FRY14_20171229_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 252.153. 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 proposes (1) revising and extending for three years the Capital Assessments
and Stress Testing information collection (FR Y-14A/Q/M; OMB No. 7100-0341); (2)
modifying the scope of the global market shock component of the Board’s stress tests (global
market shock) in a manner that would include certain U.S. IHCs of foreign banking
organizations (FBOs); and (3) making other changes to the FR Y-14 reports.
The Board’s enhanced prudential standards rule requires certain large FBOs to establish
U.S. IHCs, which are subject to the same capital and stress testing standards that apply to
domestic bank holding companies.2 All U.S. IHCs formed in 2016 with total consolidated assets
over $50 billion will become subject to supervisory stress tests in 2018. Even though several of
these U.S. IHCs have significant trading and counterparty exposures, none of them would be
subject to the global market shock in 2018 under the current standard.

1

Firms that must re-submit their capital plan generally also must provide a revised FR Y-14A in connection with
their resubmission.
2
12 CFR 252.153 (79 FR 17240 (March 27, 2014)).

Specifically, the Board has proposed to amend the FR Y-14 to apply the global market
shock to any domestic bank holding company or U.S. IHC that is subject to supervisory stress
tests and that (1) has aggregate trading assets and liabilities of $50 billion or more, or aggregate
trading assets and liabilities equal to 10 percent or more of total consolidated assets, and (2) is
not a “large and noncomplex firm” under the Board’s capital plan rule.3 As a result of the
proposed change, six U.S. IHCs are expected to become subject to the global market shock, and
the six domestic bank holding companies that meet the current materiality threshold would
remain subject to the exercise under the new threshold.4 The annual reporting burden associated
with the addition of the six U.S. IHCs to the global market shock is estimated at 9,736 hours per
firm for a total increase of approximately 58,416 hours, plus an additional 400 hours of one-time
implementation burden to implement the additional reporting required to file the FR Y-14Q
Schedule F (Trading) and Schedule L (Counterparty).
The proposed revisions to the FR Y-14M consist of adding two items related to
subsidiary identification and balance amounts, which facilitate use of these data by the Office of
the Comptroller of the Currency (OCC). The addition of these items would also result in the
removal of an existing item that identifies loans where the reported balance is the cycle-ending
balance.
A limited number of other changes to the FR Y-14 were proposed. In connection with
these proposed changes, two schedules on the FR Y-14A would be removed from the collection.
The proposed revisions to the FR Y-14 would be effective with the reports as of December 31,
2017, or March 31, 2018, as noted in the detailed schedule sections below.
The total current annual burden for the FR Y-14A/Q/M is estimated to be 858,138 hours
and, with the changes proposed in this memorandum, is estimated to increase by 58,732 hours
for a total of 916,870 aggregate burden hours. Excluding the proposed modifications to the
global market shock and modification to the FR Y-14M reports, the further changes would result
in an overall net decrease of 2,084 reporting hours.
These data are, or would 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
(Dodd Frank Act).
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
3

A large and noncomplex firm is defined under the capital plan rule as a firm that has average total consolidated
assets of at least $50 billion but less than $250 billion, has average total nonbank assets of less than $75 billion, and
is not identified as global systemically important bank holding company (GSIB) under the Board’s rules. See
12 CFR 225.8(d)(9).
4
The firms include the five firms noted in the initial notice (Credit Suisse Holdings (USA), Inc., Barclays US LLC,
DB USA Corporation, HSBC North America Holdings Inc., and UBS Americas Holdings LLC) and RBC USA
Holdco Corporation, which has since met the threshold.

2

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 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.5 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.6 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 test).7 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 reports 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 Comprehensive Capital Analysis and Review (CCAR)
5

See 12 CFR 225.8.
See 12 CFR 252, subparts B, E, F, and O.
7
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 section 252.153; and (3) a nonbank financial company supervised by
the Board.
6

3

exercise complements 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 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.8 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.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.
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.
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.

4

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.
Proposed Revisions to the FR Y-14A/Q/M
Proposed Global Market Shock Modifications
The U.S. operations of FBOs became more complex, interconnected, and concentrated in
the years leading up to the financial crisis. The financial crisis demonstrated that these large
FBOs operating in the U.S. could pose a similar threat to financial stability as large U.S.
financial companies. Prior to the crisis, U.S. branches and agencies of FBOs, traditional net
recipients of funding, began receiving less funding from their parent institutions and providing
significant funding to non-U.S. affiliates. The vulnerabilities of foreign banks’ U.S. operations
became particularly apparent as FBOs became disproportionate users of Federal Reserve lending
facilities during the financial crisis; many of these FBOs required extraordinary support from
home- and host-country central banks and governments.
To mitigate certain weaknesses in the existing framework for supervising and regulating
these organizations revealed during the crisis and to recognize the important role that FBOs play
in the U.S. financial system, the Board issued a rule imposing enhanced prudential standards on
large FBOs and capital standards on U.S. bank holding company subsidiaries of FBOs (enhanced
prudential standards rule).10 The rule aimed to strengthen the capital and liquidity positions of
the U.S. operations of FBOs and promote a level playing field among all banking firms operating
in the U.S. by requiring FBOs with U.S. non-branch assets of $50 billion or more to establish a
U.S. IHC. Under the rule, U.S. IHCs are subject to the same risk-based capital and leverage
requirements applicable to domestic bank holding companies and to many of the same enhanced
prudential standards, including capital planning and stress testing requirements.
The enhanced prudential standards rule included the following transition periods:






January 1, 2015: FBOs with U.S. non-branch assets of $50 billion or more as of June 30,
2014, were required to submit an implementation plan to the Federal Reserve outlining
the proposed process to come into compliance with the rule’s requirements;
July 1, 2016: U.S. IHCs were required to be established and are subject to risk-based
capital requirements;
2017 CCAR/DFAST cycle: Newly established IHCs are subject to the capital plan rule
(but are not subject to full CCAR);
January 1, 2018: U.S. IHCs are subject to leverage capital requirements; and
2018 CCAR/DFAST cycle: newly established IHCs are subject to CCAR and supervisory
stress tests.

The FR Y-14 data are critical inputs to the CCAR exercise and supervisory stress tests.
In 2016, the Board finalized the requirement for IHCs to file certain regulatory reports applicable
10

See 77 FR 6628 (December 28, 2012) and 79 FR 17240 (March 27, 2014).

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to bank holding companies, including the FR Y-14 reports. However, because of their current
asset size, no U.S. IHCs are required to submit trading and counterparty data on the FR Y-14
reports and are not subject to the global market shock. The global market shock applies
hypothetical asset price shocks to a firm’s trading book, private equity positions, and
counterparty exposures as of a point in time, resulting in instantaneous losses and a reduction in
capital. Under the Board’s stress test rules, the global market shock applies to firms with
significant trading activity as specified in the FR Y-14 report.11 The FR Y-14 currently provides
that firms with $500 billion or more in total consolidated assets have significant trading activity.
The materiality threshold for the global market shock is based on the trailing four-quarter
average of total consolidated assets of the holding company. The current scope of applicability
of $500 billion or more in total consolidated assets was intended to capture domestic bank
holding companies with significant trading businesses. As noted, the $500 billion threshold,
however, does not capture any U.S. IHC. Applying the market shock to certain U.S. IHCs would
help the Board more accurately identify the firms’ risks and capital needs. In addition, applying
the market shock to these IHCs would result in a more comparable treatment to large domestic
bank holding companies with similar exposures and business models.
The proposal would modify the FR Y-14 reporting thresholds for the FR Y-14Q,
Schedule F (Trading) and Schedule L (Counterparty), and FR Y-14A, Schedule A.4 (Summary Trading) and Schedule A.5 (Summary - Counterparty Credit Risk), collections to apply the
global market shock to firms based in part on the trading activities of a firm. (As noted, under
the proposal the global market shock would apply to any firm subject to supervisory stress tests
that (1) has aggregate trading assets and liabilities of $50 billion or more, or aggregate trading
assets and liabilities equal to 10 percent or more of total consolidated assets, and (2) is not a
large and noncomplex firm.) The IHCs that meet the proposed materiality threshold would be:




Required to submit data surrounding trading and counterparty exposures on the FR Y14A/Q reports (FR Y-14A Schedules A.4 and A.5, (Trading and Counterparty,
respectively); FR Y-14Q Schedules F and L (Trading and Counterparty, respectively))
effective with the reports as of December 31, 2017;12 and
Subject to the global market shock exercise beginning with the 2019 CCAR/DFAST
exercise.

The revised scope of application for the global market shock is more closely tailored to
the market risk of firms. The proposed definition of total trading activity is similar to the
applicability criteria in the Board’s market risk rule, which applies to any BHC with aggregate
trading assets and trading liabilities of either (1) 10 percent or more of total assets, or
(2) $1 billion or more.13 Large and noncomplex firms would continue to be excluded from the

11

See 12 CFR 252.54(b)(2)(i).
The FR Y-14 trading and counterparty for the reports as of Q4 2017 will be due May 1, 2018. In addition, there
will also be a delayed submission date for the reports as of Q1 2018, which will be due June 30, 2018. For the
reports Q2 2018 forward, the data will be due as outlined in the FR Y-14 instructions.
13
See 12 CFR 217.201(b).
12

6

global market shock.14 This is consistent with the goal to reduce the compliance burden for the
smaller and less complex firms that participate in CCAR.
A threshold based on aggregate trading assets and liabilities of 10 percent of total assets
would capture cases where market risk is a key risk for a firm on a relative basis. As of
December 31, 2016, the firms subject to the capital plan rule on average had a ratio of tier 1
capital to total assets of 8.9 percent. Thus, 10 percent of the total assets of these firms on
average represents more than 100 percent of their tier 1 capital. A 10 percent threshold would
also align with one of the two thresholds used to identify firms that are subject to the Board’s
market risk rule, which requires firms to have risk management processes in place to address
their market risk.15
The separate $50 billion trading activity threshold would capture cases where a firm has
total trading assets and liabilities that are significant on an absolute basis but less than 10 percent
of the firm’s total assets. Adopting the $50 billion threshold, as an alternative to the current
$500 billion total assets threshold, would better capture the market risk of the largest firms that
participate in CCAR. Notably, the four largest BHCs that do not currently participate in the
global market shock on average have total assets of $378 billion as of December 31, 2016, but
have trading activity of significantly less than $50 billion (as of December 31, 2016, $9.45
billion on average). As of December 31, 2016, the only firm that would be subject to the global
market shock based solely on the proposed $50 billion asset threshold is a BHC that currently is
subject to the global market shock under the current $500 billion total assets threshold.
Proposed Revisions to the FR Y-14A and FR Y-14Q
The proposed revisions to the FR Y-14A and FR Y-14Q consist of modifying reported
items and instructions by clarifying the intended reporting of existing items, and seek to further
align reported items with methodology, standards, and treatment on other regulatory reports or
within the FR Y-14 schedules. In this regard, the Board is proposing updates to certain FR Y14Q instructions and changes to the reporting structure and requirements of existing items. In
addition, the Board proposes eliminating two schedules from the FR Y-14A to reduce burden on
the reporting institutions. The proposal would also result in the addition of a new sub-schedule
to supplement the existing collection of business plan change information and would be
consistent with the structure of data reported elsewhere on the FR Y-14A. The proposed changes
to the FR Y-14A and FR Y-14Q outlined below would be effective December 31, 2017, or
March 31, 2018.
FR Y-14A, Schedule A (Summary)
Schedule A.2.b (Retail Repurchase Projections) In an effort to further reduce burden,
the Board proposes to eliminate the FR Y-14A, Schedule A.2.b (Retail Repurchase Projections)
with the reports with data as of March 31, 2018.
“Large and noncomplex firms” is defined by the capital plan rule and would align with recently finalized
modifications to the capital plan rule. See 12 CFR 225.8(d)(9) as described in 82 FR 9308 (February 3, 2017).
15
Notably, the proposed relative materiality threshold is much higher than the materiality criteria for other FR Y-14
schedules because the proposed 10 percent threshold is defined in terms of total assets rather than tier 1 capital.
14

