi-annual FR Y-14A filings, four quarterly FR Y-14Q filings, and 12 monthly
FR Y-14M filings.8 Compliance with the information collection is mandatory.
Current FR Y-14A (semi-annual collection)
The semi-annual collection of quantitative projected regulatory capital ratios across
various macroeconomic scenarios comprises seven primary schedules (Summary, Scenario,
Regulatory Capital Instruments, Regulatory Capital Transitions, Operational Risk, Business Plan
Changes, and Retail Repurchase Exposures schedules), each with multiple supporting tables.9
The FR Y‐14A schedules collect current financial information as well as quarterly and
annual projections under the Board’s supervisory scenarios. The information includes balances
for balance sheet and off‐balance‐sheet positions, income statement and PPNR, and estimates of
losses across various portfolios.
Firms are also required to submit qualitative information supporting their projections,
including descriptions of the methodologies used to develop the internal projections of capital
across scenarios and other analyses that support their comprehensive capital plans.
Current FR Y-14Q (quarterly collection)
The FR Y‐14Q schedules (Retail, Securities, Regulatory Capital Instruments, Regulatory
Capital Transitions, Operational Risk, Trading, PPNR, Wholesale, Mortgage Servicing Rights,
Fair Value Option/Held for Sale, Supplemental, Counterparty, and Balances schedules) collect
firm‐specific data on positions and exposures that are used as input to supervisory stress test
models, to monitor actual versus forecast information on a quarterly basis, and to conduct
ongoing supervision.
Current FR Y-14M (monthly collection)
The FR Y-14M includes two portfolio and loan-level collections for First Lien data and
Home Equity data and an account and portfolio-level collection for Domestic Credit Card data.
In order to match senior and junior lien residential mortgages on the same collateral, the Address
Matching schedule gathers additional information on the residential mortgage loans reported in
the First Lien and Home Equity schedules.
8

The most current reporting templates for the FR Y-14A/Q/M are available at
www.federalreserve.gov/apps/reportforms/default.aspx.
9
The “mid-cycle” FR Y-14A is limited to three schedules: the Summary, Macro Scenario, and Retail Repurchase
Exposure schedules. The Retail Repurchase Exposure schedule is collected on the FR Y-14Q submission date.

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Proposed Revision to the FR Y-14A/Q/M
Proposed Attestation Requirement for LISCC U.S. IHC respondents
The Board proposes to add an attestation requirement to the FR Y-14A/Q/M reports for
U.S. IHC respondents that are part of the LISCC framework. Foreign banking organizations
with non-branch assets of $50 billion or more were required to form a U.S. IHC by July 1, 2016.
The IHCs established by Barclays, Credit Suisse, UBS, and Deutsche Bank are expected to be
the LISCC U.S. IHC respondents. This requirement would be consistent with the existing
attestation requirement applicable to U.S. domiciled BHCs that are part of the LISCC framework
(LISCC respondents).
On September 16, 2015, the Board published a notice in the Federal Register proposing
to require a Chief Financial Officer (CFO) level attestation for LISCC respondents.10 On
January 21, 2016, the Board finalized the attestation requirement for LISCC respondents, with a
phased-in implementation approach beginning with the reports as of December 31, 2016.11 The
Board proposes applying an attestation requirement to LISCC U.S. IHCs following a similar
phased-in implementation approach, effective beginning December 31, 2017, and fully phased in
by December 31, 2018. The proposed effective date would provide LISCC U.S. IHCs with time
to develop the appropriate internal processes and procedures to fully implement the proposed
attestation following the creation of their U.S. IHCs in July 2016, and the first filing of FR Y-14
reports as of December 31, 2016.
As discussed in the final Federal Register notice adopting the attestation requirement for
domestic LISCC respondents, the attestation requirement was designed to help ensure that the
data reported to the Board were reliable and accurately reflect the firm’s exposures.12 These data
are integral to the Board’s assessment of the safety and soundness of a banking organization, as
the Board uses financial data reported by a banking organization to assess whether the banking
organization has the capital necessary to absorb losses under stress.
The Board has initially applied the attestation requirement to only LISCC respondents
given the added resources required to implement the attestation.13 Similarly, the Board would
propose to apply the attestation requirement only to those U.S. IHCs that will be part of the
LISCC framework, as the resources needed to ensure accurate data are appropriate in light of the
risks that the U.S. operations of these firms pose to the financial system.
Under the proposal the attestation would include three parts. First, for projected data
reported on the FR Y-14A/Q and for actual data reported on the FR Y-14A/Q/M reports,
10

See 80 FR 55621 (September 16, 2015).
See 81 FR 3412 (January 21, 2016).
12
See 80 FR 55621 (September 16, 2015).
13
As noted in the preamble to the Federal Register notice (80 FR 55621, September 16, 2015), the attestation
requirement may require respondents to enhance certain systems and processes in order to meet the attestation
requirement, such as enhancing information technology infrastructure and adding or modifying internal control
frameworks and data governance committees to include accountability and escalation processes, as well as to
increase the frequency of audits of internal controls over the FR Y-14A/Q/M reports.
11

