FFIEC101_20170602_omb

Supporting Statement for the
Regulatory Capital Reporting for Institutions Subject to the
Advanced Capital Adequacy Framework
(FFIEC 101; OMB No. 7100-0319)
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) Regulatory Reporting
Requirements for Institutions Subject to the Advanced Capital Adequacy Framework
(FFIEC 101; OMB No. 7100-0319). These data are required for certain large or internationally
active state member banks, bank holding companies (BHCs), savings and loan holding
companies (SLHCs), intermediate holding companies (IHCs), and also for those institutions that
adopt the framework on a voluntary basis and are filed on a quarterly basis. The revisions to the
FFIEC 101 that are the subject of this request have been approved by the FFIEC, of which the
Board, the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of
the Currency (OCC) (the agencies) are members. The FDIC and the OCC have also submitted a
similar request for OMB review to request this information from banks under their supervision.
The Federal Deposit Insurance Act (FDI Act) and the International Lending Supervision
Act of 1983 (ILSA) require the agencies to have risk-based capital requirements and to ensure
that banks maintain adequate capital. The Board uses these data to assess and monitor the levels
and components of each reporting entity’s risk-based capital requirements and the adequacy of
the entity’s capital under the framework. These data also allow the Board to evaluate the
quantitative impact and competitive implications of the framework on individual respondents
and on the industry. The reporting schedules also assist banks in understanding expectations
surrounding the system development necessary for implementation and validation of the
framework. The submitted data that is released publicly also provide other interested parties
with information about banks’ risk-based capital. Finally, the submitted data supplement on-site
examination processes.
The agencies propose removing two credit valuation adjustment (CVA) items from the
exposure at default (EAD) column on FFIEC 101 Schedule B, Summary Risk-Weighted Asset
Information for Banks Approved to Use Advanced Internal Ratings-Based and Advanced
Measurement Approaches for Regulatory Capital Purposes (items 31.a and 31.b, column D).
These reporting changes would take effect as of the September 30, 2017, report date. The
current annual burden for the FFIEC 101 is estimated to be 59,576 hours, and would remain
unchanged with the proposed revisions.
Background and Justification
Section 1831(o) of the FDI Act requires each Federal banking agency to adopt a riskbased capital requirement, which is based on the prompt corrective action framework in that
section. The ILSA (12 U.S.C. § 3907(a)(1)) mandates that each Federal banking agency require
banks to achieve and maintain adequate capital by establishing minimum levels of capital or by

other methods that the appropriate federal banking agency may deem appropriate. Section 908
of the ILSA (12 U.S.C. § 3907(b)(3)(C)) also directs the Chairman of the Federal Reserve Board
and the Secretary of the Treasury to encourage governments, central banks, and regulatory
authorities of other major banking countries to work toward maintaining and, where appropriate,
strengthening the capital bases of banking institutions involved in international lending.
U.S. risk-based capital requirements are based on an internationally agreed upon
framework for capital measurement that was developed by the Basel Committee on Banking
Supervision (BCBS) and endorsed by the central-bank governors of the Group of Ten (G-10)1
Countries in 1988. Although the 1988 Accord has been a stabilizing force for the international
banking system, the world financial system has become increasingly more complex. The BCBS
developed a new regulatory capital framework that recognizes new developments in financial
products, incorporates advances in risk measurement and management practices, and more
precisely assesses capital charges in relation to risk. In April 2003, the BCBS released for public
comment a document entitled The New Basel Capital Accord (Proposed New Accord) that set
forth proposed revisions to the 1988 Accord. Also, the agencies participated with other members
of the BCBS during the development of the New Accord, which was issued in June 2004. The
agencies also participated in the Fourth Quantitative Impact Study during the fall and winter of
2004-2005 (QIS 4; OMB No. 7100-0303), to better understand the potential impact of the
proposed framework on the risk-based capital requirements for banks.
On December 7, 2007, the agencies published a final rule in the Federal Register, entitled
Risk-Based Capital Standards: Advanced Capital Adequacy Framework – Basel II. This final
rule was based on the New Basel II Capital Accord and recognizes developments in financial
products, incorporates advances in risk measurement and management practices, and imposes
capital requirements that are generally more sensitive to risk. In particular, the final rule requires
banks to assign risk parameters to exposures and provides specific risk-based capital formulas
that would be used to transform these risk parameters in to risk-based capital requirements.
Included within the final rule are requirements for public disclosure of certain information at the
consolidated banking organization level as well as a reference to certain additional regulatory
reporting requirements for banks and BHCs. The additional regulatory reporting requirements
referenced within the final rule, and described more fully herein, comprise the agencies’
regulatory reporting requirements. Effective with the March 31, 2014, report date, the agencies
incorporated the Basel III capital disclosure template in its entirety consistent with the revised
regulatory capital rules and revised advanced approaches rules to calculate risk-weighted assets.
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The Board uses the data collected to:
Assess the components of each bank’s risk-based capital requirements;
Assess each bank’s capital relative to inherent risks and the Board’s minimum capital
requirements;
Monitor the levels and components of the risk-based capital requirements for banks
through peer, outlier, and risk trend analyses;
Evaluate the quantitative impact and competitive implications of the implementation of