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Schedule A.3 (AFS/HTM Securities) The Board proposes modifying the instructions for
sub-schedules A.3.a and A.3.c to clarify the reporting of “Credit Loss portion” and “Non-Credit
Loss Portion” information. To eliminate contradictory treatment in reporting these items, the
instructions for Schedule A.3.a (Projected OTTI for AFS Securities and HTM by Security) and
A.3c (Projected OTTI for AFS and HTM Securities by Portfolio) would be modified to
specifically reference which item firms should report losses on. In addition, the text describing
the reporting of positions on the FR Y-14A, Schedule A.3.c., will be removed from the report
form and incorporated into the instructions for this sub-schedule. This change would be
effective with the reports with data as of December 31, 2017.
Schedule A.5 (Counterparty) The Board proposes adding an item to capture the FVA for
an exposure to a counterparty separately from credit valuation adjustment (CVA). Some
respondents have been including FVA in their reported CVA loss estimates. The addition of this
item would clarify the appropriate reporting of both FVA and CVA, and enable the Board to
more accurately model losses associated with counterparty risk. This change would be effective
with the reports with data as of December 31, 2017.
FR Y-14A, Schedule D (Regulatory Capital Transitions)
The Board proposes eliminating FR Y-14A, Schedule D (Regulatory Capital Transitions)
from the information collection. This schedule collected a five-year projection reflecting fully
phased-in revised regulatory capital rules. With the CCAR 2018 collection (FR Y-14 reports asof December 31, 2017), the majority of the five-year forecast projects data beyond the first
quarter of 2019, the date as of which transition provisions will be fully phased-in, diminishing
the value-added by collecting these projections.
FR Y-14A, Schedule F (Business Plan Changes)
Schedule F.2 (Pro Forma Balance Sheet M&A) The Board proposes the addition of a
new BPC (FR Y-14A, Schedule F) sub-schedule, “Pro Forma Balance Sheet M&A,” to be
submitted annually, beginning with the reports as of December 31, 2017, by any firm reporting a
business plan change as defined on the existing Schedule F. The items on the sub-schedule
would consist of items on Schedule A.1.b (Balance Sheet) of the FR Y-14A, Schedule A
(Summary) and would complement the information already collected on the FR Y-14A,
Schedule F (BPC). Currently, the post-acquisition fair value of the asset is collected on the
existing FR Y-14A Schedule F, but no information on the pre-acquisition book value of the
asset, purchase accounting adjustments, or fair value adjustments is collected.
The inclusion of the proposed “Pro Forma Balance Sheet M&A” sub-schedule would
standardize the collection of pre-acquisition book value, purchase accounting adjustments, and
fair value adjustments data, on a granular level, thereby allowing for improved validation of
merger and acquisition accounting. While certain data regarding purchase accounting and fair
value adjustments are available in the supporting documentation submitted by respondents, the
granularity, structure, and amount of information provided is inconsistent across firms. The
Board expects that the incremental burden of this new sub-schedule should be minimal, given
that the pro forma information that would be required is related to what a firm must submit in its

8

application for regulatory approval and that the data items would be similar to those collected on
the existing Balance Sheet sub-schedule. In addition, the standardized collection of this
information on a new sub-schedule, which would only be completed in the case of a merger or
acquisition, should limit ad hoc follow-up during the CCAR quarter.
With the addition of the aforementioned sub-schedule, the Board proposes that the
existing BPC data collection be renamed to “Post Acquisition BPC” and become a sub-schedule
(Schedule F.1) of the FR Y-14A, Schedule F.
FR Y-14A, Schedule G (Retail Repurchase Exposures)
As communicated on February 3, 2017, in a press release regarding “Enhancements to
Federal Reserve Models Used to Estimate Post-Stress Capital Ratios” the Board notified firms of
key enhancements to certain aspects of the Board’s models.16 Specifically, in an effort to better
align the operational risk and mortgage repurchase models, for DFAST 2017, the Board retired
the mortgage repurchase model and used an enhanced operational risk model to capture losses.
In accordance with the shift in modeling these losses, the Board proposes eliminating FR Y-14A,
Schedule G (Retail Repurchase Exposures) from the information collection effective with the
reports with data as of December 31, 2017.
Proposed Elimination of Extraordinary Items
In January of 2015, an amendment (ASU No. 2015-01) to the FASB Accounting
Standards Codification, Income Statement – Extraordinary and Unusual Items (FASB Subtopic
225-30), simplified the income statement presentation through the elimination of the concept of
extraordinary items from generally accepted accounting principles. As a result, the Board
proposes making changes consistent with this amendment to the FR Y-14A and FR Y-14Q
reports. Specifically, references to the term “extraordinary items” would be eliminated from the
FR Y-14A, Schedule A.1.a (Income Statement) and the FR Y-14Q, Schedule H (Wholesale)
forms and instructions, and where appropriate, replaced with “discontinued operations.” This
change would be effective as of March 31, 2018.
FR Y-14Q, Schedule A (Retail)
Effective with the FR Y-14 reports as of December 31, 2017, the Board proposes
modifying the instructions for the FR Y-14Q, Schedule A.3 (Retail - International Credit Card)
to include consumer credit and charge cards reported in FR Y-9C, Schedule HC-C, line item 6.d
in addition to those included in Schedule HC-C, line item 6.a. The discrepancy in line item
references relates to recently updated guidance regarding the reporting of charge cards on the
FR Y-9C. These modifications would eliminate unintended differences in reporting that recently
arose between the FR Y-14 and the FR Y-9C data series.

See “Enhancements to Federal Reserve Models Used to Estimate Post-Stress Capital Ratios.” (February 3, 2017),
available at: https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20170203a1.pdf.
16

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FR Y-14Q, Schedule C (Regulatory Capital Instruments)
The Board proposes minor changes to the FR Y-14Q, Schedule C (RCI) to clarify the
reporting of certain information within the existing items on the schedule. The reporting of this
information has been inconsistent across firms, and the modification of existing guidance in the
instructions would seek to improve firms’ understanding of where to report these data and
information. Both changes would be effective with reports as of December 31, 2017.
First, the Board proposes enhancing the instructions for the “Comments” field on
Schedule C.1 (as of Quarter End), C.2 (Repurchases and Redemptions during the Quarter), and
C.3 (Issuances during the Quarter). Currently, the instructions for Columns K and AA,
respectively, note only that firms should provide any supporting information, without any
indication of what types of information are expected. The proposal would modify the
instructions for the comments column to specify that firms should indicate within the comments
how the amounts reported on these sub-schedules tie back to amounts approved in the firm’s
capital plan.
Finally, the Board proposes adding three additional types of instruments to be reported in
Column C (Instrument Type) on Schedules C.1, C.2 and C.3 to capture issuances of capital
instruments related to employee stock compensation (e.g., de novo common stock or treasury
stock), changes in a firm’s Additional Paid in Capital (APIC) related to unvested employee stock
compensation, and changes in an IHC’s APIC through the remission of capital to a foreign
parent.
The first additional instrument type will be added to capture regulatory capital associated
with employee stock compensation (Common Stock – Employee Stock Compensation) that is
currently grouped under “Common Stock (CS)”. Additionally, two new instrument types will be
added to capture changes in APIC associated with employee stock compensation (APIC –
Employee Stock Compensation) and with remissions of capital to a foreign parent entity (APIC –
Foreign Parent) of the respective IHC. These changes would provide for a more complete view
of regulatory capital, clarify the type of instruments to be captured on this schedule, allow for
more precise reporting, and track the accrual of employee stock compensation. For U.S. IHCs,
the changes would allow the Board to measure and monitor capital that a U.S. IHC remits to the
foreign parent through mechanisms other than common stock dividends. The instructions also
would be updated to indicate the expected reporting of these items.
FR Y-14Q, Schedule F (Trading)
For the March 31, 2018, submission, the Board proposes modifying the breakouts of
vintage years on Schedule F.14 (Securitized Products) to be relative to the reporting date rather
than in specified years. The report included the current breakouts of vintage years since the
report’s inception and, because they are static breakouts, they have since become outdated. This
change would result in no structural changes to the reporting form.

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FR Y-14Q, Schedule H (Wholesale)
The Board proposes several changes to the FR Y-14Q, Schedule H (Wholesale), as
outlined below, all of which would be effective with the March 31, 2018, report date. These
changes include the modification or clarification of certain item definitions and allowable values
within those schedules.
Recent comments and questions provided by respondents via the FR Y-14 frequently
asked questions process (FAQs) resulted in several suggestions to refine or modify the
instructions for Schedules H.1 and H.2 (Corporate and CRE, respectively). Respondents
indicated that the Disposition Flag and Credit Facility Type fields on the FR Y-14Q Schedules
H.1 and H.2 do not provide reporting options to capture commitments to commit that expire.
The Board agrees there is currently no way to report or identify commitments to commit within
the current reporting structure. Therefore, in response to this feedback, the Board proposes
expanding the Disposition Flag (Schedule H.1, Corporate, Item 98, and Schedule H.2, CRE, item
61) and Credit Facility Type (Schedule H.1, Corporate, Item 20) to include an option for
commitment to commit. These changes would allow respondents to report, and the Board to
identify, commitments to commit.
The Board has also identified two other areas of the instructions for Schedules H
(Wholesale) that require modification to align with existing standards or to address gaps in
reporting. First, the Board proposes updating the instructions for the ASC 310-30 item
(Schedule H.1, Corporate, item 31 and Schedule H.2, CRE, item 47) to be consistent with
purchase credit impaired (PCI) accounting standards and terminology. While the ASC 310-30
field already exists, the instructions, as currently written, are not clear, and the proposed changes
should improve consistency of reporting and availability of information regarding PCIs with
minimal additional burden.
Finally, the Board proposes modifying the Participation Flag field (Item 7) on Schedule
H.2 (CRE) to be mandatory rather than optional. The Participation Flag indicates if a CRE loan
is participated or syndicated among other financial institutions and if it is part of the Shared
National Credit Program. Currently, the item Participation Interest (Item 59) on Schedule H.2
(CRE) is mandatory, but the Participation Flag is optional, which leads to gaps in reporting of
information regarding these loans and an inability to match loans across institutions. Changing
the Participation Flag field to mandatory would also align with the treatment of these items on
the FR Y-14Q, Schedule H.1 (Corporate). Almost all reporting firms already choose to report
the participation flag field. Therefore, the Board expects the information is readily available and
the overall impact of this change should be minimal in terms of the information reported by most
firms.
FR Y-14Q, Schedule J (FVO/HFS)
Effective with the FR Y-14 reports as of December 31, 2017, the Board proposes
modifying the instructions for the FR Y-14Q, Schedule J, Table 1, item 7, Credit Card Loans
(Not in Forward Contracts) by expanding the scope of the definition for this item. Currently, this
line item includes the unpaid principal balance (column A) and carrying value (column B) for