5

collectively, the CFO (or equivalent senior officer14) of a LISCC U.S. IHC would be required to
attest that the reports have been prepared in conformance with the instructions issued by the
Board.15 Second, for actual data, the CFO (or equivalent senior officer) of a LISCC U.S. IHC
would be required to attest that senior management is responsible for the internal controls over
the reporting of these data, and that the data reported are materially correct to the best of senior
management’s knowledge. The CFO would also be required to attest that the controls are
effective and include those practices necessary to provide reasonable assurance as to the
accuracy of these data. The CFO would be required to attest that the controls are audited
annually by internal audit or compliance staff, and are assessed regularly by management of the
named institution. For the third part, the CFO would be required to agree to report material
weaknesses in these internal controls and any material errors or omissions in the data submitted
to the Board promptly as they are identified. Both domestic LISCC firms and LISCC U.S. IHCs
subject to the attestation requirement should have a policy in place for determining materiality in
the context of attesting to material correctness and internal controls.16
As indicated above, the Board proposes that the attestation for LISCC U.S. IHCs would
follow a phased-in implementation approach beginning December 31, 2017. The attestation
submitted with reports as of December 31, 2017, would relate to the effectiveness of internal
controls over submissions for the as of date and would not include an attestation to submissions
through the year. Beginning with the monthly FR Y-14M report submitted on January 31, 2018,
and for each monthly, quarterly, and semi-annual FR Y-14 report submitted thereafter,
respondents would attest to conformance with the FR Y-14 instructions and to the material
correctness of data to the best of the respondent’s knowledge, and agree to report material
weaknesses and any material errors in the data as they are identified. The full attestation
requirement, including attestation to the effectiveness of internal controls throughout the
previous year, would be effective starting with the reports submitted as of December 31, 2018.
The attestation pages submitted by LISCC U.S. IHCs would be the same as those used by LISCC
BHCs.
Proposed Requirement to Submit Adjusted Capital Action Data
The Board proposes to require additional submissions of certain FR Y-14 schedules to
collect information on adjustments to planned capital actions and incremental capital distribution
from BHCs and IHCs that have elected to make such adjustments, effective with the reports as of
December 31, 2016. An ad-hoc process is currently used to collect this information, which is
“An equivalent senior officer” refers to a senior officer who functions as the CFO but carries a different title.
The instructions define the scope and content of items that must be reported, and specify that the reports must be
filed in accordance with U.S. generally accepted accounting principles (GAAP). The instructions further state that
respondents should maintain financial records in such a manner and scope to ensure the FR Y-14A/Q/M reports
reflect a fair presentation of the HCs’ financial condition and assessment of performance under stressed scenarios.
16
The materiality policy should include a robust analysis of all relevant quantitative and qualitative considerations,
including, but not limited to, the size and effect of the omission or misstatement on firms’ projected regulatory
capital ratios in stressed scenarios. Qualitative factors may result in a conclusion that a small change in regulatory
capital ratios is considered material. Those circumstances might include the repeat occurrence of errors and
omissions, the proximity of a firm’s regulatory capital ratios to minimum capital requirements, and whether errors
and omissions could change a knowledgeable person’s view of the adequacy of internal controls over the capital
adequacy process.
14
15

6

necessary if, for example, firms intend to exercise the option to adjust their planned capital
distributions based on the preliminary results of the supervisory quantitative assessment in
CCAR.17 Given the time-sensitive nature of the collection, current manual collection processes,
and ongoing need for firms to submit the data, formalizing the requirement as part of the FR Y14 would reduce operational risk, establish a regular, standard submission process, and account
for the burden of providing these data. Additionally, it would formalize a standard process for
firms to employ in submitting information regarding requests to make incremental capital
distributions above those included in their capital plans.
The proposed requirement includes two components. First, for adjustments to planned
capital actions, firms would be required to submit an updated FR Y-14A Schedule A.1.d
(Summary, Capital - CCAR) for the BHC Baseline, Supervisory Adverse, and Supervisory
Severely Adverse scenarios and an updated FR Y-14A Schedule C (RCI). These submissions
would be collected subsequent to the firms’ annual FR Y-14 submission in a timeframe
communicated by the Board of at least 14 calendar days in advance of the submission. Second,
for incremental capital action requests (i.e. requests for additional capital distributions in the
period between CCAR exercises), firms would be required to resubmit the FR Y-14A Schedule
C (RCI). The incremental capital action requests would be submitted at the time a firm seeks
approval for or notifies the Board of its intention to make additional capital distributions.
To allow for the collection of the information necessary to understand these adjustments,
the Board proposes adding certain items to the FR Y-14A Schedule C (RCI) including: (1) cash
dividends declared on preferred stock, (2) cash dividends declared on common stock, (3)
common shares outstanding (Millions), and (4) common dividends per share ($).
Proposed Revision to the FR Y-14A
The proposed revisions to the FR Y-14A consist of adding data items in accordance with
the finalized modifications to the capital plan and stress test rules (Regulation Y and YY),18 and
modifying existing data items to provide more precise information. The limited changes to
Schedule A.1.d (Capital) are expected to require relatively minimal additional burden on firms
and in the case of the SLR items are required in accordance with mandatory capital planning
requirements. The proposed changes to Schedule E (Operational Risk) would balance the
increase in burden due to the addition and modification of items to align with expectations
outlined in SR Letter 15-18 with the reduction in burden from the elimination of the outdated and
unnecessary data collection.
Schedule A (Summary)
Schedule A.1.d (Capital) In accordance with the finalized amendments to the capital
plan and stress test rules, a firm will be required to estimate its SLR for the DFAST/CCAR
planning horizon beginning January 1, 2018.19 To facilitate the mandatory reporting of this
17

The CCAR Instructions provide further information regarding adjustments a BHC may make to its planned
capital distributions http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20160128a1.pdf.
18
See 80 FR 75419 (December 2, 2015).
19
See 12 CFR 225.8(c)(3), 12 CFR 252.53(b)(3).