1

The Group of Ten is made up of eleven industrial countries (Belgium, Canada, France, Germany, Italy, Japan, the
Netherlands, Sweden, Switzerland, the United Kingdom, and the United States) which consult and cooperate on
economic, monetary and financial matters.

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the framework on risk-based capital levels within reporting banks and on an overall
industry basis;
Provide market participants, depositors, the public, supervisors, and other interested
parties with information about banks’ risk-based capital; and
Supplement on-site examination processes and decisions pertaining to the allocation of
supervisory resources.

In addition, this proposal assists supervised institutions in understanding expectations
surrounding the system development necessary for implementation and validation of the
framework.
The Board needs to monitor and assess international active banks’ conformance with
capital adequacy standards and understand the capital resulting from the implementation of the
framework. The general risk-based regulatory capital data submitted by international active
banks does not provide enough relevant information regarding risk-based capital under the
framework. Because the final rule includes transitional arrangements that involve capital floors
linked to the general risk-based capital rules (as defined in the final rule), the Board believes it is
necessary to require data submissions under both the general risk-based capital rules and
advanced risk-based capital frameworks for as long as a bank is subject to risk-based capital
floors.
As noted in the final rule, the Board conducts analyses to gauge the impact of the
framework, and the preparedness of banks to compute risk-based capital consistent with those
requirements, during the parallel run and transitional floor periods. Data submitted through these
reporting requirements, combined with dual reporting requirements for the general risk-based
capital data, provides quantitative support for these impact analyses. Such analyses also helps
the Board evaluate the competitive and cyclical implications of the framework relative to capital
requirements for banks subject to the general risk-based capital rules and the adequacy of capital
generated under the framework. General risk-based capital data are currently captured in the
Consolidated Reports of Condition and Income (Call Report) for banks (FFIEC 031, FFIEC 041,
and FFIEC 051; OMB No. 7100-0036) and the Consolidated Financial Statements for Holding
Companies (FR Y-9C; OMB No. 7100-0128).
The FFIEC 101 is necessary to ensure that the new risk-based regulatory capital
framework is implemented in the United States in a safe and sound manner. There is no other
reporting form that collects from all banks and BHCs the information that is gathered through the
FFIEC 101.
Description of Information Collection
Who Must Report
The FFIEC 101 information collections are mandatory for institutions using the advanced
approaches risk-based capital rule (advanced approaches banking organizations): national banks
(12 U.S.C. § 161), state member banks and bank holding companies (12 U.S.C. § 324 and
12 U.S.C. § 1844(c)), savings and loan holding companies (12 U.S.C. § 1467a(b)), intermediate