11

extensions of credit to individuals for household, family, and other personal expenditures arising
from credit cards, as defined in the FR Y-9C, Schedule HC-C, item 6.a. Although small and
medium enterprise (SME) and corporate cards are not broken out or separately defined on the
FR Y-9C, they are broken out and separately defined across several schedules of the FR Y14
reports, creating a reporting gap. The proposed change would expand the scope of the FR Y14Q, Schedule J, Table 1, item 7, to include the unpaid principal balance and carrying value of
SME and corporate cards, as defined in the FR Y-14Q, Schedule M.1 (Balances). To the extent
that Schedule J, Table 2 references definitions associated with Table 1, the change in definition
would apply to Table 2 as well.
In addition to these substantive changes to the instructions, the Board proposes
incorporating clarifying changes to other line items in Schedule J to address typographical errors
and eliminate some unnecessary language as outlined in the draft instructions associated with
this proposal.
FR Y-14Q, Schedule L (Counterparty)
The Board proposes several changes to the FR Y-14Q, Schedule L (Counterparty) as
outlined below. All of the changes would be effective with the March 31, 2018, report date
except for the collection of information related to additional or offline reserves, which will be
collected with the reports with data as of December 31, 2017. These modifications include
changing the ranking methodology of information collected on certain sub-schedules,
consolidating certain existing tables, and collecting new information. Although the collection of
new information creates additional burden on respondents, the Board anticipates these changes
would enhance supervisory modeling by allowing for the reporting of more detailed, consistent
information and would facilitate a more effective collection of the counterparty exposures in
XML since its transition in 2016.
Two changes would seek to simplify the ranking required for reporting positions and
address questions and feedback received regarding ranking methodology. First, the ranking
methodologies for Schedules L.5 (Counterparty – Securities transactions profile, top 25
counterparties) and L.6 (Counterparty – Derivatives profile, top 25 counterparties) would be
modified to require the top 25 counterparties to be reported as ranked by gross current exposure
and net current exposure for the four quarterly unstressed submissions to simplify the ranking
required. The ranking for the stressed/CCAR submission would remain unchanged. Second, the
currently separate collections of counterparties as ranked by derivatives and securities financing
transactions (SFTs), respectively, would be combined to be one collection of counterparties that
would be reported according to all ranking methodologies to simplify the reporting structure.
The schedules with asset category-level information, L.5.2 (Counterparty – SFT assets) and
L.6.2 (Counterparty – Derivative assets), would remain in their current structure.
Consistent with the change proposed to the FR Y-14A, Schedule A.5 (Counterparty),
additional or offline CVA reserves would be required to be reported according to five reserve
type categories, notably FVA, on the FR Y-14Q, Schedule L.1e (Counterparty - Aggregate
derivative data by ratings and collateral), similar to information previously collected on an ad
hoc basis.

12

Finally, the proposal would require the reporting of notional amounts and weightedaverage time to maturity for positions included on Schedules L.1 (Counterparty – Derivatives
profile, by counterparty & aggregated across counterparties) and L.6 (Counterparty – Derivatives
profile, top 25 counterparties). This information would support firm-provided unstressed and
stressed reported exposure amounts.
The Board also proposes additional clarifications to this schedule as described in
consultation outside the agency section below.
FR Y-14Q, Schedule M (Balances)
In line with the changes to the FR Y-14Q, Schedule A.3 (Retail – International Credit
Cards), the Board proposes modifying the instructions and the form for the FR Y-14Q, Schedule
M (Balances). The proposal would update the FR Y-9C references in certain FR Y-14 items to
align these items with the reporting of charge cards on the FR Y-9C report, in line with recently
updated guidance regarding the reporting of charge cards. Specifically, the instructions for
Schedule M.1 (Quarter-end Balances), line item 3.b (Charge cards) will be modified to also
include charge card loans to consumers included in FR Y-9C, Schedule HC-C, line item 6.d
(Other consumer loans) (where 6.d replaces 9.b.(2) (All other loans)). Similarly, on the form for
Schedule M.2 (FR Y-9C Reconciliation), line item 3.b under Charge cards will be modified to
reflect charge card loans reported in FR Y-9C, Schedule HC-C, line 6.d instead of line 9.b.(2).
Proposed Revisions to the FR Y-14M
The proposed revisions to the FR Y-14M consist of adding a line item to collect the
RSSD ID (the unique identifier assigned to institutions by the Board) of any chartered national
bank that is a subsidiary of the BHC and that is associated with a loan or portfolio reported, and
add a line item to collect the month-ending balance for credit card borrowers. Both items would
be effective for reports as of March 31, 2018. The actual burden associated with reporting the
proposed items is expected to increase only minimally, as the OCC previously collected the two
items from a limited number of firms and supplement the monthly retail schedules collected by
the Board. The addition of the items would allow the firms to submit a single monthly data set
that both the Board and OCC could use rather than requiring separate, potentially overlapping
reporting. This approach, which was recommended by a commenter to a proposed OCC data
collection, would be less burdensome than requiring firms to revert to submitting multiple
collections.17
Schedules A, B, D (First Lien, Home Equity, and Credit Card)
For reports as of March 31, 2018, the Board proposes adding an item to collect the RSSD
ID (the unique identifier assigned to institutions by the Board) of any chartered national bank
that is a subsidiary of the BHC and that is associated with a loan or portfolio reported on the
FR Y-14M schedules. This identifier would allow for clearer mapping of exposures and

17

See 80 FR 35739 (June 22, 2015).

13

understanding the sources of risk. It would also allow for segmentation of loans and portfolios
by each national bank charter if a holding company owns multiple national bank charters.
The Board also proposes additional clarifications to these schedules as described in
consultation outside the agency section below.
Schedule D (Credit Card)
For the report as of March 31, 2018, the Board proposes breaking out the total
outstanding balance reported on Schedule D (Credit Card) into two items: Cycle-Ending Balance
(existing item 15) and Month-Ending Balance. Currently, the instructions request that firms
report the total outstanding balance for the account at the end of the current month’s cycle (i.e.,
Cycle-Ending Balance). The total balance outstanding on the account as of the month-end
reporting date is reported only if cycle ending balance is not available. The Board anticipates
both cycle-end and month-end balances are readily available and maintained by firms and these
items had previously been part of the credit card-related collection of the OCC. Collection of
these two distinct items would distinguish between types of borrowers with varying risk
characteristics and allow for a more detailed evaluation of company-run stress test results. The
addition of the month-ending balance item would replace the Cycle Ending Balance Flag (item
16), which would be eliminated.
Attestation
The Board will modify the attestation requirement as follows:






FR Y-14A/Q (annual submission): for both LISCC U.S. IHCs and BHCs subject to the
FR Y-14 attestation requirement, the attestation associated with the annual submission
(i.e., data reported as of December 31, including the global market shock submission18)
will be submitted on the last submission date for those reports, typically April 5 of the
following year. For example, all of the FR Y-14Q schedules due 52 days after the as of
date (typically mid-February), all of the FR Y-14A schedules due April 5, and the trading
and counterparty schedules due on the global market shock submission date (March 15 at
the latest) will be due on the latest of those dates, the annual submission date for the
FR Y-14A report schedules (April 5).
FR Y-14M: for those firms that file the FR Y-14M reports, the three attestations for the
three months of the quarter will be due on one date, the final FR Y-14M submission date
for those three intervening months. For example, the attestation cover pages and any
associated materials for the FR Y-14M reports with January, February, and March as of
dates will be due on the data due date for the March FR Y-14M. Note that one attestation
page per monthly submission is still required.
FR Y-14Q: the FR Y-14Q attestation for the three remaining quarters (Q1, Q2, and Q3)
will continue to be submitted on the due date for the FR Y-14Q for that quarter.

18

As outlined in Sections 252.144 (Annual Stress Tests) of Regulation YY (12 CFR 252), the as-of date will be
October 1 of the calendar year preceding the year of the stress test cycle to March 1 of the calendar year of the stress
test cycle and will be communicated to the BHCs by March 1st of the calendar year.

14

The instructions and cover pages will be updated to clarify and align with the submission
dates.
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 FR Y-9C; 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.
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 Board.
Schedules and Sub-Subschedules

Submission Date
to Board

Data as-of-date
Semi-annual Schedules

Summary,
Macro Scenario




December 31st.
June 30th.

Retail Repurchase
Exposures




December 31st.
June 30th.



April 5th of the following
year.
 October 5th of the same year.
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 June).

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

December 31st.
Data as of a specified date
in the first quarter that
would be communicated
by the Board.19

19



April 5th of the following
year.



April 5th.

See 12 CFR 252.14(b)(2). The as-of date will be between January 1st and March 1st of that calendar year and
will be communicated to the BHCs by March 1st of the calendar year. BHCs 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. In February 2017, the Board finalized modifications to the capital
plan rule extending the range of dates from which the Board may select the as-of date for the global market shock
to October 1 of the calendar year preceding the year of the stress test cycle to March 1 of the calendar year of the
stress test cycle Federal Register (82 FR 9308 (February 3, 2017)).

15



Counterparty

Regulatory Capital
Instruments

Data as-of December
31st.




Schedules

Original submission: Data are due
April 5th of the following year.
Adjusted submission: The Board
will notify companies at least 14
calendar days in advance of the
date on which it expects
companies to submit any adjusted
capital actions.
 Incremental submission: At
the time the firm seeks
approval for additional capital
distributions (see 12 CFR
225.8(g)) or notify the Board
of its intention to make
additional capital distributions
under the de minimis
exception (see 12 CFR
225.8(g)(2)).

Submission Date
to Board

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

Trading Schedule
Counterparty Schedule

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.
For all other quarters, the
as-of date would be the
last day of the quarter,
except for firms that are

16

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):
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

required to re-submit
their capital plan.
For these firms, the as-of
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

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.

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 resubmitted capital plan is due,
including any extensions.
FR Y-14M (Monthly Filings)
Data as of the last
 By the 30th calendar day of
business day of each
the following month.
calendar month.

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, IHCs, and nonbank financial companies supervised by the Board are subject to enhanced
risk-based 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.
Consultation Outside the Agency
On December 9, 2016, the Board hosted a meeting with respondents and presented at a
high-level the proposed changes to these reports.