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information, it is necessary to add SLR items to the FR Y-14A report. The Board proposes
adding two items to the FR Y-14A Summary Schedule (A.1.d, Capital) report as of December
31, 2016: Supplementary Leverage Ratio Exposure (SLR Exposure) and Supplementary
Leverage Ratio (the SLR). The SLR would be a derived field.
In addition, to collect more precise information regarding deferred tax assets (DTAs), the
Board proposes modifying one existing item on the FR Y-14A Schedule A.1.d (Summary Capital) as of December 31, 2016. The Board proposes changing existing item 111 on Schedule
A.1.d. (Summary - Capital), “Deferred tax assets arising from temporary differences that could
not be realized through net operating loss carrybacks, net of DTLs, but before related valuation
allowances”, to “Deferred tax assets arising from temporary differences, net of DTLs.” A firm in
a net deferred tax liability (DTL) position would report this item as a negative number. This
modification would provide more specific information about the components of the “DTAs
arising from temporary differences that could not be realized through net operating loss
carrybacks, net of related valuation allowances and net of DTLs” subject to the common equity
tier 1 capital deduction threshold.
The Board also proposes removing Schedule HC-M, Memoranda item 107, “Total
number of bank holding company common shares outstanding”, from the FR Y-14A Schedule A
(Summary - Capital) with the reports as of December 31, 2016, to reduce burden on firms. This
item provides minimal additional value and therefore, is no longer needed.
Finally, to reduce the risk of inconsistencies in reporting and align with other regulatory
reports, certain definitions in the instructions for the FR Y-14A Schedule A.1.d (Summary Capital) would be clarified or streamlined to reference comparable items on the FR Y-9C.
Schedule A.5 (Counterparty) The Board proposes adding the item “Other counterparty
losses” to Schedule A.5 (Summary - Counterparty), similar to the item that was removed with
the proposal finalized October 1, 2014.20 The Board provides guidance to respondents to include
risks not considered in the supervisory scenarios and the addition of this item will allow these
risks to be captured. This change is proposed to be effective with the reports as of December 31,
2016.
Schedule E (Operational Risk)
The Board proposes several changes to the FR Y-14A Schedule E (Operational Risk) for
the reports as of December 31, 2016, to align with the guidance and expectations contained in
recent supervisory letters, notably SR Letter 15-18. SR Letter 15-18 outlines expectations
regarding a firm’s risk management infrastructure and strength of associated processes.
In order to capture the information surrounding the risk management infrastructure and
processes as outlined in SR Letter 15-18, the Board proposes adding two sub-schedules to the
FR Y-14A Schedule E (Operational Risk) and modifying the supporting documentation
requirements for this schedule effective with the reports as of December 31, 2016. First, new
20

See 79 FR 59264 (October 1, 2014).

8

sub-schedule E.2, Material Risk Identification, would collect information on a firm’s material
operational risks included in loss projections based on their risk management framework, a
component of risk management emphasized in SR Letter 15-18. Second, new sub-schedule E.3,
Operational Risk Scenarios, would collect a firm’s operational risk scenarios included in the
BHC Baseline and BHC Stress projections, a fundamental element of the framework. Finally,
the Board recommends updating the requirements for supporting documentation and modifying
certain terminology, definitions, and references to align with SR Letter 15-18.
Certain information related to the previous methodology are no longer necessary to
collect given the aforementioned change in guidance, resulting in the proposed removal of these
items and updating of associated terminology. Sub-schedule E.1 (BHC Operational Risk
Historical Capital) would be removed as this schedule pertains to Advanced Measurement
Approaches (AMA) methodology and these data are no longer necessary. This change in
methodology also results in the removal of two associated columns on the FR Y-14A Schedule
A.6 (Operational Risk Scenario Inputs and Projections): Type of Data and Brief Description.
References to previous methodology would be updated, including changing the name of a
column on the FR Y-14A Schedule A.6 (Operational Risk Scenario Inputs and Projections) from
Units of Measure to Risk Segment. These changes would also be effective with the report as of
December 31, 2016.
Proposed Revisions to the FR Y-14Q
The proposed revision to the FR Y-14Q consists of adding an item to more accurately
collect information that is currently derived. This proposed change would allow for more
accurate and consistent reporting of information with minimal anticipated burden on
respondents.
Schedule B (Securities)
For reports as of December 31, 2016, the Board proposes adding a new column to the
FR Y-14Q Schedule B.1 (Securities 1 - Main Schedule) to collect the price of the security to
more accurately collect price information and thereby enhance supervisory modeling. Because
this information is believed to be readily available, the Board estimates this revision would
impose minimal additional burden while improving the ability to use these data.
Proposed Revision to the FR Y-14M
Schedule D (Credit Card)
For reports as of December 31, 2016, the Board proposes modifying the definition of
Item 62, Gross Charge-off Amount – Current month to reflect the intended method of reporting
the item and in response to industry comments. The definition would be modified to indicate
that all gross charge-offs must be reported regardless of whether they are from purchased or
impaired loans by eliminating the reference to allowance for loan and lease losses (ALLL).

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Respondent Panel
The respondent panel consists of any top-tier BHC or IHC, that has $50 billion or more in
total consolidated assets, as determined based on (1) the average of the firm’s total consolidated
assets in the four most recent quarters as reported quarterly on the firm’s Consolidated Financial
Statements for Holding Companies (FR Y-9C) (OMB No. 7100-0128) or (2) the average of the
firm’s total consolidated assets in the most recent consecutive quarters as reported quarterly on
the firm’s FR Y-9Cs, if the firm has not filed an FR Y-9C for each of the most recent four
quarters. Reporting is required as of the first day of the quarter immediately following the
quarter in which it meets this asset threshold, unless otherwise directed by the Board.
Time Schedule for Information Collection and Publication
The following tables outline by schedule the as of dates for the data and the due date for
the current submissions to the Board by reporting frequency (annually, semiannually, quarterly,
or monthly).
Schedules and SubSub-schedules

Summary,
Macro Scenario




Retail Repurchase
Exposures

Regulatory Capital
Instruments,
Regulatory Capital
Transitions,
Operational Risk, and
Business Plan Changes
schedules
CCAR Market Shock
exercise
Summary schedule
 Trading Risk
 Counterparty

Submission Date
to Federal Reserve

Data as of date





Semiannual Schedules
Data as of
 Data are due April 5th of the
December 31st.
following year.
Data as of June
 Data are due October 5th of
30th.
the same year.
Data are due seven calendar days
after the FR Y-9C reporting
Data as of
schedule (52 calendar days after
December 31st.
the calendar quarter-end for
Data as of June
December and 47 calendar days
30th.
after the calendar quarter-end for
June).
Annual Schedules

Data as of
December 31st.

Data as of a specified
date in the first quarter.
As of date would be

10



Data are due April 5th of the
following year.



Data are due April 5th

communicated by
Federal Reserve21

Schedules

Submission Date
to Federal Reserve

Data as of date
FR Y-14Q (Quarterly Filings)

Securities
PPNR
Retail
Wholesale
Operational
MSR Valuation
Supplemental
Retail FVO/HFS
Regulatory Capital
Transitions
Regulatory Capital
Instruments
Balances

Data as of each
calendar quarter end.

Due to the CCAR
Market Shock exercise,
the as of date for the
fourth quarter would be
communicated in the
subsequent quarter.