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holding companies (12 U.S.C. § 1844(c), 12 U.S.C §§ 3106 and 3108(a), 12 U.S.C. § 5365,
12 CFR 252.153(b)(2)), insured state nonmember commercial and savings banks (12 U.S.C. §
1817), and savings associations (12 U.S.C. § 1464).
Overview of the Data Collection
Respondents are required to submit detailed data on the components of their capital and
risk-weighted assets in nineteen schedules (A through S). A limited portion of this data is
publicly available (Schedules A and B and data items 1 and 2 of Schedule S). The majority of
the data is not publicly available.
Publicly Available Data
Schedules A and B (and data items 1 and 2 of proposed Schedule S, Operational Risk)
include data items that are publicly available for each reporting entity for reporting periods
subsequent to its parallel run period. Schedule A contains information about the components of
Tier 1 capital, Tier 2 capital, and adjustments to regulatory capital as defined within the rule.
Schedule B contains summary information about risk-weighted assets by risk type, and, in the
case of credit risk exposures, outstanding balances and aggregated information about the drivers
and estimates that underlie the calculation of risk-weighted assets.
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The general exposure breakdowns in Schedule B are as follows:
Wholesale Exposures, including separate reporting for the following types of exposures:
Corporate; Bank; Sovereign; Income Producing Real Estate; High Volatility Commercial
Real Estate; Eligible Margin Loans, Repo-Style Transactions, and OTC Derivatives with
Cross Product Netting; Eligible Margin Loans, Repo-Style Transactions, and OTC
Derivatives without Cross Product Netting;
Retail Exposures, including separate reporting for the following types of exposures:
Residential Mortgage Closed-end First Liens, Residential Mortgage Closed-end Junior
Liens, Residential Mortgage Revolving Exposures, Qualifying Revolving Exposures, and
Other Retail Exposures;
Securitization Exposures;
Equity Exposures;
Other Assets;
Excess Eligible Credit Reserves Not Included in Tier 2 Capital;
Market Risk Equivalent Assets; and
Operational Risk.

Some of the aggregate data items submitted in Schedule B are derived from information
contained in the more detailed confidential supporting schedules described below. The data
contained in Schedule B describe the main summary-level components of banks’ risk-weighted
assets, but would not allow users to exactly replicate banks’ risk-weighted asset calculations
since the data are averaged, weighted, and rounded.
Schedule S shows the data items within the operational risk exposure class that banks
submit. Data items 1 and 2 are publicly available and include high-level information on
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operational risk capital, expected operational loss, eligible operational risk offsets, and total riskbased capital requirements for operational risk.
The intent of these disclosures is to provide market participants, depositors, supervisors,
the public, and other interested parties with a sufficient level of detail (comparable, in principle,
to risk-based capital information collected currently) about banks’ major capital and riskweighted asset components as well as summary information about the composition of regulatory
capital and the risk parameters that underlie risk-weighted asset calculations.
Non-publicly Available Data
The data items contained in Schedules C through S describe the main components of
banks’ risk-weighted assets and are essentially expanded detail of the more summary information
contained in the public data items shown in Schedule B. The data submitted in these schedules
are not made available to the public (except for data items 1 and 2 of Schedule S, Operational
Risk). Supervisors request these data to support comparisons of certain critical capital drivers
across banks and across time. For the reasons cited previously, however, the information
contained in the columns of the tables would not allow users to exactly replicate banks’ riskweighted asset calculations. A brief description of the content of Schedules C through S follows.
Wholesale Exposures. Schedules C through J show data items within the wholesale
exposure category that are submitted. Each schedule represents a sub-portfolio of the wholesale
exposure category as listed on the public Schedule B. For each reported sub-portfolio, the
schedule groups exposures into sub-portfolio segments using supervisor-defined probability of
default (PD) ranges. The reported cells within these schedules then describe the main risk
parameters and characteristics of each sub-portfolio segment.
Retail Exposures. Schedules K through O show data items within the retail exposure
category that are submitted. Again, each schedule represents a sub-portfolio of the retail
exposure category as listed on the public Schedule B. PD ranges are used to sub-divide each subportfolio into segments.2 The reported cells within these schedules then describe the main risk
parameters and characteristics of each sub-portfolio segment. The retail schedules also
incorporate risk characteristics that are believed to be commonly used drivers within banks’ risk
management and measurement processes, including the distribution of each sub-portfolio
segment by loan-to-value ranges (applies only to real estate exposures), weighted average credit
bureau score, and weighted average account age.3
Securitization Exposures. Schedules P and Q show data items within the securitization
exposure class that are submitted. Schedule P provides information by rating categories about
exposures subject to either the Ratings-Based Approach (RBA) or the Internal Assessment
Approach (IAA). Schedule Q provides certain memoranda information about unrated
securitization exposures, exposures treated under the Supervisory Formula Approach, synthetic
2

Unlike the wholesale credit exposure reporting schedules, the PD ranges for retail exposures differ from subportfolio to sub-portfolio.
3
For qualifying revolving exposures and other (non-mortgage) retail exposures, the exposure at default (EAD) of
accounts under two years old is reported instead of weighted average age for each sub-portfolio exposure segment.