17

On June 9, 2017, the Board published an initial notice in the Federal Register
(82 FR 26793) requesting public comment for 60 days on the proposal to extend, with revision,
the FR Y-14 reports. The comment period for this notice expired on August 8, 2017. The Board
received eight comment letters addressing the proposed changes: three from industry groups
(The Financial Services Roundtable, The Clearing House, The Institute of International
Bankers), and five from U.S. IHCs that file the FR Y-14 reports. Most comment letters focused
on the proposed modifications to the global market shock. Commenters requested that the Board
reconsider applying the global market shock to U.S. IHCs at this time. In lieu of the proposed
threshold, commenters recommended a number of alternative approaches to achieve what they
indicated would be a more appropriate application of the global market shock, such as further
tailoring the threshold based on risk, size, or complexity. Commenters suggested that if the
Board were to adopt the modifications to the global market shock, the implementation timeline
should be delayed and provide for a gradual phase-in of both the global market shock and
associated FR Y-14 reporting requirements, including for BHCs or U.S. IHCs that subsequently
cross the thresholds for application of the GMS in future quarters.
Two commenters also addressed the proposed changes to the FR Y-14 information
collection. Those commenters expressed support for many of the clarifying and burden reducing
changes, but posed clarifying questions on the proposed instructions, forms, or reporting
requirements for those items. Commenters offered alternatives to or suggestions for modifying
or clarifying certain proposed changes, particularly surrounding the proposed modifications to
the FR Y-14Q, Schedule H (Wholesale) and Schedule L (Counterparty), and recommended that
the Board delay the effective date of several of the proposed modifications. Both commenters
requested the elimination of additional FR Y-14 schedules or sub-schedules.
The Board also received comments outside of the scope of this proposal regarding (1)
historical resubmission of the FR Y-14Q, Schedule A.2 (Retail - U.S. Auto), (2) timing of release
and content of technical instructions, (3) the Q&A (previously known as the FAQ) process, (4)
the FR Y-14 attestation requirement, and (5) the removal of additional schedules or subschedules.
The following section includes a detailed discussion of aspects of the proposed FR Y-14
collection for which the Board received substantive comments and an evaluation of, and
responses to the comments received. Where appropriate, responses to these comments and
technical matters are also addressed in the attached final FR Y-14A/Q/M reporting forms and
instructions.
Proposed Revisions to the FR Y-14A/Q/M
Proposed Global Market Shock Modifications
The global market shock currently applies to a firm with a four quarter average of total
consolidated assets of $500 billion or more. The proposal would have modified the definition of
a firm with “significant trading activity” for purposes of determining applicability of the trading
and counterparty components of the supervisory and company-run stress tests (“global market
shock”) and associated regulatory reports. As noted, the proposal would have revised the

18

definition of “significant trading activity” to include a firm that (1) has aggregate trading assets
and liabilities of $50 billion or more, or aggregate trading assets and liabilities equal to 10
percent or more of total consolidated assets, and (2) is not a “large and noncomplex firm” under
the Board’s capital plan rule. The proposed changes were designed to better align the threshold
with the risk profile of firms subject to the stress test rules.
Commenters recommended various modifications to the proposed threshold. For
instance, commenters recommended that the Board adopt a threshold based on the size, risk
profile, or systemic importance of trading activities at the covered companies. Commenters
noted that the modified threshold would scope in firms that have materially smaller trading
activities and smaller systemic footprints than the firms currently subject to the global market
shock. Some commenters noted that applying the global market shock to additional firms, and
thereby increasing capital requirements for these firms, could disincentivize these firms to invest
in their U.S. lending and securities businesses.
The global market shock is a key element of the Dodd-Frank Act stress tests. The DoddFrank Act requires the Board to conduct annual analyses of whether bank holding companies
with total consolidated assets of $50 billion or more have the capital necessary to absorb losses
as a result of adverse economic conditions and to direct those firms to conduct stress tests under
baseline, adverse, and severely adverse conditions. The Board’s regulations provide that the
Board will issue scenarios on an annual basis, and indicates that firms with “significant trading
activity” (as identified in the Capital Assessments and Stress Testing report (FR Y-14)) may be
required to include a trading and counterparty component in its stress test.
The Board’s Policy Statement on Scenario Design describes how the Board develops the
supervisory scenarios, including the global market shock, and why the global market shock is
important for firms with significant trading activity. As described in the Policy Statement, the
macroeconomic severely adverse scenario is designed to reflect conditions that characterize postwar U.S. recessions, and does not capture the effects of a sudden market dislocation. The pattern
of a financial crisis, characterized by a short period of large declines in asset prices, increased
volatility, and reduced liquidity of higher-risk assets is a familiar and plausible risk to capital.
To the extent a firm’s trading activity is sufficiently large, or represents a sufficiently large
percentage of the firm’s assets, the trading shock is necessary to adequately evaluate whether the
firm has capital necessary to absorb losses and withstand stressful conditions.
The proposed measure was intended to provide a simple measure of the significance of a
firm’s trading activity to its operations. The proposed threshold would have represented a level
of trading exposure that would be material to the capital of the firms subject to the global market
shock. For example, unlike most banking book activities, losses stemming from trading activity
potentially could be larger than the total size of on-balance sheet trading assets, for example, for
derivatives exposures.
As noted by commenters, the modified threshold would include firms with smaller
trading activities than the firms currently included by the $500 billion in total consolidated assets
threshold. However, the proposed revisions were designed to capture the materiality of a firm’s
trading activities to its operations, as well as the absolute size of a firm’s trading activities.

19

While the application of the global market shock may require a higher level of capital to meet
post-stress regulatory minimums, this capital would be related to the losses arising from the
firm’s trading activities under stress. As such, the application of the global market shock would
help to ensure that when the U.S. IHCs look to expand their U.S. lending and securities
businesses, the firms are holding capital commensurate with the market risk associated with
these exposures and activities.
In addition, commenters argued that the global market shock should be modified as
applied to U.S. IHCs. For instance, commenters recommended that the Board modify the
definition of “trading activity” to exclude hedging positions booked outside of the United States.
Another commenter argued that U.S. IHCs have less flexibility to respond to a negative outcome
in CCAR as many IHCs have little or no planned capital distributions to reduce in the limited
adjustment to planned capital actions.
As noted, the proposal would have applied the same definition of significant trading
activity standard to U.S. IHCs and U.S. BHCs. The stress testing regime is designed to measure
the ability of the U.S. IHC to maintain operations during times of stress. In stressful
circumstances, each U.S. IHC is expected to continue operations based on its own capital
position, without relying on hedges overseas. Additionally, to the extent that a firm is unable to
maintain capital levels above all minimum capital requirements even when it has little or no
capital distributions, it should consider seeking a capital infusion.
Commenters also provided views on the measurement of trading activities. For instance,
commenters recommended that the Board take into account the risks and purposes of trading
activities, such as excluding certain types of assets like U.S. Treasuries.
Adopting a significant trading activity threshold that excluded certain types of trading
assets, such as U.S. Treasuries, could be inconsistent with the purposes of the global market
shock. The global market shock estimates projected profit and losses associated with repricing
trading exposures based on a large instantaneous shock to risk factors. The resulting impact to
capital is a reflection of market risk, not credit risk, and U.S. Treasuries could generate market
losses, such as through changes to interest rates. In addition, all else equal, a firm with safer
trading activities will have smaller losses in the global market shock than a firm that engages in
riskier trading activities.
For these reasons, the Board is finalizing the same definition of global market shock
threshold as was proposed. The global market shock is applicable to any firm subject to the
supervisory stress test that (1) has aggregate trading assets and liabilities of $50 billion or more,
or aggregate trading assets and liabilities equal to 10 percent or more of total consolidated assets,
and (2) is not a “large and noncomplex firm” under the Board’s capital plan rule.
In addition to modifications to the threshold itself, commenters noted that tailoring the
reporting collection would allow the Board to estimate the losses associated with the global
market shock while minimizing reporting burden on firms with smaller and less complex trading
activity. In this regard, commenters recommended that the Board adopt an additional threshold
for firms with smaller or less material trading exposures where only a subset of FR Y-14Q,

20

Schedule F (Trading) data collection would apply. Alternatively, commenters recommended
setting materiality thresholds for individual lines or sub-schedules on the trading schedule.
Notably, the proposal adopted a threshold that was significantly higher than the
materiality threshold for other FR Y-14 schedules, generally $5 billion or 5 percent of tier 1
capital for firms that are not large and noncomplex. The higher materiality threshold in the
proposal reflected the Board’s intention to apply the global market shock only to firms with
significant trading activities that pose a potential risk to capital. Additionally, by excluding
noncomplex firms from the global market shock, the proposal did tailor the application to only
those firms that are larger and more complex.
Introducing additional materiality criteria would create additional complexity in reporting
thresholds and potentially require different scenarios or models to estimate trading losses. If a
firm does not have exposure to particular risk factors, it can report a zero for that item on the
trading schedule. However, if a firm does have sensitivity to that risk factor it would be
inappropriate not to estimate the resulting profit and loss stemming from that exposure in the
global market shock. As such, the final rule does not introduce an additional materiality
threshold with tailored reporting requirements.
Commenters also recommended that, as an alternative form of tailoring, the Board could
revise the FR Y-14Q Schedule F and L (Trading and Counterparty collections) to require smaller
firms to file the trading schedule less frequently, such as one time a year as of the date of the
supervisory stress test. Commenters noted that this would reduce the reporting burden associated
with participating in the global market shock for firms with smaller trading operations.
The frequency of the collection of trading data is consistent with other FR Y-14
schedules and necessary for running of the stress tests. For instance, the Board collects data on
credit cards and mortgages monthly and data on securities, other loans, and revenues quarterly.
Trading exposures can evolve rapidly, especially relative to these banking book assets. Firms
with material trading exposures produce reports and run internal stress tests far more frequently
than once a quarter, usually at least weekly. As such, the firms subject to the global market
shock should be able to produce information on their trading exposures once a quarter, allowing
the Board to analyze the risks of their trading book and the evolution of those risks over the year.
Further, collecting a time series of these data at least quarterly is important to the stress test to
allow the Board to follow trends and examine the volatility of each respective firm’s data.
Therefore, the frequency of reporting the FR Y-14 Trading and Counterparty schedules is being
finalized without further modification.
Commenters also requested additional support for the proposed threshold, notably the
impact on capital from the proposal. Based on publically available data from the stress test
exercises from 2012 through 2017, on average, each global market shock firm experienced losses
under the severely adverse stress scenarios equivalent to 4.8 percent of trading exposure on the
as of date of the supervisory stress test. As of June 30, 2017, 4.8 percent of trading exposure
would be equivalent to about 14.3 percent of tier 1 capital, on average, for the new participants in
the global market shock.

21

Ultimately, the impact on capital under the proposal would be a function of the trading
exposures of each covered firm. Notably, many commenters indicated that their trading
exposures were significantly less risky than the trading exposures of the firms that currently
participate in the global market shock, which could make estimating the impact of the proposal
based on those exposures unrepresentative. Additionally, since 2014, disclosed trading losses
have also included the impact of the large counterparty default scenario component, which is not
a part of this proposal. As such, this impact analysis may overstate the impact of the proposal on
a firm’s capital.
In addition to the suggestion for further tailoring the global market shock requirement,
commenters expressed concerns regarding transparency and the manner of notification
surrounding the proposed changes to the global market shock threshold. Specifically,
commenters stated that given the perceived significance of the changes and aforementioned
impact to regulatory capital, the modifications should not have been proposed as a modification
to the FR Y-14 information collection. As previously noted, the stress test rules indicate that the
Board will specify the definition of significant trading activity in the FR Y-14.20 Moreover, the
Board invited public comment on the proposed changes. For example, firms had the opportunity
to comment for sixty days, Federal Reserve staff met with commenters to discuss their
comments, and the Board considered and is responding to these comments.21
One commenter recommended that in the context of firms newly subject to the global
market shock, the Board should clarify the treatment of losses on the same trading positions
between the instantaneous shock and the Pre-Position Net Revenue (PPNR) nine quarter
projections as outlined in the CCAR instructions. The commenter highlighted the difficulty in
identifying identical positions when the as-of date for the global market shock is different from
that of the other nine-quarter projections, including PPNR.
The global market shock is generally intended to be an add-on component of the stress
scenarios that is independent of a firm’s PPNR projection process, with the exceptions for
identical positions noted in the CCAR instructions. Per the CCAR 2017 instructions, firms have
the option, but are not required, to demonstrate that identical positions are stressed under both
the global market shock and supervisory macroeconomic scenario and, if so, may assume
combined losses from such positions do not exceed losses resulting from the higher of losses
See 12 CFR 252.54(b)(2)(i). The Board’s stress test rules require companies to submit data necessary for the
Board to conduct a supervisory stress test. See 12 CFR 252.45(a)-(b). In the case of companies with significant
trading activities, such data includes data necessary for the Federal Reserve to derive pro forma estimates of losses
and revenue related to the global market shock. In addition, the capital plan rule (12 CFR 225.8), which applies to
U.S. IHCs pursuant to 12 CFR 252.153(e)(2)(ii), requires companies to provide the Federal Reserve with
information regarding the amount and risk characteristics their on- and off-balance sheet exposures, including
exposures within the company’s trading account, other trading-related exposures (such as counterparty-credit risk
exposures) or other items sensitive to changes in market factors, including, as appropriate, information about the
sensitivity of positions to changes in market rates and prices. See 12 CFR 225.8(e)(3)(iii).
21
As noted, companies subject to the Board’s stress test rules are required, pursuant to these rules, to submit data
necessary for the Board to conduct the stress tests, and companies subject to the capital plan rule are required,
pursuant to the capital plan rule, to provide the Federal Reserve with information regarding their trading exposures.
See 12 CFR 225.8(e)(3)(iii), and 12 CFR 252.45(a)-(b). This information, when applied through the global market
shock, facilitates the implementation of the Board’s supervisory stress tests under the stress test rules and the
Board’s review of capital plans under the capital plan rule.
20