Trading Schedule
Counterparty Schedule

Data are due seven calendar days
after the FR Y-9C reporting schedule
(52 calendar days after the calendar
quarter-end for December and 47
calendar days after the calendar
quarter-end for March, June, and
September).

Data are due seven calendar days
after the FR Y-9C reporting
schedule.

Fourth quarter – Trading and
Counterparty (Regular/unstressed
submission):
For all other quarters,
52 calendar days after the notification
the as of date would be
date (notifying respondents of the as
the last day of the
of date) or March 15, whichever
quarter, except for
comes earlier. Unless the Board
firms that are required
requires the data to be provided
to re-submit their
over a different weekly period,
capital plan.
firms may provide these data as of
the most recent date that corresponds
For these firms, the as
to their weekly internal risk reporting
of date for the quarter
cycle as long as it falls before the as
preceding the quarter in
of date.
which they are required
to re-submit a capital

21

As outlined in Section 252.54 (Annual Stress Tests) of Regulation YY (12 CFR 252), the as of date will be
between January 1st and March 1st of that calendar year and will be communicated to the firms by March 1st of
the calendar year. Firms are permitted to submit the CCR schedule and the Trading and CCR sub-schedules of the
Summary schedule as of another recent reporting date prior to the supplied as of date as appropriate.

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Fourth quarter – Counterparty
(CCAR/stressed submission):
April 5.
In addition, for firms that are
required to re-submit a capital plan,
the due date for the quarter preceding the quarter in which the firms
are required to re-submit a capital
plan would be the later of (1) the
normal due date or (2) the date that
the re-submitted capital plan is due,
including any extensions.
FR Y-14M (Monthly Filings)
Data as of the last
Data are due by the 30th calendar day
business day of each
of the following month.
calendar month.
plan would be
communicated to the
firms during the
subsequent quarter

All schedules

As proposed and mentioned above, the Board would notify companies at least 14
calendar days in advance of the date on which it expects companies to submit any adjusted
capital actions. For the incremental capital action submission, a firm would submit the
adjustment at the time the firm seeks approval for the additional capital distributions (see 12
CFR 225.8(g)) or notifies the Board of its intention to make additional capital distributions under
the de minimis exception (see 12 CFR 225.8(g)(2)).
Legal Status
The Board’s Legal Division has determined that this mandatory information collection is
authorized by section 165 of the Dodd-Frank Act, which requires the Board to ensure that certain
firms and nonbank financial companies supervised by the Board are subject to enhanced riskbased and leverage standards in order to mitigate risks to the financial stability of the United
States (12 U.S.C. § 5365). Additionally, section 5 of the Bank Holding Company Act authorizes
the Board to issue regulations and conduct information collections with regard to the supervision
of firms (12 U.S.C. § 1844).
With regard to the CFO-level attestation requirement, which is intended to improve
accountability and accuracy and heighten requirements for internal control, the Board provided
sufficient description and justification to require such attestation from respondents, consistent
with the aforementioned statutory authorities.
As these data are collected as part of the supervisory process, they are subject to
confidential treatment under exemption 8 of the Freedom of Information Act (FOIA) (5 U.S.C. §
552(b)(8)). In addition, commercial and financial information contained in these information
collections may be exempt from disclosure under exemption 4 of FOIA (5 U.S.C. § 552(b)(4)), if
disclosure would likely have the effect of (1) impairing the government’s ability to obtain the
necessary information in the future or (2) causing substantial harm to the competitive position of
the respondent. Such exemptions would be made on a case-by-case basis.

12

Consultation Outside the Agency
On July 28, 2016, the Board published a notice in the Federal Register (81 FR 49653)
requesting public comment for 60 days on the extension, with revision, of the FR Y-14A/Q/M
reports. The comment period for this notice expired on September 26, 2016. The Board
received three comment letters addressing the proposed changes: one from the Financial Services
Roundtable, one from the Clearing House, and one from the Federal Advisory Council.
Commenters requested clarification of the instructions, forms, or general requirements for
proposed items, in particular the operational risk modifications to the FR Y-14A, Schedule E.2
and E.3. The Board also received general comments regarding (1) the frequency of changes and
stability of the collection, (2) timing of release of technical instructions, and (3) estimates of
reporting burden.
No comments were received specifically related to the modifications to the FR Y-14A
Schedule A.5, FR Y-14Q Schedule B, or FR Y-14M Schedule D. Therefore the Federal Reserve
will proceed with the aforementioned changes effective December 31, 2016. Furthermore, no
comments were received on the proposed application of attestation to LISCC US IHCs. The
Federal Reserve will apply the attestation requirement to LISCC US IHCs effective December
31, 2017. The Federal Reserve will adopt the remaining reporting requirements as proposed,
with revisions in response to comment, as outlined below.
The following section includes a detailed discussion of aspects of the proposed FR Y-14
collection for which the Federal Reserve received substantive comments and an evaluation of,
and responses to the comments received. A detailed discussion of these comments is also
included in the final Federal Register notice for the FR Y-14 revisions. Where appropriate,
responses to these comments and technical matters are also addressed in the revised FR Y14A/Q/M reporting forms and instructions.
Detailed Discussion of Public Comments
A. General Comments
In general, commenters expressed concerns with the timing of implementing changes and
the frequency of changes to the FR Y-14 series of reports. Two commenters indicated that
additional time before the implementation of changes would be needed to allow for the
development of internal processes and procedures, and integration of changes, and to materially
improve the FR Y-14 data collection. Specifically, consistent with previously submitted
comments, the Financial Services Roundtable requested a minimum of six months between the
finalization of all reporting and technical requirements and the effective date, and a reduction in
the frequency of changes. Both the Financial Services Roundtable and the Clearing House
requested earlier publication of technical instructions and the ability to address clarifying
questions before adoption of any final rule or the effective date of the changes. Both
organizations expressed their willingness to continue to work with the Federal Reserve on
addressing these issues. Finally, the Federal Advisory Council encouraged stability in the
reporting requirements as continued iterations and modifications necessitate the utilization of
manual processes to meet filing deadlines.

