FR2320_20171214_omb

Supporting Statement for the
Quarterly Savings and Loan Holding Company Report
(FR 2320; OMB No. 7100-0345)
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,
without revision, the mandatory Quarterly Savings and Loan Holding Company Report
(FR 2320; OMB No. 7100-0345). The FR 2320 collects select parent only and consolidated
balance sheet and income statement financial data and organizational structure data from savings
and loan holding companies (SLHCs) that are currently exempt from filing other Federal
Reserve regulatory reports (exempt SLHCs).1 The FR 2320 is used by the Board to analyze the
overall financial condition of exempt SLHCs to ensure safe and sound operations. These data
assist the Board in the evaluation of a diversified holding company and in determining whether
an institution is in compliance with applicable laws and regulations. The annual burden is
estimated to be 150 hours.
Background and Justification
The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)
was enacted into law on July 21, 2010. Title III of the Dodd-Frank Act transferred all former
Office of Thrift Supervision (OTS) authorities (including rulemaking) related to SLHCs and their
non-depository subsidiaries to the Board of Governors of the Federal Reserve System on July 21,
2011. Consequently, the Board became responsible for the consolidated supervision of SLHCs
as of that date. Initially, all SLHCs continued to submit all regulatory reports previously
required by the OTS through the existing processing system, the OTS’s Electronic Filing System
(EFS), through December 31, 2011. However, on February 6, 2012, the Board of Governors
approved the implementation of the FR 2320 for the exempt SLHCs. The FR 2320 report
replaced the OTS Thrift Financial Report (TFR; OMB No. 1557-0255) Schedule HC for these
organizations, effective March 31, 2012.
Description of Information Collection
The FR 2320 collects select parent only and consolidated balance sheet and income
statement financial data and organizational structure data from SLHCs exempt from filing other
Federal Reserve regulatory reports.
Respondent Panel
The respondents are:

1

To be exempt, an SLHC must meet one of the following criteria: (1) the SLHC was formed under section
10(c)(9)(C) of the Home Owners’ Loan Act (HOLA) and the consolidated assets of its saving association
subsidiaries make up less than 5 percent of the total consolidated assets of the SLHC; or (2) its top-tier holding
company is an insurance company that only prepares financial statements using statutory accounting principles.

(1) grandfathered unitary SLHCs2 whose:
(a) savings association subsidiaries’ consolidated assets make up less than
5 percent of the total consolidated assets of the grandfathered SLHC on an
enterprise-wide basis as calculated annually as of June 30th, using the four
previous quarters (which includes the quarter-ended June 30th reporting period),
for any of these four quarters; and
(b) where more than 50 percent of the assets of the grandfathered unitary SLHC
are derived from activities that are not otherwise permissible under HOLA on an
enterprise-wide basis as calculated annually as of June 30th, using the assets
reported as of June 30th, OR
(2)
(a) SLHCs where more than 50 percent of the assets of the SLHC are derived
from the business of insurance on an enterprise-wide basis as calculated annually
as of June 30th, using the assets reported as of June 30th; and
(b) the SLHC does not submit reports to the SEC pursuant to sections 13 or 15(d)
of the Securities Exchange Act of 1934.
The FR 2320 is generally filed by the top-tier SLHC if that SLHC is exempt from filing
other Federal Reserve existing regulatory reports. However, if a top-tier SLHC is not required to
file the FR 2320, then a lower-tier SLHC must file the FR 2320. Determinations as to which
SLHC will be required to file the FR 2320 will be made by the appropriate Federal Reserve
Bank. In addition, lower-tier SLHCs may voluntarily file the FR 2320 or may be required to file
(in addition to the top-tier SLHC) for safety and soundness purposes at the discretion of the
appropriate Federal Reserve Bank.
Time Schedule for Information Collection and Publication
The FR 2320 is filed quarterly as of the end of March, June, September, and December.
If a SLHC has a quarter-end other than a calendar quarter-end, data from the fiscal quarter
ending within the calendar quarter may be used to complete the FR 2320. The submission date
to file this report is 45 calendar days after the report date.
Legal Status
The Board’s Legal Division has determined the Home Owners’ Loan Act authorizes the
Board to require SLHCs to file “such reports as may be required by the Board” and instructs that
such reports “shall contain such information concerning the operations of such savings and loan
holding company and its subsidiaries as the Board may require” (12 U.S.C. 1467a(b)(2)). The
obligation to respond is mandatory for exempt SLHCs. Lower-tier SLHCs may voluntarily file
the FR 2320 or may be required to file (in addition to the top-tier SLHC) for safety and
soundness purposes at the discretion of the appropriate Federal Reserve Bank.
The Board’s Legal Division has also determined that data items SLHCC572, SLHCC573,
and SLHCC574 (line items 24, 25, and 26) may be protected from disclosure under exemption 4
of the Freedom of Information Act (FOIA). Commercial or financial information may be
protected from disclosure under exemption 4 if disclosure of such information is likely to cause
2

SLHCs that are exempt pursuant to section 10(c)(9)(C) of HOLA.

2

substantial competitive harm to the provider of the information (5 U.S.C. 552(b)(4)). The data
items listed above pertain to new or changed pledges, or capital stock of any subsidiary savings
association that secures short-term or long-term debt or other borrowings of the SLHC; changes
to any class of securities of the SLHC or any of its subsidiaries that would negatively impact
investors; and defaults of the SLHC or any of its subsidiaries during the quarter. Disclosure of
this type of information is likely to cause substantial competitive harm to the SLHC providing
the information and thus this information may be protected from disclosure under FOIA
exemption 4.
With regard to the remaining data items on the FR 2320, the Board’s Legal Division has
determined that institutions may request confidential treatment for any FR 2320 data item or for
all FR 2320 data items, and that confidential treatment will be reviewed on a case-by-case basis.
Consultation Outside the Agency
On August 23, 2017, the Board published an initial notice in the Federal Register
(82 FR 40000) requesting public comment for 60 days on the extension, without revision, of the
FR 2320. The comment period for this notice expired on October 23, 2017. The Board did not
receive any comments. On December 12, 2017, the Board published a final notice in the Federal
Register (82 FR 58396) and the information collection will be extended as proposed.
Estimate of Respondent Burden
The annual burden for the FR 2320 is estimated to be 150 hours as shown in the
following table. The estimated hours per response is based on the hourly estimate previously
associated with the FR 2320. The Board believes this estimate is reasonable given that no
changes are proposed to the data items to be collected. These reporting requirements represent
less than 1 percent of the total Federal Reserve System paperwork burden.
Number of
respondents3
FR 2320

15

Estimated
Estimated
Annual
average hours annual burden
frequency
per response
hours
4

2.5

150

The current annual cost to the public of this report is estimated to be $8,235.4

3

Of these respondents, none are considered 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-sureyou-meet-sba-size-standards/table-small-business-size-standards.
4
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/.

3

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 cost estimates to the Federal Reserve System for collecting and processing the
FR 2320 is negligible.

4