FRY14_20170906_omb

OMB Supporting Statement for the
Capital Assessments and Stress Testing
(FR Y-14A/Q/M; OMB No. 7100-0341)
Amendments to the Capital Plan and Stress Test Rules; Regulations Y and YY
(Docket No. R-1548; RIN 7100-AE59)
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 mandatory Capital Assessments and Stress Testing (FR Y-14A/Q/M; OMB
No. 7100-0341) 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 252.153. 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.1
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 is comprised of three retail portfolio- and loan-level collections,
and one detailed address matching collection to supplement two of the portfolio and loanlevel collections.

The FR Y-14A, FR Y-14Q, and FR Y-14M reports are used to support the
Comprehensive Capital Analysis and Review (CCAR) exercise, supervisory stress test models,
and continuous monitoring efforts.
The Board adopted a final rule that reduces burden associated with reporting the FR Y-14
schedules for large and noncomplex firms by raising the materiality threshold, reducing
supporting documentation requirements, removing several sub-schedules from the FR Y-14A
Summary Schedule, and using the median loss rate for immaterial portfolios. The total annual
burden for the FR Y-14A/Q/M is estimated to be 858,138 hours, a decrease of 56,454 hours from
the current burden of 914,592 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
1

Firms that must re-submit their capital plan generally also must provide a revised FR Y-14A in connection with
their resubmission.

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
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 Board annually and to require such firms to request prior approval
from the Board under certain circumstances before making a capital distribution.2 In connection
with submissions of capital plans to the Board, firms are required, pursuant to 12 CFR
225.8(d)(3), to provide certain data to the Board.
The Board’s stress test rules establish stress testing requirements for certain BHCs, state
member banks, savings and loan holding companies and foreign banking organizations.3 The
final rules implement sections 165(i)(1) and (i)(2) of the Dodd-Frank Act. Section 165(i)(1)
requires the Board to conduct an annual stress test of each covered company 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).4 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 Board 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 IHCs 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 began filing the FR Y-14 reports 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
information and perspective needed to help ensure that large firms 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 is complemented by other Board
supervisory efforts aimed at enhancing the continued viability of large firms, including
continuous monitoring of firms’ planning and management of liquidity and funding resources
2

See 12 CFR 225.8.
See 12 CFR 252, subparts B, E, F, and O.
4
See 12 U.S.C. 5365(a). A covered company means (1) a bank holding company (other than a foreign banking
organization) with average total consolidated assets of $50 billion or more; (2) A U.S. intermediate holding
company subject to 12 CFR 252, subpart F pursuant to §252.153; and (3) A nonbank financial company supervised
by the Board.
3

2

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. To fully evaluate the data submissions, the Board may
conduct follow-up discussions with, or request responses to follow up questions from
respondents.
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.5 Compliance with the information collection is mandatory.
FR Y-14A (semi-annual collection)
The semi-annual collection of quantitative projected regulatory capital ratios across
various macroeconomic scenarios is comprised of seven primary schedules (Summary, Scenario,
Regulatory Capital Instruments, Regulatory Capital Transitions, Operational Risk, Business Plan
Changes (BPC), and Retail Repurchase Exposures schedules), each with multiple supporting
tables.6
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.
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 inputs to supervisory stress test
models to monitor actual versus forecast information on a quarterly basis and to conduct ongoing
supervision.
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.
To match senior and junior lien residential mortgages on the same collateral, the Address

5

The most current reporting templates for the FR Y-14A/Q/M are available at:
www.federalreserve.gov/apps/reportforms/default.aspx.
6
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.