13

As previously indicated, the Federal Reserve recognizes the challenges with
implementing changes in a timely and controlled manner, especially when the changes are
finalized close to the effective date.22 The Federal Reserve continues to weigh the need to
collect additional information or benefits of enhancing the collection in light of the proposed
effective date with the objective of providing as much time as is feasible in advance of
implementation. The Federal Reserve has engaged the industry in ongoing dialogue regarding
several of the specific recommendations contained in these letters and continues to assess these
recommendations. In response to these comments, the Federal Reserve will revisit these
discussions and consider additional ways to further engage the industry throughout the process in
order to improve the transparency and clarity surrounding proposed changes.
In regards to the proposed changes, the Federal Reserve notes that the changes related to
collecting components of SLR on the FR Y-14A Schedule A (Summary – Capital) align with
related changes to the rule and allow for the incorporation of regulatory elements into the stress
test as required. The inclusion of the requirement to submit certain FR Y-14 schedules to collect
information on adjustments to planned capital actions and incremental capital distribution from
firms that have elected to make such adjustments formalizes the process and format by which
firms undertaking such actions would be providing the information. It is expected, therefore,
that firms could leverage existing processes and controls for collecting and reporting this
information given that regardless of the collection method, this information would be provided.
Similarly, the information collected on proposed FR Y-14A, Schedules E.2 and E.3, would
otherwise be provided as part of the supporting documentation submitted by a firm subject to SR
Letter 15-18. Furthermore, the Federal Reserve has engaged the industry regarding the
expectations outlined in SR Letter 15-18, and the requirements remain largely the same as
proposed. Therefore, the Federal Reserve will not delay the implementation of these proposed
changes given they are consistent with recent supervisory guidance or would replace collections
of the same or similar information through other methods or processes.
Other changes with a December 31, 2016, implementation date are clarifying in nature,
streamline the instructions, address industry feedback, or remove information. These include the
remaining changes to the FR Y-14A, Schedule A.1.d (Summary – Capital), the changes to the
FR Y-14A, Schedule A.6 (Ops Risk) which align with updated methodology, the elimination of
the FR Y-14A, Schedule E.1, and the definitional change to the FR Y-14M, Schedule D (Credit
Cards). Given these changes will reduce burden and address reporting issues to alleviate
confusion and inconsistent reporting for the CCAR cycle and do not involve the collection of
new information, these changes will be implemented with a December 31, 2016, effective date.
While the collection of other losses on the FR Y-14A, Schedule A.5 (Summary –
Counterparty) results in the collection of additional information for which internal processes and
controls need to be developed, the Federal Reserve reiterates that this information was previously
collected. Draft forms and instructions were provided with the publication of the initial notice
and remain the same as proposed. No comments were received specifically regarding this
change, therefore the Federal Reserve will implement this change as proposed.

22

See, e.g., 79 FR 59264 (October 1, 2014).

14

Finally, the addition of the column for “Price” on the FR Y-14Q, Schedule B (Securities)
addresses inconsistencies in reporting identified in prior reporting periods. As noted in the
proposal, the data currently collected on the FR Y-14 leaves data gaps that can result in outdated
information and ultimately reduced accuracy of modeling. While the Federal Reserve
understands that the collection of new information close to the effective date results in process
challenges, delaying the collection of price information could result in the need for
resubmissions in the short term. The Federal Reserve indicated in the initial notice that they
understood these data to be readily available on the as of date, and no comments were received
specifically indicating challenges with reporting the information necessary for this proposed
change. Therefore, the Federal Reserve will implement this change as proposed.
In response to the Federal Reserve’s solicitation for feedback regarding burden associated
with the FR Y-14A/Q/M, the Financial Services Roundtable noted that dialogue regarding the
estimates of burden associated with the FR Y-14 collection with Federal Reserve staff is
ongoing. The Federal Reserve regularly reviews burden estimates and discussions with industry
groups regarding FR Y-14 burden are ongoing.
B. Schedule Specific Comments
FR Y-14A
Schedule A.1.d. (Capital)
The Federal Reserve received two requests for clarification related to the proposed
modifications requiring firms to estimate the SLR for the projection horizon beginning
January 1, 2018, for baseline and stress scenarios, in accordance with revisions to the capital plan
and stress test rules, and report these ratios on Schedule A.1.d. The requests related to the
application of this requirement to both BHCs and IHCs.
Specifically, one industry group commented that the inclusion of this information on the
FR Y-14A, Schedule A (Summary) suggests that the Federal Reserve will require institutions’
projections to remain above the regulatory minimum on a post-stress basis beginning
January 1, 2018, and going forward in order to quantitatively pass the Comprehensive Capital
Analysis and Review (CCAR), implying an accelerated effective date from January 1, 2018, to
December 31, 2016. Accordingly, the commenter asked the Federal Reserve to clarify that
information regarding the SLR would be collected for informational purposes only on the FR Y14A Summary Schedule as of December 31, 2016, and that banks would not be expected to meet
the post stress supplementary minimum for purposes of the 2017 CCAR. The commenter also
asked the Federal Reserve to confirm this would be informational and on a best efforts basis for
IHCs of FBOs and that they would not be expected to meet leverage or supplementary leverage
post stress minima for CCAR 2017.
Bank holding companies (BHCs) must maintain capital above each minimum regulatory
capital ratio on a pro forma basis throughout the planning horizon. The capital plan rule defines
minimum regulatory capital ratio to include the SLR.23 Under the 2015 amendment to the capital
23

See 12 CFR 225.8(d)(8).