22

from either the global market shock or macroeconomic scenario. For example, the Board adjusts
PPNR to account for the global market shock by using a median regression approach for firms
subject to the global market shock to lessen the influence of extreme movements in trading
revenue, and, thereby, to avoid double-counting of trading losses that are captured under the
global market shock. Firms should refer to the CCAR instructions and the Supervisory Stress
Test Methodology and Results document for that year’s exercise for guidance regarding the
treatment of identical positions. For firms that choose to implement their own version of a
market shock, firms have flexibility regarding how to effectively identify and capture their key
risks, including the interaction of the BHC stress scenario market shock and PPNR projections;
therefore, the Board does not intend to provide additional information regarding the double
counting of losses in the described circumstance.
If the Board did adopt the proposed changes modifying the applicability criteria for the
global market shock, commenters recommended the implementation feature a phase-in of the
application of global market shock to new participants and allow for additional time for firms
newly subject to the global market shock to submit the FR Y-14 trading and counterparty
schedules. Commenters stated that the compressed timeframe between finalization and the
effective date would create challenges accounting for the impact of the global market shock on
regulatory capital requirements, and to prepare systems, infrastructure, and processes to file the
associated FR Y-14 data.
Suggestions from commenters for transitioning the initial application of the global market
shock to new participants included a confidential “dry-run” for the 2018 stress test and capital
plan cycle and delaying full application of the global market shock component and public
disclosure until the 2019 cycle. For the associated FR Y-14 data submissions, commenters
requested additional time to submit the data for the reports with data as of September 30, 2017
and December 31, 2017. Finally, commenters requested that any transitions for new participants
apply for any additional firms that become subject to the global market shock going forward.
Although, as noted, the Board is adopting the proposed global market shock threshold
without modification, the Board recognizes the challenges associated with building the systems
necessary to report the data in the trading schedule. Regarding the application of the global
market shock component, under the revised FR Y-14 report, the Board is delaying the
application of the global market shock to firms that would become newly subject to it until the
2019 DFAST/CCAR exercise. However, assessing potential losses associated with trading
books, private equity positions, and counterparty exposures for firms with significant trading
activity is a critical component of stress testing and capital planning. Therefore, for the 2018
DFAST exercise, pursuant to the stress test rules, the materiality of trading exposures and
counterparty positions to U.S. IHCs may warrant applying an additional component to firms that
meet such criteria. The components would serve as an add-on to the economic conditions and
financial market environment specified in the adverse and severely adverse scenarios. The
Board will notify any affected firms in writing of the additional components or the additional
scenarios to be included.22

22

See 12 CFR 252.54(b)(4)(i).

23

In consideration of the recommendations outlined by commenters regarding the
submission of FR Y-14Q, Schedule F (Trading) and Schedule L (Counterparty), the Board
agrees that a delay in the initial data submission date would facilitate improved data quality.
Although commenters indicated that submitting data as of September 30, 2017, would be
feasible with a delay in the submission date, firms joining the reporting panel will not be
required to report the FR Y-14 trading and counterparty schedules until the December 31, 2017,
as-of date. Given the alternative approach to inclusion of trading and counterparty activities for
these firms for stress testing in 2018 the Board will provide firms with additional time to submit
the FR Y-14 data with the objective of allowing for additional opportunities for submitting test
files and achieving higher data quality. Specifically, the FR Y-14 trading and counterparty for
the reports as of Q4 2017 will be due May 1, 2018. In addition, there will also be a delayed
submission date for the reports as of Q1 2018, which will be due June 30, 2018. For the reports
Q2 2018 forward, the data will be due as outlined in the FR Y-14 instructions.
The Board understands the need for additional time for the initial application of the
modified global market shock threshold. If firms that were already subject to stress testing and
FR Y-14 reporting and subsequently cross the global market shock threshold going forward,
firms would presumably have been below but close to the threshold for a considerable period of
time and would have been aware of the application criteria. This should already provide an
adequate amount of time to anticipate meeting and preparing to comply with requirements. In
addition, firms already have a phase-in period related to the establishment of a U.S. IHC and
application of the capital plan rule. Therefore, for firms that cross the global market shock
threshold in the future, the Board does not anticipate providing any further delay in applicability.
In the context of the recommendation for a transition period for applicability of the
modified global market shock threshold, one commenter expressed that the resources required
for actual implementation of the global market shock would be multiples of the estimated
ongoing resources requirements for the schedule, estimated at 9,736 hours per firm. The Board
continues to invite comments on the burden estimates and strives to accurately reflect the effort
to compile and submit data on the FR Y-14 reports. The commenter provided no further
information on how or why the Board should adjust the burden estimates and the Board received
no other comments on the burden estimates as related to the global market shock threshold. To
capture the additional effort necessary to begin reporting the FR Y-14 trading and counterparty
schedules, the Board will adjust the implementation burden to recognize the upfront burden for
the six firms newly subject to the global market shock and, specifically associated FR Y-14
reporting requirements, to begin filing the schedules.
Commenters also noted that the proposal did not address whether U.S. IHCs that become
subject to the global market shock would also become subject to the large counterparty default
scenario. Specifically, commenters requested that if the Board’s intention is to apply the large
counterparty default scenario component to the firms covered under the modified global market
shock threshold, they should conduct a quantitative impact study and/or allow for public
comment. If the Board does apply the large counterparty default scenario component to firms
newly subject to global market shock, commenters requested that it be applied only after
implementation of global market shock or with a phased-in approach similar to that
recommended for global market shock.

24

The large counterparty default scenario component is an add-on component that requires
firms with substantial derivatives or securities financing transaction activities to incorporate a
scenario component into their supervisory adverse and severely adverse stress scenarios. In
connection with the large counterparty default scenario component, subject firms are required to
estimate and report losses and related effects on capital associated with the instantaneous and
unexpected default of the counterparty that would generate the largest losses across their
derivatives and securities financing activities, including securities lending and repurchase or
reverse repurchase agreement activities. As indicated in the stress test rules, the Board will
notify the firm in writing no later than December 31 of the preceding calendar year of its
intention to require the firm to include one or more additional components in its stress test. The
covered firm may request reconsideration with an explanation for why reconsideration should be
granted within 14 calendar days of receipt of the notification. The Board will continue to use
this existing process to apply the large counterparty default scenario component.
Proposed Revisions to the FR Y-14A
The proposed revisions to the FR Y-14A consisted of modifying reported items and
instructions by clarifying the intended reporting of existing items or aligning them with standards
and methodology, adding an item critical to stress test and supervisory modeling, and reducing
burden through the elimination of certain schedules.
Specifically, the Board proposed modifying Summary – Securities (Schedule A) subschedules A.3.a and A.3.c to clarify the reporting of “Credit Loss portion” and “Non-Credit Loss
Portion” information, adding an item to the Summary - Counterparty sub-schedule (Schedule
A.5) to capture Funding Valuation Adjustment (FVA), and eliminating the FR Y-14A, Schedule
D (Regulatory Capital Transitions) and Schedule G (Retail Repurchase Exposures).
Commenters were supportive of these modifications and the final FR Y-14 requirements
implement the modifications as proposed effective for the reports with data as of December 31,
2017.
Comments and clarifying changes were received on the proposed addition of a subschedule to the FR Y-14A, Schedule F (Business Plan Changes), indirectly related to the
proposed removal of Schedule G (Retail Repurchase Exposures), and the proposed elimination
of the concept of extraordinary items. In some cases, these comments resulted in modifications
to the proposed changes, including delays in the effective date for certain changes to
December 31, 2017, or March 31, 2018. The effective dates and responses to comments are
detailed below.
FR Y-14A, Schedule A (Summary)
One commenter did not comment on the proposal to capture FVA on the FR Y-14A and
FR Y-14Q reports, but recommended clarifications to the FR Y-14A instructions to allow for
consistent reporting of FVA and related activities. First, the commenter recommended that the
Board update the instructions to indicate that firms should report FVA gains and losses for all
supervisory and BHC scenarios. Second, the commenter recommended that the Board update
the instructions to indicate that gains and losses on FVA hedges should be reported on Schedule

25

A.4 (Summary - Trading). The Board has reviewed the suggested clarifications, however
additional analysis is needed surrounding the impact on reporting before updating to the
instructions. The Board will continue to consider the clarifications and will propose changes for
notice and comment or provide additional guidance in the future if appropriate.
FR Y-14A, Schedule F (Business Plan Changes)
Schedule F.2 (Pro Forma Balance Sheet M&A)
Two commenters requested clarification on what information surrounding pro forma
balance sheet mergers and acquisitions the proposed sub-schedule would collect, and one
commenter requested the Board delay the implementation of this new sub-schedule, which was
originally proposed to be effective as of December 31, 2017. Specifically, one commenter
requested clarification as to whether the “Pro Forma Balance Sheet M&A” sub-schedule of the
FR Y-14A, Schedule F (Business Plan Changes) would require respondents to report projections.
The same commenter also requested that the Board provide a minimum of six months to
implement necessary changes to accommodate the proposed sub-schedule.
In the event that a covered company intends to undertake a merger or acquisition, then
the “Pro Forma Balance Sheet M&A” worksheet will require projections, as does the current
FR Y-14A, Schedule F.1 (BPC). The pro forma information required is similar to what a firm
must submit in its application for regulatory approval for the merger or acquisition, and the items
collected on the sub-schedule must sum to the post-acquisition fair value of the portfolio as
reported on the FR Y-14A, Schedule F.1 (BPC). The projection of these additional items should
not pose a significant additional burden for firms that are already projecting a merger or
acquisition for the purposes of reporting the FR Y-14A Schedule F, Balance Sheet worksheet.
This information should be available to the firms that would be required to complete the
schedule, is similarly structured to information reported elsewhere, and would provide valuable
inputs to the DFAST and CCAR exercises, therefore the Board will not delay the effective date
of this change. The final FR Y-14A report implements sub-schedule F.2 (Pro Forma Balance
Sheet M&A) as proposed, effective December 31, 2017.
Another commenter requested that the Board clarify if divestitures would also be
included in the proposed sub-schedule F.2. The Board confirms that divestitures would not be
included in sub-schedule F.2. The commenter also requested that the Board clarify how a firm
would report values associated with M&A activity in the structure of the FR Y-14A, Balance
Sheet as proposed. The Board confirms that a firm would report only the post-acquisition fair
value of an asset or liability onboarded in a merger or acquisition on its projected balance sheet.
The “Pro Forma Balance Sheet M&A” sub-schedule allows firms to report the pre-acquisition
book value, purchase accounting adjustments, and fair value adjustments that resulted in the
post-acquisition fair value reported on the current FR Y-14A, Balance Sheet sub-schedule.
FR Y-14A, Schedule G (Retail Repurchase Exposures)
One commenter requested that the Board clarify if the proposal eliminates the FR Y-14A,
Schedule G (Retail Repurchase Exposures) completely or if the collection of these data would