3

Matching schedule gathers additional information on the residential mortgage loans reported in
the First Lien and Home Equity schedules.
Proposed Revisions
The Board adopted a final rule that revises the capital plan and stress test rules for BHCs
with $50 billion or more in total consolidated assets and U.S. IHCs of foreign banking
organizations. Under the final rule, large and noncomplex firms (those with total consolidated
assets of at least $50 billion but less than $250 billion, nonbank assets of less than $75 billion,
and that are not U.S. global-systemically important banks) are no longer subject to the provisions
of the Board’s capital plan rule whereby the Board may object to a capital plan on the basis of
qualitative deficiencies in the firm’s capital planning process. Accordingly, these firms will no
longer be subject to the qualitative component of the annual Comprehensive Capital Analysis
and Review (CCAR). The final rule also modifies certain regulatory reports to collect additional
information on nonbank assets and to reduce reporting burdens for large and noncomplex firms.
For all bank holding companies subject to the capital plan rule, the final rule simplifies the initial
applicability provisions of both the capital plan and the stress test rules, reduces the amount of
additional capital distributions that a bank holding company may make during a capital plan
cycle without seeking the Board’s prior approval, and extends the range of potential as-of dates
the Board may use for the trading and counterparty scenario component used in the stress test
rules.
In discussions on CCAR, several large and noncomplex firms recommended that the
Board revise the FR Y-14 series of reports to reduce reporting burdens for these firms. For
instance, these large and noncomplex firms suggested that the Board raise the materiality
threshold for the FR Y-14 reports and reduce the detail required in the supporting documentation
requirements. The final rule reduced burden associated with reporting the FR Y-14 schedules for
large and noncomplex firms by raising the materiality threshold, reducing supporting
documentation requirements, removing several sub-schedules from the FR Y-14A Summary
Schedule, and using the median loss rate for immaterial portfolios.
The final rule increased the materiality thresholds for filing schedules on the FR Y-14Q
report and the FR Y-14M report for large and noncomplex firms. The FR Y-14 instructions
currently define material portfolios as those with asset balances greater than $5 billion or asset
balances greater than five percent of tier 1 capital, each measured as an average for the four
quarters preceding the reporting quarter.7 The final rule revised the FR Y-14’s definition of a
“material portfolio” for large and noncomplex firms to mean a portfolio with asset balances
greater than either (1) $5 billion or (2) 10 percent of tier 1 capital, each measure as an average
for the four quarters preceding the reporting quarter.8 As a result of this change, respondents will
be able to exclude certain portfolios from reporting and in some cases may not be required to
report certain schedules at all.

7

Respondents have the option to complete the data schedules for immaterial portfolios.
The four quarter average percent of tier 1 capital is calculated as the sum of the firm’s preceding four quarters of
balances subject to the particular materiality threshold divided by the sum of the firm’s proceeding four quarters of
tier 1 capital.
8

4

In addition, the final rule reduced the supporting documentation a large and noncomplex
firm will be required to be submit with its capital plan. Appendix A of the FR Y-14A report
outlines qualitative information that a bank holding company should submit in support of its
projections, including descriptions of the methodologies used to develop the internal projections
of capital across scenarios and other analyses that support the bank holding company’s
comprehensive capital plans. The final rule revised the instructions to Appendix A of the FR Y14A to remove the requirement that a large and noncomplex firm include in its capital plan
submission certain documentation regarding its models, including any model inventory mapping
document, methodology documentation, model technical documents, and model validation
documentation. Large and noncomplex firms will still be required to be able to produce these
materials upon request by the Federal Reserve, and all or a subset of these firms may be required
to provide this documentation depending on the focus of the supervisory review of large and
noncomplex firm capital plans. Removing the requirement that a large and noncomplex firm
submit this information in connection with its capital plan should reduce the resources needed to
prepare the plan for submission and alleviate concerns of an adverse supervisory finding that a
capital plan is incomplete based on the failure to provide documentation.
Under the final rule, large and noncomplex firms will no longer be required to complete
several elements of the FR Y-14A Schedule A (Summary), including the Securities OTTI
methodology sub-schedule, Securities Market Value source sub-schedule, Securities OTTI by
security sub-schedule, the Retail repurchase sub-schedule, the Trading sub-schedule,
Counterparty sub-schedule, and Advanced RWA sub-schedule.9 The revised instructions for the
FR Y-14A Summary schedule reporting form are available on the Board’s public website.
Removing these elements should reduce burdens associated with collecting and validating this
data, responding to follow-up inquiries, and implementing and maintaining technical systems.
Under the final rule, a large and noncomplex firm may adopt these changes for the FR Y-14A
report as of December 31, 2016, or as of June 30, 2017. The Board continues to review the
details required to be reported in the FR Y-14 series of reports, and may propose additional
changes in the future to further reduce burdens associated with these reporting requirements.
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: (i) 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 (ii) 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 the respondent meets this asset threshold, unless otherwise directed by the Board.

9

A large and noncomplex firm would be required to report line item 138 of the income statement, as that line item is
currently derived from the retail repurchase sub-schedule.

5

Consultation Outside the Agency
On September 30, 2016, the Board published a notice of proposed rulemaking in the
Federal Register (81 FR 67239) for public comment. The comment period for this notice expired
on November 25, 2016. The Board did not receive any specific comments related to the
Paperwork Reduction Act (PRA) analysis. On February 3, 2017, the Board published a final rule
in the Federal Register (82 FR 9308). The final rule is effective on March 6, 2017.
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
BHCs and nonbank financial companies supervised by the Board are subject to enhanced riskbased and leverage standards 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
BHCs (12 U.S.C. § 1844).
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.
Time Schedule for Information Collection and Publication
The following tables outline, by schedule and reporting frequency (annually, semiannually, quarterly, or monthly), the as of dates for the data and their associated due date for the
current submissions to the Federal Reserve.
Schedules and SubSub-schedules

Summary,
Macro Scenario

Retail Repurchase
Exposures

Data as-of-date

Submission Date
to Federal Reserve

Semi-annual Schedules
 Data as-of
 Data are due April 5th of
December 31st.
the 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).