15

plan rule, the Board delayed the incorporation of the SLR requirement in the capital plan and
stress test rules for one year, until 2017.24 Accordingly, for the 2017 capital plan and stress test
cycle, BHCs subject to the SLR will be required to maintain capital above a minimum three (3)
percent SLR on a pro forma basis for quarters of the planning horizon beginning
January 1, 2018, which corresponds with the fifth projection quarter of the CCAR 2017 exercise.
Under the capital plan rule and stress test rules, all regulatory capital ratios are calculated
using the definitions of capital, risk-weighted assets, and total assets that are in effect during a
particular quarter of a planning horizon.25 For example, the Federal Reserve required firms to
meet minimum common equity tier 1 ratio requirements, which came into effect on
January 1, 2015, beginning in the fourth projection quarter of CCAR 2014.
Similarly, both the leverage and supplementary leverage requirements become effective
for the intermediate holding companies (IHCs) of foreign banking organizations (FBOs) on
January 1, 2018. In CCAR 2017, beginning with quarters that correspond to dates after
January 1, 2018 (i.e. the fifth quarter of the CCAR 2017 planning horizon), each U.S. IHC will
be required to calculate the tier 1 leverage ratio and the SLR and demonstrate in the IHC’s own
baseline and stress projections that it can maintain capital above a minimum four (4) percent tier
1 leverage ratio and three (3) percent SLR. Notably, however, for an IHC designated by an FBO
that was not a BHC previously subject to CCAR, the IHC will not be subject to the supervisory
stress test or public objection to its 2017 capital plan. For CCAR 2018, all IHCs will be subject
to all aspects of CCAR, including the supervisory stress test, public disclosure of results, and
public notice of the Federal Reserve’s action on each IHCs capital plan. In CCAR 2018,
leverage requirements will be in effect for all quarters of the planning horizon.
Given the alignment with the capital plan and stress testing rules as outlined above, the
modifications to the FR Y-14A, Schedule A.1.d (Summary – Capital), will be implemented as
proposed for reports submitted as of December 31, 2016. No further comments were received
regarding the other proposed changes to the FR Y-14A, Schedule A.1.d (Summary - Capital) and
these changes will also be implemented as proposed.
Schedule A.6 (BHC Operational Risk Scenario Inputs and Projections)
Two commenters requested clarification regarding the change of the column heading
from “Unit of Measure” to “Risk Segment” in the FR Y-14A, Schedule A.6 and associated
instructions. First, one commenter asked whether there was an expectation that respondents use
classifications other than Basel event types in the reporting of the risk segment. The Federal
Reserve clarifies that large and complex firms should use risk segments that best describe the
risks to which they are exposed. Classifications other than the current Units of Measure are
acceptable and in some cases may be preferable to more clearly link the methodologies used to
measure those risks for both day-to-day business operations and to estimate post-stress capital
needs.

24
25

See 80 FR 75419, 75421 (December 2, 2015), 12 CFR 225.8(c)(3).
See Comprehensive Capital Analysis and Review 2016 Summary Instructions (January 2016), p. 3.

16

Second, the other commenter inquired as to whether the change in heading would also
result in a change in the definition of the reported column. Specifically, the commenter asked
whether (1) the definition of Risk Segment to be used is the same definition for Risk Segment
contained in the prior instructions (i.e., “the BHC’s internal classification of operational risk into
granular risk categories used for risk management and operational risk loss projection
purposes”), (2) the prior definition of Unit of Measure should be applied (i.e., “the level at which
the BHC’s quantification model generates a separate distribution for estimating potential
operational losses”), or (3) an alternate definition of Risk Segment should be applied. The
Federal Reserve confirms that the definition of Risk Segment to be used is the same definition
for Risk Segment contained in the prior instructions and as indicated in the draft instructions
associated with this notice (i.e., “the BHC’s internal classification of operational risk into
granular risk categories used for risk management and operational risk loss projection
purposes”). Because this definition is already contained in the instructions, the change will be
implemented as proposed.
Schedule C (RCI)
Under the proposed revisions to the FR Y-14A, firms would be required to resubmit the
FR Y-14A, Schedule C for incremental capital action requests at the time a firm seeks approval
for or notifies the Federal Reserve of its intention to make additional capital distributions in the
period between CCAR exercises. While the commenter expressed support for the Federal
Reserve’s objective of formalizing a standard process for firms to submit information regarding
requests for additional capital distributions in the period between CCAR exercises, the
commenter requested that the Federal Reserve institute a threshold, below which firms would not
need to resubmit the FR Y-14A, Schedule C (RCI) as part of the request. The commenter
indicated that this would enable firms to make small incremental distributions without requiring
the internal processes and control structure otherwise needed to resubmit the template outside of
the annual CCAR process.
The Federal Reserve reiterates that firms may not exceed the distributions included in
their capital plan on a gross or net basis. As such, a firm seeking to make incremental capital
distributions must notify the Federal Reserve (in the case of a de minimis incremental
distribution) or request approval (in the case of incremental distributions that do not qualify for
the de minimis exception for well capitalized firms). In any case where a firm seeks to make
incremental distributions it is important that the Federal Reserve have up to date information on
the firm’s capital plan. As such, the Federal Reserve does not believe such a threshold is
appropriate and will implement the requirement as proposed.
Schedules E (Operational Risk)
Several of the changes proposed to the FR Y-14A, Schedule E (Operational Risk) were
consistent with the guidance and expectations contained in recent supervisory letters, notably
SR Letter 15-18. SR Letter 15-18 sets out the differences in expectations for U.S. bank holding
companies and intermediate holding companies of foreign banking organizations that are either
(1) subject to the Federal Reserve’s Large Institution Supervision Coordinating Committee
(LISCC) framework or (2) have total consolidated assets of $250 billion or more or consolidated