26

move back to a sub-schedule of the FR Y-14A, Schedule A (Summary) where it was historically
collected. The Board confirms that the collection of data under the FR Y-14A, Schedule G
would be removed and the FR Y-14 would no longer collect these data. Having received no
further comments on the removal of the FR Y-14A, Schedule G, the final FR Y-14 eliminates the
schedule as proposed, effective with the reports with data as of December 31, 2017.
One commenter asked that the Board eliminate the FR Y-14A, Schedule A.2.b (Retail
Repurchase Projections). The commenter noted that this sub-schedule collects similar
information to the FR Y-14A, Schedule G (Retail Repurchase Exposures) indicating the rationale
should also apply for eliminating this annual collection. In addition, commenters cited that large
and noncomplex firms are no longer required to complete the FR Y-14A, Schedule A.2.b (Retail
Repurchase Exposures).
The Board agrees that some of the same reasons for eliminating the FR Y-14A, Schedule
G (Retail Repurchase Exposures) apply to the projection data collection, however notes there are
additional, ongoing uses of these data for which the Board can find alternative inputs. However,
given the schedule’s connection to other components of the FR Y-14A, Schedule A (Summary)
and current reliance on these data for the CCAR and DFAST exercises, firms will still report the
sub-schedule through the reports with data as of December 31, 2017. In response to comment
and in an effort to further reduce burden, the final FR Y-14 eliminates the FR Y-14A, Schedule
A.2.b (Retail Repurchase Projections) with the reports with data as-of March 31, 2018.
Proposed Elimination of Extraordinary Items
Under the proposal, references to the term “extraordinary items” would be eliminated
from the FR Y-14A, Schedule A.1.a (Income Statement) and the FR Y-14Q, Schedule H
(Wholesale) forms and instructions, and where appropriate, replaced with “discontinued
operations” as a result of an amendment (ASU No. 2015-01) to the FASB Accounting Standards
Codification, Income Statement – Extraordinary and Unusual Items (FASB Subtopic 225-30)
effective with the reports with data as of September 30, 2017.
One commenter requested that the Board clarify if firms should aggregate all categories
of Discontinued Operations (revenue, expenses, and provisions) into the proposed field,
Discontinued Operations, on the FR Y-14A, Schedule A.1.a (Income Statement) and
consequently exclude all of those categories from other line items in the Income Statement subschedule. The Board clarifies that the intended reporting of line item 131 in the Income
Statement sub-schedule (historically, “Extraordinary items and other adjustments, net of income
taxes” and now proposed, “Discontinued operations, net of applicable income taxes”) does not
change with the proposed modifications, rather the line item name has been updated to be in-line
with the FR Y-9C, Schedule HI. The definition for this line item references the FR Y-9C,
Schedule HI, item 11 and should still be reported as such under the proposed changes.
Another commenter requested that the Board delay the removal and replacement of the
extraordinary items concept on the FR Y-14Q, Schedule H (Wholesale) until at least March 31,
2018, to allow adequate time for the firms to source and validate the data. In response, the Board
is delaying the effective date of these changes for both the FR Y-14A, Schedule A.1.a (Income

27

Statement) and the FR Y-14Q, Schedule H (Wholesale) to be effective as of March 31, 2018
(i.e., for reports as of June 30, 2018, for FR Y-14A, Schedule A).
Proposed Revisions to the FR Y-14Q
The proposed revisions to the FR Y-14Q consisted of updating certain instructions and
changing the reporting structure and requirements of existing items to further align reported
items with methodology, standards, and treatment on other regulatory reports or within the
FR Y-14 reports, and to enhance supervisory modeling. The proposal would also have added
new items and make a number of changes to the FR Y-14Q, Schedule L (Counterparty). Two
commenters addressed the proposed changes to the FR Y-14Q schedules.
Commenters were generally supportive of and voiced no concerns regarding the
modifications to the FR Y-14Q Schedule A (Retail), Schedule C (Regulatory Capital
Instruments), Schedule J (FVO/HFS), and Schedule M (Balances). These changes are narrow in
scope or clarifying in nature, and are necessary to enhance supervisory information for the
CCAR and DFAST exercises. Therefore, the Board will implement these changes with the
reports with data as of December 31, 2017. There were no substantive comments regarding the
proposed change to the FR Y-14Q, Schedule F (Trading); however, in response to comments, the
Board will extend the effective date of this change until March 31, 2018. Any clarifying
questions have been addressed in the detailed sections.
Regarding the remaining changes to the FR Y-14Q, Schedule H (Wholesale) and
Schedule L (Counterparty), certain modifications to the proposed changes will be made in
consideration of the comments received, including delays in the effective date for certain
changes to December 31, 2017, or March 31, 2018. The effective dates and responses to
comments are detailed below.
FR Y-14Q, Schedule C (Regulatory Capital Instruments)
Under the proposal, the Board would enhance the instructions for the “Comments” field
in all three sub-schedules of the FR Y-14Q, Schedule C (Regulatory Capital Instruments) to
specify that firms should indicate within the comments how the amounts reported on these subschedules tie back to amounts approved in the firm’s capital plan. One commenter requested that
the Board clarify if the “Comments” field in the three sub-schedules should reflect summary
balance variances to the firm’s capital plan by Instrument Type since the capital plans submitted
by firms do not reflect CUSIP-level detail. The Board confirms that firms’ comments in the
FR Y-14Q, Schedule C should reflect summary balance variances by Instrument Type.
Furthermore, if the same comment is relevant across multiple instruments in the firm’s
submission, comments should repeat.
Also under the proposal, additional types of instruments would be added to be reported in
Column C (Instrument Type) on the issuance and redemption sub-schedules to capture issuances
and redemptions of capital instruments related to employee stock compensation (e.g., de novo
common stock or treasury stock), and changes in an IHC’s APIC through the contribution of
capital from a foreign parent or the remission of capital to a foreign parent.

28

One commenter requested that the Board clarify if the firm should report the same CUSIP
in multiple rows or add a character at the end of each CUSIP to uniquely identify each
instrument. The Board confirms that the firm should report the same CUSIP across multiple
rows, provided that a different instrument type is used for each recurrence of the respective
CUSIP. The combination of the CUSIP and the Instrument Type will uniquely identify each
record. If there are duplicate records with the same CUSIP and Instrument Type, a firm should
append a differentiating feature on the end of the CUSIP (e.g., “v1” and “v2”, etc.) and specify in
the comments column that these are in fact swaps on the same CUSIP.23 This guidance will be
added to the instructions. Another comment asked for guidance regarding the intended reporting
of Common Stock with relation to the three proposed instruments. The Board clarifies that firms
should report the remaining amount of common stock after deducting the amount reported in the
new instruments.
Finally, a third comment requested clarification surrounding how a decrease in APIC
should be treated if it resulted from an issuance of common stock from treasury stock. The
Board clarifies that a decrease in APIC as a result of treasury stock being issued at a price lower
than its cost basis (i.e., the accounting amount of the stock held on the firm’s balance sheet) must
not be captured in sub-schedule C.2 (Issuances). Reductions in APIC on sub-schedule C.2
should reflect only instances in which an U.S. IHC remits capital to its foreign parent outside the
context of payment on or redemption of an internal capital instrument. Sub-schedule C.2 does
not capture decreases in APIC resulting from employee stock compensation-related drivers, nor
does sub-schedule C.3 capture increases in APIC resulting from employee stock compensationrelated drivers. The final instructions include these clarifications.
The final FR Y-14 will be updated accordingly and the changes implemented with the
reports with data as of December 31, 2017.
FR Y-14Q, Schedule F (Trading)
One commenter asked that the Board confirm the formatting of the proposed vintage
breakouts on the FR Y-14Q, Schedule F.14 (Securitized Products). The proposed draft
instructions erroneously specified one of the vintage breakouts for the FR Y-14Q, Schedule F.14.
The vintage breakouts should read as follows: “>9Y”, “>6Y and <= 9Y”, “>3Y and <= 6Y”, “<=
3Y”, and “Unspecified Vintage”. The final form reflects the appropriate vintage breakouts. As
noted above, having received no other comments, the final FR Y-14 will implement the revision
as proposed effective with the reports with data as of March 31, 2018.
FR Y-14Q, Schedule H (Wholesale)
The Board proposed expanding the Disposition Flag (Schedule H.1 (Corporate), item 98,
and Schedule H.2 (CRE), item 61) and Credit Facility Type (Schedule H.1, (Corporate), item 20)
to include an option for commitments to commit. Commenters requested that the Board clarify
the expectations surrounding the reporting of the proposed Credit Facility Type field to ensure
accurate reporting and expressed that reporting firms do not always consider “commitment to
commit” as a separate facility type. Commenters also asserted that the concept of netting
23

See FR Y-14 FAQ ID Y140000259.

29

deferred fees of a commitment is not a GAAP or FR Y-9C concept. Commenters requested that
the Board withdraw or defer both of these proposed changes to a later effective date.
The final FR Y-14 includes the expansion of the Disposition Flag (Schedule H.1,
Corporate, Item 98, and Schedule H.2, CRE, item 61) and Credit Facility Type (Schedule H.1,
Corporate, Item 20) to include an option for commitment to commit. However, in response to
comments, the Board is delaying the effective date of this change until the reports with data as of
March 31, 2018. The Board clarifies that firms are already required to report commitments to
commit on both the FR Y-14Q, Schedule H.1 (Corporate) and H.2 (CRE). This improved data is
necessary to adequately capture risk and provide consistent treatment across the portfolio of
firms. In the absence of a clear and explicit reporting requirement, there has been significant
variation in how banks have reported these exposures, including some who have not reported
them at all. As these facilities constitute material exposures for some banks, the improvements
fill important gaps in our assessment of potential losses. The Board further clarifies that firms
should report commitments to commit, as defined in the FR Y-9C, Schedule HC-L (Derivatives
and Off-Balance Sheet Items), on the Wholesale schedules along with all corresponding data
fields. Per the FR Y-14Q, Schedule H.1 (Corporate) and H.2 (CRE) instructions for Origination
Date (H.1, item 18 and H.2, item 10), “For commitments to commit which are not syndicated,
report the date on which the BHC or IHC extended terms to the borrower.” Therefore,
commitments to commit should not have a future origination date.
The Board intended the proposed change in the reporting of Utilized
Exposure/Outstanding Balance (Schedule H.1, Corporate, item 25 and Schedule H.2, CRE, item
3) and Committed Exposure (Schedule H.1, Corporate, item 24 and Schedule H.2, CRE, item 5)
items to clarify reporting. However, in light of comments and questions received, the Board is
not adopting these proposed changes to the FR Y-14.
The Board also proposed updating the instructions for the ASC 310-30 item (Schedule
H.1, Corporate, item 31 and Schedule H.2, CRE, item 47) to be consistent with purchase credit
impaired (PCI) accounting standards and terminology and modifying the Participation Flag field
(Item 7) on Schedule H.2 (CRE) to be mandatory rather than optional.
One commenter questioned how the proposed instructions would result in different
reporting from the current requirements. The Board confirms that the change to the existing
ASC 310-30 field is only meant to clarify reporting of PCIs to improve alignment with GAAP
and may not represent a change in reporting based on a firm’s prior interpretation of the
instructions. The final FR Y-14 implements this change effective with the reports with data as of
March 31, 2018.
Regarding the change of the Participation Flag to mandatory, one commenter expressed
that item 7 and item 59 (Participation Flag and Participation Interest, respectively) of the FR Y14Q, Schedule H.2 (CRE) should remain optional. Commenters cited that the SNC program
status is monitored by agent banks, which are not required to notify participant banks of the
status and therefore, the information is often not available and therefore not reported. Therefore,
the commenter suggests, even if the field becomes mandatory, it should only be mandatory for
agent banks.