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securitizations, and risk-weighted assets relating to early amortization features of securitizations
as prescribed in the rule.
Equities. Schedule R provides information about a bank’s equity exposures by type of
exposure and by approach to measuring required capital. Schedule R also provides information
on equity exposures subject to specific risk weights and equity exposures to investment funds. A
bank also completes the appropriate section of the schedule based on whether it uses a simple
risk-weight approach, a full internal models approach, or a partially modeled approach to
measuring required capital for equity exposures.
Operational Risk. Schedule S shows the data items within the operational risk exposure
class that banks submit. Data items submitted in this schedule, which are confidential, include
various details about historical operational losses, on a stand-alone and group-wide basis, for the
current reporting period and those historical operational losses used to model operational risk
capital. The schedule also contains confidential data items related to scenarios, distribution
assumptions, and loss caps used to model operational risk capital.
Proposed Revisions
The agencies propose to remove two items which collect EAD information related to
CVAs that already is captured in a separate item on FFIEC 101 Schedule B. Specifically, the
agencies are proposing to remove column D (EAD) for items 31.a, “Credit valuation adjustments
simple approach,” and 31.b, “Credit valuation adjustments advanced approach.” These line
items were added to the FFIEC 101 report in March of 2014, and were intended to provide data
pertaining to the CVA requirements under the agencies’ regulatory capital rules4 for over-thecounter (OTC) derivative activities.
Under these rules, CVA is the fair value adjustment to reflect counterparty credit risk in
the valuation of an OTC derivative contract that has a positive fair value. The advanced
approaches risk-based capital rules provide two approaches for calculating the CVA capital
requirement: the simple and advanced CVA approaches. The conditions for each approach, as
well as the methods for calculation, are described in section 132 of the regulatory capital rules.
Currently, EAD information pertaining to CVAs that is reported in FFIEC 101 Schedule B
remains confidential, even after an institution completes its parallel run period.
The agencies have determined that the EAD information reported in column D of items
31.a and 31.b on FFIEC 101 Schedule B is already captured in column D of item 10 (OTC
derivatives - no cross-product netting - EAD adjustment method) on FFIEC 101 Schedule B.
Continuing to collect the same EAD information in both places is not only redundant, but also
may be misinterpreted by the agencies’ users of FFIEC 101 data as additional default risk held
by the reporting entity. For these reasons, the agencies propose removing column D for items
31.a and 31.b on FFIEC 101 Schedule B. The agencies would continue to collect the amount of
risk-weighted assets for CVAs in column G of items 31.a and 31.b on FFIEC 101 Schedule B.
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For national banks and federal savings associations (12 CFR part 3) (OCC); for state member banks and holding
companies (12 CFR part 217) (Board); and for state nonmember banks and state savings associations (12 CFR part
324) (FDIC).