17

total on-balance sheet foreign exposure of $10 billion or more (Large and Complex firms). Two
commenters requested clarification as to whether the proposed changes to the FR Y-14A,
Schedule E were intended to apply to all BHCs and IHCs, or only to those institutions subject to
SR Letter 15-18. The Federal Reserve confirms that the additional sub-schedules proposed for
the FR Y-14A Schedule E would apply only to BHCs and IHCs subject to SR Letter 15-18, in
alignment with the guidance outlined therein; however, notes that the elimination of Schedule
E.1 would apply for all firms.
The Federal Reserve proposed adding a new sub-schedule, Schedule E.2 Material Risk
Identification, to capture material operational risks included in a firm’s projections. Two
commenters requested additional clarification on the information to be captured in this subschedule. One commenter requested guidance regarding the definition of “material” operational
risks, as the subjective application of materiality may lead to varying definitions across
organizations. The commenter also questioned at what point organizations not just include Basel
Loss Event Type I as their material operational risks and if additional guidance would be
provided on quantifying risks that do not have a one-to-one (1:1) match of risk to dollars (e.g.,
those implicitly captured in the estimates through historical losses experienced).
The Federal Reserve expects large and complex firms to maintain capital planning
processes that capture or otherwise consider the full range of material risks facing the firm. A
firm should identify how and where its material risks are accounted for within the capital
planning process. The Federal Reserve expects a firm to seek input from multiple stakeholders
across the organization (for example, senior management, finance and risk professionals, front
office and line-of-business leadership) in identifying its material risks. Materiality thresholds
should be established at multiple levels of the BHC and include (1) easily quantifiable risks and
(2) risks that are more difficult to quantify. The specifics of the risk identification process will
differ across firms given differences in organizational structure, business activities, and size and
complexity of operations. However, the risk identification process at all firms subject to this
guidance should be dynamic, inclusive, and comprehensive, and drive the firm’s capital
adequacy analysis. A firm should (1) evaluate material risks across the enterprise to ensure
comprehensive risk capture on an ongoing basis, (2) establish a formal risk identification process
and evaluate material risks at least quarterly, (3) actively monitor its material risks, and (4) use
identified material risks to inform key aspects of the firm’s capital planning, including the
development of stress scenarios, the assessment of the adequacy of post-stress capital levels, and
the appropriateness of potential capital actions in light of the firm’s capital objectives.
Regarding risks that do not have a 1:1 match of risk to dollars, firms should have
transparent and well-supported estimation approaches based on both quantitative analysis and
expert judgment, and should not rely on unstable or unintuitive correlations to project operational
losses. Scenario analysis should be a core component of the firm’s operational loss projection
approaches. Certain operational risks, particularly those most likely to give rise to large losses,
often may not have measureable relationships to the overall scenario conditions. In addition,
large operational loss events are often idiosyncratic, limiting the relevance of historical data.
The other commenter suggested that rather than create a new template to capture material
operational risks that are included in a firm’s risk projections, as well as those excluded from the

18

firms’ risk projections, the Federal Reserve continues to refer to the CCAR supporting
documentation for a discussion of operational risks provided that the supporting documentation
conforms with all Federal Reserve requirements. By collecting this information in a structured
way via the new FR Y-14 sub-schedule, the Federal Reserve expects to ensure a clear and
consistent reporting of material risks, including a transparent reconciliation of which risks are
included or excluded from the projections. The supporting documentation should, among other
things, provide a description of the process(es) employed to identify, select and/or exclude risks
from the reported projections.
Several comments were received regarding the draft forms and instructions associated
with the proposed FR Y-14A, Schedule E.2. First, commenters requested additional clarification
as to the Federal Reserve’s expectations with respect to the reporting of Material Risks in
Schedule E.2, particularly as to the intended definitions of “Risk Name”, “Risk Segment” and
“BHC Stress Projection Amount” in this schedule.
As indicated in the draft instructions and consistent with other instructions for this
schedule, the Federal Reserve does not intend to provide specific definition for these terms.
Each firm uses its unique methodology for each identified material risk as well as its risk
segment. Risk segmentation and resulting material risks vary based on business mix, risk
profile, and risk drivers. Therefore the Federal Reserve does not expect a standard taxonomy for
reporting purposes. Risk Name is the firm’s taxonomy for a given material risk. Risk Segment
is the firm’s chosen taxonomy for risk segmentation/risk categorization.
Second, in order to better conform the items as proposed in the draft forms and consistent
with the item description, the commenter requested the addition of “Operational” before
“Risk(s)” to the (1) title of the schedule, (2) header of the first column in the schedule, and (3)
descriptions below the aforementioned header on Schedule E.2. Consistent with the request
regarding the insertion of the word “Operational” into the appropriate locations on Schedule E.2,
the commenter also suggested the addition of the words “Operational Risk” to each of the names
of the columns in Schedule E.3, as well as to the lines for “percentage of the loss estimates” and
“total number of scenarios.” The forms will be updated as suggested.
In regards to Schedule E.3, the commenter requested the addition of the word “9-Qtr
Projection” after “BHC Baseline” and “BHC Stress” to clarify that the total nine quarter
projections are the information being sought on this schedule. To further clarify the column
titles in schedule E.3, “Nine-Quarter Loss Projection” will be added after “BHC Base Line” and
after “BHC Stress.”
Finally, one commenter requested additional clarity surrounding expectations for the
information to be reported under the column “Methodology for applying scenario results” on the
proposed FR Y-14A, Schedule E.3. The Federal Reserve clarifies that the intent of this column
is for the firm to note the name of methodology used to quantify losses using the Scenario
approach. For example, quantitative model, historical averages, estimate based on expert
judgment, etc.

19

The changes to the FR Y-14A, Schedule E (Operational Risk) will be implemented as of
December 31, 2016, with the revisions noted above.
FR Y-14Q
Schedule H.1 (Corporate Loan)
In addition to the comments specific to the proposed changes contained in the initial
notice, the Federal Reserve also received two comments regarding the reporting of syndicated
pipelines and disposition activity on Schedule H.1 (Wholesale – Corporate), to which no changes
were proposed. The commenter inquired as to when the Federal Reserve would provide draft
and/or final technical instructions for the third quarter 2016 reporting requirements on
Syndicated Finance Pipeline Reporting and Disposition Activity. Technical instructions for the
third quarter were posted to the public website on October 17, 2016.
The commenter also questioned whether the Federal Reserve would provide an interim
exemption on having to provide responses to edit check exceptions for these new reporting
requirements similar to what was done for the 2Q 2016 Fronting Exposure edit checks, which did
not require responses until 4Q 2016. The Federal Reserve emphasizes the value of edit checks
for both firms and the Federal Reserve in ensuring data quality, particularly for newly reported
items. The final notice adopting these changes delayed the implementation of these requirements
an additional quarter (to be effective as of September 30, 2016), in order to allow firms
additional time to prepare for the reporting of these exposures.26 Therefore, exemptions to edit
checks responses on these reporting requirements are not planned at this time.
On December 22, 2016, the Board published a final notice in the Federal Register (81 FR
93917).
Estimate of Respondent Burden
The current total annual burden for the annual, quarterly, and monthly reporting
requirements of this information collection is estimated to be 928,387 hours and with the
proposed revisions would increase by 23,477 hours, for a total of 951,864 hours, including
18,720 hours of automation burden. This increase is primarily due to the addition of the
attestation requirement for LISCC U.S. IHCs, modifications to Schedule E (Operational Risk),
and the addition of the requirement to submit certain FR Y-14 schedules identifying adjustments
to planned capital actions and incremental capital distributions. These reporting requirements
represent 7.6 percent of total Federal Reserve System paperwork burden.
FR Y-14A Burden
The current total annual burden hours for the FR Y-14A is estimated to be 83,499 hours
and with the proposed revisions would increase by 1,241 hours for a total of 84,740 hours. The
increase is primarily due to the addition of sub-schedules to Schedule E (Operational Risk) and
the addition of the requirement to submit certain FR Y-14 schedules identifying adjustments to
26

See 81 FR 3412 (January 21, 2016).