30

As stated in the initial Federal Register notice, almost all reporting firms already choose
to report the participation flag field. Therefore, this information does in fact appear to be readily
available in most cases. The Board confirms that intent of the options in the Participation Flag
field are, in conjunction with the SNC Internal Credit Facility ID and Participation Interest,
intended to distinguish whether or not the credit facility is included in the SNC report. The
change will be implemented as proposed, with a delay in the effective date until March 31, 2018.
FR Y-14Q, Schedule L (Counterparty)
The Board proposed several changes to the FR Y-14Q, Schedule L (Counterparty). All
of the changes were proposed to be effective with the September 30, 2017, report date.
Primarily, commenters asked for additional time to incorporate these changes given the
perceived material nature of several of the changes and inconsistencies or ambiguity identified in
the proposed instructions and forms. Firms indicated that the Board would need to provide
further guidance in order for respondents to report the various fields properly. Commenters also
asked several clarifying questions regarding the proposed forms and instructions.
The final FR Y-14 implements the proposed changes to the FR Y-14Q, Schedule L
(Counterparty), but will delay the effective date until March 31, 2018, for all changes except for
the collection of information related to additional or offline reserves, which will be collected
with the reports with data as of December 31, 2017. This should allow reporting firms adequate
time to incorporate the changes with the additional guidance needed to report the requested data
properly. Furthermore, the final forms and instructions include a number of clarifications in line
with the comments, as appropriate, to enhance guidance surrounding the intended reporting.
One commenter noted that the FR Y-14Q, Schedule L.5 (Derivatives and Securities
Financing Transactions (SFT) Profile) sub-schedules do not consistently address requirements
for each scenario or distinguish on the report form for sub-schedule L.5.1 (Derivative and SFT
information by counterparty legal entity and master netting agreement) where internal and
external ratings of counterparties or different currencies should be reported, although subdivided
reporting was proposed. To address this, the final FR Y-14 form for the L.5 sub-schedules will
include a column for severely adverse and adverse scenarios, and the form for sub-schedule
L.5.1 will include columns for both internal and external ratings and currencies in line with the
proposed instructions. The final XML technical instructions will further outline reporting
structure.
Several clarifications were requested regarding the ranking and definition of central
clearing counterparties (CCPs), including what ranking methodology should be used to report on
sub-schedule L.5.2 (SFT assets posted and received by counterparty legal entity and master
netting agreement) and what definition should be used for CCPs. The Board confirms that CCPs
refer to designated central clearing counterparties and will update the instructions to clarify that
all G-7 Sovereigns and CCPs should be reported in addition to the Top 25 counterparties by
Rank 1, 2, 3, 4 (including non G-7s Sovereigns). For counterparties reported on sub-schedule
L.5.2 ranking methodologies 1 and 2 apply. The final FR Y-14 form for the L.5 sub-schedules
will include columns for rank methodology and rank so that firms may clearly report by

31

distinguishing which counterparties are reported for each ranking methodology. The technical
instructions will specify reporting structure details.
Similarly, one commenter noted that the proposed instructions for sub-schedule L.5 did
not specify a ranking methodology for the baseline and stressed scenarios. The Board clarifies
that for unstressed (Non-CCAR) quarters, firms should report all G-7 Sovereigns and CCPs plus
Top 25 non G-7/Non CCP counterparties, ranked by SFT amount posted, SFT net current
exposure, derivatives notional, and derivatives net current exposure. For the CCAR (stressed)
quarter, firms should report all G-7 Sovereigns and CCPs plus Top 25 non G-7/Non CCP
counterparties, ranked by SFT amount posted, derivatives notional amount, SFT FR stressed net
current exposure for each scenario, and derivatives FR stressed net current exposure for each
scenario. The final instructions will be updated to be consistent with this reporting methodology.
One commenter noted the proposed instructions indicate firms should report notional
information and inquired whether respondents should report the notional amounts on the FR Y14Q, Schedule L (Counterparty) net or gross. The Board confirms that respondents should report
the gross amount and the instructions include this guidance. Total notional is the gross notional
value of all derivative contracts on the reporting date. For contracts with variable notional
principal amounts, the basis for reporting is the notional principal amounts at the time of
reporting. The total should include the sum of notional values of all contracts with a positive
market value and contracts with a negative market value.
One commenter asked for clarification regarding the reporting of netting Agreement ID
and Netting Set ID on the FR Y-14Q, Schedule L.5.1 and noted that the form only included a
column for Netting Set ID. The Board clarifies that firms should only report the Netting Set ID
field for both SFTs and derivatives. The final instructions will be updated to reflect this
treatment.
The commenter also asked for clarification regarding the “consolidation of
counterparties” section of the general instructions for the FR Y-14Q, Schedule L. The Board
will clarify these instructions to indicate that firms should report Sovereigns and CCPs at the
entity level and non-Sovereigns and non-CCPs at the consolidated group level. For Sovereigns
and CCPs, firms should report consolidated group/parent level name in the Counterparty Name
field, the consolidated counterparty ID in Counterparty ID field, the counterparty entity ID in the
Netting Set ID field, and the counterparty entity name in the Sub-Netting Set ID field. The
ranking described in this section of the general instructions should be based on the consolidated
Sovereign or CCP and firms must report that rank for each entity. For non-Sovereigns and nonCCPs, firms should report NA in both the Netting Set ID and the Sub-Netting Set ID fields.
Also regarding L.5.1, one commenter asked if certain fields (Agreement Type
(CACNR529), Agreement Role (CACNR530), Netting Level (CACNR532), Legal
Enforceability (CACNR534), Independent Amount (non CCP) or Initial Margin (CCP)
(CACSR551), Excess Variation Margin (for CCPs) (CACSR553), Default Fund (for CCPs)
(CACSR554) were to be reported for both derivatives and SFTs. As proposed, firms should
report these fields for both derivatives and SFTs. The final instructions reflect allowable entries
for these fields applicable to derivatives as well.

32

One commenter indicated that some firms do not collect initial margin and default fund
as part of SFT CCP reporting and that the proposed instructions did not specify if the firms need
to exclude initial margin and default fund contributions from SFT CCP data. The Board clarifies
that initial margin and default fund contribution should only be reported where applicable to SFT
CCP reporting.
One commenter observed that 3 new columns were added to the instructions for the
FR Y-14Q, Schedule L.5.4 (Derivative position detail), but were not included on the form. The
commenter also asked if certain fields (total notional, new notional during the quarter, weighted
average maturity, position MTM and total net collateral) are applicable to CCPs. The Board
confirms that these fields are applicable to CCPs, for sub-schedules L.1.a through L.1.d. The
instructions and forms will be updated accordingly.
The proposed draft instructions asked firms to report Weighted Average Maturity.
Commenters inquired whether, for trades with Optional Early Termination agreements (OETs) or
Mandatory Early Termination agreements (METs), the maturity reporting should take into
account early termination features and whether firms should report effective average maturity
(e.g., to reflect amortizations or prepayments) or only legal maturity. The Board clarifies that
firms should report the average of time to maturity in years for all positions associated with the
reported amount in the item Gross CE, as weighted by the gross notional amount associated with
a given position. For trades with Optional Early Termination (OET), the maturity reporting
should not take into account such early termination features. For trades with Mandatory Early
Termination (MET), however, the maturity reporting should take into account such early
termination features.
One commenter noted some inconsistencies in the instructions, and requested
clarification to central counterparty reporting regarding the house exposures and client
exposures. The Board has reviewed and addressed questions related to central counterparty
reporting outside of this proposal. Firms should refer to the most up-to-date instructions that are
available on the Board’s public website.
Proposed Revisions to the FR Y-14M
The proposed revisions to the FR Y-14M consisted of adding a line item to collect the
RSSD ID (the unique identifier assigned to institutions by the Board) of any chartered national
bank that is a subsidiary of the BHC and that is associated with a loan or portfolio reported, and
add a line item to collect the month-ending balance for credit card borrowers. Both items were
proposed to be effective for reports as of September 30, 2017.
Schedules A, B, D (First Lien, Home Equity, and Credit Card)
Regarding the addition of an item to collect the RSSD ID (the unique identifier assigned
to institutions by the Board) one commenter presented questions regarding what RSSD ID
should be reported and questioned the value of adding a field versus enhancing the existing
“Entity Type” field (fields 129, 207, and 115 of Schedules A, B, and D, respectively). The

33

commenter requested that in light of the required data sourcing and coding changes, the Board
delay the implementation of this item.
The final FR Y-14 implements the collection of the RSSD ID for loans reported on the
FR Y-14M Schedules A, B, and D, but in response to comment will delay the effective date until
the reports with data as of March 31, 2018, and would make certain clarifications to the
collection of these data. The Board continues to support collection of this data element to meet
supervisory needs of the OCC, but understands the complexities involved in making these
changes. Accordingly, the final FR Y-14 implements the collection of the RSSD ID field
beginning with the reports with data as of March 31, 2018, with the clarifications included in the
following section.
One commenter asked that the Board clarify, in Schedules A, B, and D, if loans could be
identified using the existing Entity Type field or RSSD ID contained in the file name rather than
adding a new field. The Board agrees the existing field provides additional information,
however notes that it is not sufficient or comprehensive on its own. The Entity Type field alone
is not sufficient, because for BHCs that have multiple national bank charters, the Entity Type
field does not specify which national bank charter holds a financial interest in the loan.24
Furthermore, the RSSD ID provided in each of the BHC’s file naming conventions is the RSSD
ID of the BHC. The requested additional RSSD ID field is the RSSD ID of the national bank
entity that has a financial interest associated with the loan.
Commenters asked several questions to clarify what RSSD ID respondents should
provide in the proposed field in particular circumstances. Commenters asked if respondents
should report the RSSD ID based on the direct subsidiary or indirect subsidiary for the proposed
field for loans that are held in a chartered national bank that is an indirect subsidiary of the
holding company. For example, if national bank B were an indirect subsidiary of a BHC and a
direct subsidiary of national bank A (which is a direct subsidiary of a BHC). Commenters also
asked if a respondent would ever be required to provide a RSSD ID of a chartered national bank
that is not a subsidiary of the reporting BHC. For example, whether respondents would report
loans serviced by a subsidiary of the BHC but owned by another bank or, if loans are owned by
the BHC but serviced by a third party, whether respondents would report the RSSD ID of the
subsidiary national bank or that of the third-party bank. For loans serviced by a direct subsidiary
of the BHC for a third party entity, commenters asked if the respondent would report the BHC
RSSD ID. Finally, commenters asked for clarification on whether the field should be reported if
the subsidiary of the holding company is a state chartered bank, and not a national bank, and if
so, if the reported RSSD ID should reflect the BHC or the state bank.
In the case of an indirect subsidiary, the respondent should report the RSSD ID of the
national bank that has a financial interest in the loan. For loans that are serviced by a national
bank subsidiary of the BHC but owned by another entity, the respondent should report the RSSD
ID of the national bank subsidiary that services the loan. For loans that are owned by a national
bank subsidiary of the BHC but serviced by another entity, the respondent should report the
RSSD ID of the national bank subsidiary that owns the loan. If a national bank subsidiary of the
24

For the purposes of this notice, a national bank subsidiary is deemed to have a financial interest in the loan if it
owns the loan and/or services the loan.