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The reporting changes would take effect as of the September 30, 2017, report date.
However, as the two items being removed are not made public or otherwise shared outside the
agencies, reporting entities may elect to adopt the changes immediately by ceasing to report
column D of items 31.a and 31.b on FFIEC 101 Schedule B.
Time Schedule for Information Collection
The FFIEC 101 is collected quarterly as of the end of the last calendar day of March,
June, September, and December. Reporting HCs and banks submit data quarterly because efforts
to monitor banks’ progress toward, and actions under, the framework require regular and
consistent data submissions from all of the institutions adopting this framework. The first
reporting period for Schedules A through S for each reporting entity seeking to qualify for the
advanced approaches corresponds to the first quarter of its parallel run period.
The report due dates are 60 days following the end of a quarter while a state member
bank or HC is in its parallel run period. After completing its parallel run period, the report due
dates are the same as the report due dates currently required of banks and HCs when filing their
respective Call Report or FR Y-9C. State member banks must submit the FFIEC 101 to the
appropriate Federal Reserve Bank within thirty calendar days following the as-of date; a five-day
extension may be given to banks with more than one foreign office. HCs must submit the
FFIEC 101 to the appropriate Federal Reserve Bank within forty calendar days after the
March 31, June 30, and September 30 as of dates unless that day falls on a weekend or holiday
and within forty-five calendars days after the December 31 as of date.
Individual respondent data, excluding confidential information, would be available on the
National Information Center public website.
Legal Status
The Board’s Legal Division has determined that section 9(6) of the Federal Reserve Act
for state member banks (12 U.S.C. § 324), section 5(c) of the Bank Holding Company Act for
BHCs and IHCs (12 U.S.C. § 1844(c)), the Homeowners’ Loan Act for savings and loan holding
companies (12 U.S.C. § 1467a(b)(2)), and section 165 of the Dodd-Frank Act for IHCs (12
U.S.C. § 5365) authorize the Board to require the information collection. The FFIEC 101 is
mandatory for advanced approaches banking organizations.
Some items collected as part of the FFIEC 101 will be made public upon filing. For these
items, the issue of confidentiality will not arise unless the submitter asks for confidential
treatment and provides a basis to withhold the information as confidential commercial
information whose disclosure would cause substantial competitive harm, justifying confidential
treatment under exemption 4 of the Freedom of Information Act (FOIA). Such requests would
have to be considered on a case-by-case basis.
Some items are proposed to be withheld during the so-called “parallel run” period, but
released publicly thereafter. These include Schedule A, Schedule B, and items 1-2 in
Schedule S, Operational Risk. Schedule A collects information about the components of tier 1

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capital, tier 2 capital, adjustments to regulatory capital, regulatory capital ratios, and capital
buffer. Schedule B contains summary information about risk-weighted assets by risk type, and,
in the case of credit risk exposures, outstanding balances and aggregated information about the
estimates that underlie the calculation of risk-weighted assets. Schedule S collects data related to
operational risk under the agencies’ advanced approaches rules.
The parallel run period is designed in significant part to allow the supervisory agencies to
assess the quality of a banking organization’s internal models and systems and determine
whether the banking organization is ready for the implementation of the advanced approaches.
During the parallel run period, supervisors may request a banking organization to amend its
internal models, risk measurement and management infrastructure. Public disclosure of these
schedule items during the parallel run period could lead investors, competitors, and the public to
misjudge the financial health of the institutions, when in fact there has been no change to their
underlying fundamentals and, therefore, could result in substantial competitive harm. The
specific items treated as confidential during the parallel run period are Schedule A items 78, 79,
86, 87, 88, 89, and 90, as well as Schedules B through S. These classes of data may be protected
from disclosure during the parallel run period under exemption 4 of the FOIA.
Finally, Schedules C through S would remain confidential both during and after the
parallel run period. The data items found in these schedules contain more detailed information
than included in the public schedules, including sensitive information breaking down individual
banking organization exposures to borrowers by probability of default, exposures at default, and
loss given default. Disclosure of this information could result in substantial competitive harm to
the institution, particularly because many financial institutions will not be reporting such data,
and would benefit from the public disclosure of such detailed information regarding their
competitors they would not be required to disclose themselves. Accordingly, FOIA exemption 4
permits confidential treatment for these data items.
Consultation Outside the Agency
On March 1, 2017, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (82 FR 12274) requesting public comment for 60 days on the
extension, with revision, of the FFIEC 101. The comment period for this notice expired on
May 1, 2017. No comments were received addressing the proposed revisions. On June 2, 2017,
the agencies published a final notice in the Federal Register (82 FR 25655).
Estimate of Respondent Burden
The current total annual burden for the FFIEC 101 is estimated to be 59,576 hours and
would remain unchanged based on the proposed revisions. These reporting requirements
represent less than 1 percent of the total Federal Reserve paperwork burden.

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Annual
frequency

Estimated
average hours
per response

6

4

674

16,176

16

4

677

43,328

6

4

3

72

Number of
respondents5

FFIEC 101
SMBs
BHCs and SLHCs
IHCs

Estimated
annual burden
hours

59,576

Total

The current cost to the public for this information collection is estimated to be $3,270,722.6
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The ongoing costs for collecting and processing the data are estimated to be $157,694 per
year.

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Of these respondents, none are considered small entities 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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Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$67, 15% Lawyers at $67, and 10% Chief Executives at $93). 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 2016, published March 31, 2017, 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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