20

planned capital actions and incremental capital distributions. For burden purposes, the Board
estimates approximately five adjusted or incremental capital plans may be submitted in a year;
however, the number of respondents will vary based on the firms electing to make an adjustment.
FR Y-14Q Burden
The current total annual burden hours for the FR Y-14Q is estimated to be 223,708 hours
and with the proposed revisions would increase by 156 hours for a total of 223,864 hours. The
additional burden to collect the new column on Schedule B (Securities) is expected to be
minimal and other changes are clarifying in nature.
FR Y-14M Burden
The current total annual burden hours for the FR Y-14M is estimated to be 579,420
hours. The proposed revisions are clarifying in nature and burden is expected to remain the
same.
Implementation and On-Going Automation Burden
In an effort to more accurately reflect the burden imposed on the BHCs for reporting the
FR Y-14 data, the Board has included estimates for annual on-going automation burden (for
existing respondents) and implementation for new respondents. The Board estimates the burden
for each existing respondent BHC that would update their systems in order to complete the
FR Y-14 submissions would vary across BHCs. On average it would take approximately 480
hours (on-going maintenance) to update systems for submitting the data, for a total of 18,720
hours. Additionally, the Board estimates that on average it would take approximately 7,200
hours for each new respondent to implement the requirements of the FR Y-14. Since there are
no new respondents for the current proposal, this results in 0 hours.

21

Current FR Y-14A
Summary
Macro scenario
Operational risk
Regulatory Capital
Transitions
Regulatory Capital
Instruments
Business Plan Changes
Retail Repurchase Exposures

Estimated
average hours
per response

Annual
frequency

39
39
39
39

2
2
1
1

987
31
12
23

76,986
2,418
468
897

39

1

20

780

39
39

1
2

10
20

390
1,560

Current FR Y-14A Total
Current FR Y-14Q
Retail
Securities
PPNR
Wholesale
Trading
Regulatory Capital
Transitions
Regulatory Capital
Instruments
Operational Risk
MSR Valuation
Supplemental
Retail FVO/HFS
Counterparty
Balances

Estimated
annual burden
hours

Number of
respondents27

83,499

39
39
39
39
6
39

4
4
4
4
4
4

16
13
711
152
1,926
23

2,496
2,028
110,916
23,712
46,224
3,588

39

4

52

8,112

39
18
39
28
6
39

4
4
4
4
4
4

50
24
4
16
508
16

7,800
1,728
624
1,792
12,192
2,496

Current FR Y-14Q Total

223,708

27

Of the respondents required to comply with the FR Y-14A/Q/M information collection, 0 are estimated to be
small entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total
assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-smallbusiness-size-standards.

22

Current FR Y-14M
Retail Risk
1st lien mortgage

37

12

515

228,660

Home equity

32

12

515

197,760

Credit card

25

12

510

153,000

Current FR Y-14M Total
Implementation and
On-going Automation
Implementation
On-going revisions

579,420

0
39

1
1

7,200
480

Implementation and
On-going Automation Total
Attestation
Implementation
On-going

0
18,720
18,720

0
9

1
1

Attestation Total

4,800
2,560

0
23,040
23,040

Current Collection Total

928,387

23

Number of
Annual
respondents28 frequency
Proposed FR Y-14A
Summary
Macro scenario
Operational risk
Regulatory Capital Transitions
Regulatory Capital Instruments
Business Plan Changes
Retail Repurchase Exposures
Adjusted Capital Plan
Submission

39
39
39
39
39
39
39
5

2
2
1
1
1
1
2
1

Estimated
average hours
per response
993
31
18
23
21
10
20
100

Proposed FR Y-14A Total
Proposed FR Y-14Q
Retail
Securities
PPNR
Wholesale
Trading
Regulatory Capital Transitions
Regulatory Capital Instruments
Operational Risk
MSR Valuation
Supplemental
Retail FVO/HFS
Counterparty
Balances

Estimated
annual burden
hours
77,454
2,418
702
897
819
390
1,560
500

84,740

39
39
39
39
6
39
39
39
18
39
28
6
39

4
4
4
4
4
4
4
4
4
4
4
4
4

Proposed FR Y-14Q Total

16
14
711
152
1,926
23
52
50
24
4
16
508
16

2,496
2,184
110,916
23,712
46,224
3,588
8,112
7,800
1,728
624
1,792
12,192
2,496
223,864

28

Of the respondents required to comply with the FR Y-14A/Q/M information collection, 0 are estimated to be
small entities as defined by the Small Business Administration (i.e., entities with less than $550 million in total
assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-smallbusiness-size-standards.

24

Proposed FR Y-14M
Retail Risk
1st lien mortgage

37

12

515

228,660

Home equity
Credit card

32
25

12
12

515
510

197,760
153,000

Proposed FR Y-14M Total
Proposed Implementation and
On-going Automation
Implementation
On-going revisions

579,420

0
39

1
1

7,200
480

Proposed Automation Total
Attestation
Implementation
On-going

0
18,720
18,720

3
12

1
1

Attestation Total

4,800
2,560

14,400
30,720
45,120

Proposed Collection total

951,864

Total Change

23,477

The current annual cost to the public of these reports is estimated to be $49,343,769 and would
increase to $50,591,572 with the proposed changes.29
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.

29

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/.

25

Estimate of Cost to the Federal Reserve System
The current cost to the Federal Reserve System is estimated to be $2,739,104, the onetime cost is estimated to be $74,300, and the proposed cost is estimated to be $2,779,104.

26