34

BHC both owns and services the loan, the respondent should report the RSSD ID of the national
bank subsidiary that both owns and services the loan. If no national bank subsidiary either owns
or services the loan, this field should be left blank (null). In all cases, this field either would be
left null or will contain the RSSD ID of a chartered national bank that is a subsidiary of the
reporting BHC. To clarify the intended reporting of the national bank RSSD ID in line with the
proposal and in light of commenters’ questions, the definition of this item within the FR Y-14M
instructions will be updated to include these clarifications.
Finally, commenters questioned whether the RSSD ID field would only affect Loan
Level files (FR Y-14M, Schedules A.1, B.1, and D.1) or if an additional field also be added to
Portfolio Level files (FR Y-14M, Schedules A.2, B.2 and D.2). With the clarifications to the
instructions outlined above, the final FR Y-14 implements the proposed changes for the Loan
Level files (Schedules A.1, B.1, and D.1) effective with the reports with data as of March 31,
2018. The RSSD ID field will not be collected as part of the Portfolio Level files (Schedules
A.2, B.2, and D.2).
Schedule D (Credit Card)
For the reports with data as of September 30, 2017, the Board proposed breaking out the
total outstanding balance reported on Schedule D (Credit Card) into two items: Cycle-Ending
Balance (existing item 15) and Month-Ending Balance. The addition of the month-ending
balance item would replace the Cycle Ending Balance Flag (item 16).
One commenter indicated that the rationale for both cycle-ending balance and monthending balance on Schedule D was unclear and that availability in credit card servicing systems
does not necessarily imply those data are available for reporting purposes. The commenter
requested that the Board withdraw this change.
The Board emphasizes that both Month Ending Balance and the existing Cycle-Ending
Balance fields enhance modeling and enable the Board and the OCC to identify the level and
direction of model risks to which a bank is exposed. In particular, the cycle-ending balance
informs consumers’ behavior in terms of performance of loans, spending and payment behavior,
and highlights the timing influence between the two measures. The existing cycle-ending
balance field currently allows firms to report either the month-ending or cycle-ending balances
identified by the existing cycle-ending balance flag field, resulting in inconsistent reporting
across firms and diminished usability of the reported data for this field. The final FR Y-14
implements these changes with the reports with data as of March 31, 2018.
Other Comments
Under the current attestation requirement, BHCs and U.S. IHCs subject to supervision by
the Large Institution Supervision Coordination Committee (LISCC)25 are required to submit a
cover page signed by the chief financial officer or an equivalent senior officer attesting to the
material correctness of actual data, conformance to instructions, and effectiveness of internal
25

BHCs subject to supervision by the LISCC were subject to the attestation requirement in December 2016, and
U.S. IHCs subject to supervision by the LISCC will be subject beginning in December 2017.

35

controls. Although no modifications to the existing attestation requirement were proposed,
commenters suggested certain modifications to the submission dates for the attestation
requirement, including allowing firms subject to supervision by the LISCC to submit the FR Y14M attestations quarterly, instead of each respective month. Another commenter requested that
U.S. IHCs subject to supervision by the LISCC that are required to submit their first attestation
as of December 31, 2017, submit their attestations for the reports associated with the annual
cycle for the FR Y-14A and FR Y-14Q reports in April 2018, instead of on each data schedule’s
respective submission date. These modifications would allow these U.S. IHCs the same amount
of time to come into compliance with the attestation requirement as was accorded BHCs and
would clarify the attestation due date for FR Y-14 schedules with alternative submission dates,
while reducing operational burden associated with the attestation requirement. In line with this
feedback, the Board will modify the attestation requirement as follows:






FR Y-14A/Q (annual submission): for both LISCC U.S. IHCs and BHCs subject to the
FR Y-14 attestation requirement, the attestation associated with the annual submission
(i.e., data reported as of December 31, including the global market shock submission26)
will be submitted on the last submission date for those reports, typically April 5 of the
following year. For example, all of the FR Y-14Q schedules due 52 days after the as-of
date (typically mid-February), all of the FR Y-14A schedules due April 5, and the trading
and counterparty schedules due on the global market shock submission date (March 15 at
the latest) will be due on the latest of those dates, the annual submission date for the
FR Y-14A report schedules (April 5).
FR Y-14M: for those firms that file the FR Y-14M reports, the three attestations for the
three months of the quarter will be due on one date, the final FR Y-14M submission date
for those three intervening months. For example, the attestation cover pages and any
associated materials for the FR Y-14M reports with January, February, and March as of
dates will be due on the data due date for the March FR Y-14M. Note that one attestation
page per monthly submission is still required.
FR Y-14Q: the FR Y-14Q attestation for the three remaining quarters (Q1, Q2, and Q3)
will continue to be submitted on the due date for the FR Y-14Q for that quarter.
The instructions and cover pages will be updated to clarify and align with the submission

dates.
Two commenters requested the elimination of several schedules that the Board did not
propose to modify. Commenters requested that the Board no longer require the reporting of
detailed information on a firm’s retail balances and loss projections (FR Y-14A, Schedule A.2.a),
metrics of pre-provision net revenue (FR Y-14A, Schedule A.7.c), or quarterly data monitoring
progress towards phasing in regulatory capital requirements (FR Y-14Q, Schedule D) as they
believe the information is not material to the balance sheet and provides little incremental
information or value. The Board reviews the items required to be reported on the FR Y-14 series
of reports on an ongoing basis. In response to past comments, the Board has assessed the
information collected on the Summary – PPNR Metrics (FR Y-14A, Schedule A.7.c) sub26

As outlined in Sections 252.144 (Annual Stress Tests) of Regulation YY (12 CFR 252), the as-of date will be
October 1 of the calendar year preceding the year of the stress test cycle to March 1 of the calendar year of the stress
test cycle and will be communicated to the BHCs by March 1st of the calendar year.

36

schedule and added thresholds to certain items or removed other items altogether. All of these
schedules continue to be used to produce either the Dodd-Frank Act stress test estimates or as
part of the qualitative capital plan assessment (either through the qualitative component of the
CCAR assessment for LISCC and large and complex firms or through the annual supervisory
review for large and noncomplex firms). The Board may propose additional changes in the
future to further reduce burden associated with these reporting requirements or in connection
with updates to stress-test projections.
Similarly, in an effort to reduce burden, commenters recommended that the Board reduce
the reporting of the FR Y-14M schedules to a quarterly frequency. One commenter also
summarized and provided further feedback on topics that require ongoing discussions, including
requirements for historic resubmissions. The Board continues to investigate opportunities to
reduce the burden of reporting while still collecting the data at a level of granularity and
frequency that supports the running of the DFAST and CCAR exercises. As requested, the
Board will continue to engage the industry to gather further feedback, including in regards to the
FR Y-14M, and values industry feedback on matters related to FR Y-14 reporting.
As in prior proposals,27 commenters requested that the Board undertake a periodic, fullscale review of the data items required in the FR Y-14 submissions, and that the Board increase
edit check thresholds or allow for permanent closure options. In response, the Board confirms
that it regularly reviews the required elements of the FR Y-14 submissions and will continue to
review the requirements to ensure they are appropriate. The current edit check thresholds and
permanent closure of edit checks are varied and have been determined on a case-by-case basis
depending on the data item to which the edit check pertains. Given the disparate nature of the
data items being collected, it would be inappropriate to create uniform minimum thresholds
across all schedules.
On December 15, 2017, the Board published a final notice in the Federal Register
(82 FR 59608).
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 858,138 hours and, with the
proposed revisions, would increase by 58,732 hours, for a total of 916,870 hours. This increase
is primarily due to the expansion of the global market shock.
The proposed modifications to the scope of the global market shock are estimated to
increase the annual reporting burden by approximately 61,000 hours in the aggregate.28 All of
the increase in burden due to the modification of the global market shock is attributable to the six
U.S. IHCs that would become subject to the global market shock submitting the FR Y-14 trading

27

See, for example, responses to comments outline in the final tailoring rule (82 FR 9308 (February 3, 2017)).
This total includes an estimated 144 additional burden hours attributable to the six specified IHCs that would file
the FR Y-14Q, Schedule L (Counterparty) under the proposed threshold also being subject to the other new
requirements of Schedule L as outlined in this proposal.
28

37

and counterparty schedules on a quarterly basis. None of the increased burden would fall on
domestic bank holding companies that are subject to the global market shock.
The addition of items to the FR Y-14M reports as requested by the OCC to facilitate their
continuing use of the Board data collection also increases burden. The addition of these items to
the FR Y-14M represents 1,200 total additional burden hours.
Excluding the above changes, there would be an overall decrease in burden attributable to
the removal of the FR Y-14A, Schedule D (RCT) and FR Y-14A, Schedule G (Retail
Repurchase Exposures). The addition of the new pro-forma balance sheet M&A sub-schedule to
the FR Y-14A, Schedule F (Business Plan Changes), and new reporting requirements on the
FR Y-14Q Schedule C (RCI) and Schedule L (Counterparty) partially offset the decrease in
burden, for an overall total net decrease of 3,572 hours.
The total burden hours also includes ongoing automation burden, which captures the
automation and programming updates necessary to accommodate changes that modify the
reporting structure or requirements of existing items. The Board estimates that on average it
would take approximately 480 hours 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 Y-14. Finally, the
Board estimates on average that it will take 400 hours for each of the six IHCs that will begin
filing the FR Y-14Q Schedule F (Trading) and Schedule L (Counterparty) to implement the
additional reporting. Since the modifications outlined in this proposal do not result in any new
FR Y-14 filers, the implementation burden estimate is 0 burden hours.
These reporting requirements represent approximately 8.5 percent of total Federal
Reserve System paperwork burden.

38

Number of
Annual
respondents frequency

FR Y-14

Estimated
average hours
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 Plan
Current FR Y-14A Total

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

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
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
218,464

36

12

515

222,480

Home Equity

30

12

515

185,400

Credit Card

17

12

510

104,040
511,920

0
38

1
1

7,200
480

0
18,240
18,240

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

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

39

Implementation
On-going
Attestation total

0
13

1
1

4,800
2,560

0
33,280
33,280
858,138

Current Collection total

40

Annual
frequency

Estimated
average hours
per response

38
38
38
38
38
5

2
2
1
1
1
1

887
31
18
21
16
100

67,412
2,356
684
798
608
500
72,358

38
38
38
38
12
38
38
38
14
38
24
12
38

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

15
13
711
151
1,926
23
54
50
23
4
15
514
16

2,280
1,976
108,072
22,952
92,448
3,496
8,208
7,600
1,288
608
1,440
24,672
2,432

Number of
respondents29
Proposed FR Y-14A
Summary
Macro Scenario
Operational Risk
Regulatory Capital Instruments
Business Plan Changes
Adjusted Capital Plan
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

Proposed FR Y-14Q total

277,472

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

36

12

516

222,912

Home Equity
Credit Card
Proposed FR Y-14M total

30
17

12
12

516
512

185,760
104,448
513,120

29

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.

41

Proposed Implementation and On-going Automation
Implementation
0
On-going revisions
38
One-time Implementation
6
Proposed Automation total
Attestation
Implementation
On-going

0
13

1
1
1

7,200
480
400

0
18,240
2,400
20,640

1
1

4,800
2,560

0
33,280
33,280

Attestation total
Proposed Collection total

916,870

Total Change

58,732

The current annual cost to the public of these reports is estimated to be $47,111,776 and would
increase to $50,336,163 with the proposed changes.30
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.

30

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/.

42