6

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

Schedules



Data as-of
December 31st.

Data as-of a specified
date in the first quarter.
As-of-date would be
communicated by
Federal Reserve10



Data are due April 5th of
the following year.



Data are due April 5th of
the following year

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.

10

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).

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.

7

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

For all other quarters,
the as-of date would be
the last day of the
quarter, except for
firms that are required
to re-submit their
capital plan.

Fourth quarter – Trading and
Counterparty (Regular/unstressed
submission):
52 calendar days after the notification
date (notifying respondents of the asof-date) or March 15, whichever
comes earlier. Unless the Board
requires the data to be provided
over a different weekly period,
firms may provide these data as-of
the most recent date that corresponds
to their weekly internal risk reporting
cycle as long as it falls before the asof-date.

For these firms, the asof date for the quarter
preceding the quarter in
which they are required
to re-submit a capital
plan would be
communicated to the
firms during the
subsequent quarter

All schedules

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.

As 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)).

8

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 914,592 hours and, with the
proposed revisions, would decrease by 56,454 hours, for a total of 858,138 hours, including
18,240 hours of ongoing automation burden. These reporting requirements represent 6.83 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 82,580 hours
and, with the proposed revisions, would decrease by 6,346 hours, for a total of 76,234 hours.
FR Y-14Q Burden
The current total annual burden hours for the FR Y-14Q is estimated to be 219,552 hours
and, with the proposed revisions, would decrease by 1,088 hours for a total of 218,464 hours.
FR Y-14M Burden
The current total annual burden hours for the FR Y-14M is estimated to be 560,940 hours
and, with the proposed revisions, would decrease by 49,020 hours, for a total of 511,920 hours.
Implementation and On-Going Automation Burden
In an effort to more accurately reflect the burden imposed on the BHCs and IHCs 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 or IHC that would update their systems to
complete the FR Y-14 submissions would vary across firms. On average, it would take
approximately 480 hours (on-going maintenance) to update systems for submitting the data, for a
total of 18,240 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 Y14. Since there are no new respondents for the final rule, this estimate results in 0 burden hours.

9

Estimated
Number of
Annual
average hours
respondents frequency
per response

Estimated
annual burden
hours

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

38
38
38
38
38
38
38
5

2
2
1
1
1
1
2
1

993
31
18
23
21
10
20
100

75,468
2,356
684
874
798
380
1,520
500
82,580

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
Current FR Y-14Q total

38
38
38
38
6
38
38
38
17
38
27
6
38

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

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

2,432
2,128
108,072
23,104
46,224
3,496
7,904
7,600
1,632
608
1,728
12,192
2,432
219,552

36

12

515

222,480

Home Equity

31

12

515

191,580

Credit Card

24

12

510

146,880
560,940

Implementation and On-going Automation
Implementation
0
On-going revisions
38
Implementation and On-going Automation total

1
1

7,200
480

0
18,240
18,240

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

Current FR Y-14M total

10

Attestation
Implementation
On-going

0
13
Attestation total

0
33,280
33,280

Current Collection total

914,592

11

1
1

4,800
2,560

Number of
respondents11
Proposed FR Y-14A
Summary
Macro Scenario
Operational Risk
Regulatory Capital Transitions
Regulatory Capital Instruments
Business Plan Changes
Retail Repurchase Exposures
Adjusted Capital Submission
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
Estimated
average hours annual burden
per response
hours

Annual
frequency

38
38
38
38
38
38
38
5

2
2
1
1
1
1
2
1

911
31
18
20
21
10
20
100

69,236
2,356
684
760
798
380
1,520
500
76,234

38
38
38
38
6
38
38
38
14
38
24
6
38

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

15
13
711
151
1,926
23
52
50
23
4
15
508
16

2,280
1,976
108,072
22,952
46,224
3,496
7,904
7,600
1,288
608
1,440
12,192
2,432

Proposed FR Y-14Q total

218,464

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

36

12

515

222,480

Home Equity
Credit Card
Proposed FR Y-14M total

30
17

12
12

515
510

185,400
104,040
511,920

11

Of the respondents required to comply with the FR Y-14A/Q/M information collection, none 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/content/table-small-business-size-standards.

12

Proposed Implementation and On-going Automation
Implementation
0
On-going revisions
38
Proposed Automation total

1
1

7,200
480

0
18,240
18,240

1
1

4,800
2,560

Attestation total

0
33,280
33,280

Proposed Collection total

858,138

Attestation
Implementation
On-going

0
13

-56,454

Total Change
The total cost to the public for this information collection is estimated to decrease from
$50,211,101 to $47,111,776 with the proposed revisions.12
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 estimated cost to the Federal Reserve System for collecting and processing this
report are $74,300 for one-time costs and $2,779,104 for ongoing costs.

12

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.nr0.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

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