FRY6_FRY7_FRY10_FRY10E_20180126_omb

Supporting Statement for the
Annual Report of Holding Companies,
Annual Report of Foreign Banking Organizations,
Report of Changes in Organizational Structure, and
Supplement to the Report of Changes in Organizational Structure
(FR Y-6, FR Y-7, FR Y-10, and FR Y-10E; OMB No. 7100-0297)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated authority
from the Office of Management and Budget (OMB), proposes to revise the mandatory Structure
Reporting Requirements for Domestic and Foreign Banking Organizations (OMB No. 71000297). This family of reports is comprised of the Annual Report of Holding Companies (FR Y6), Annual Report of Foreign Banking Organizations (FR Y-7), Report of Changes in
Organizational Structure (FR Y-10), and Supplement to the Report of Changes in Organizational
Structure (FR Y-10E).
The proposal would revise the FR Y-7 to collect information from foreign banking
organizations (FBOs) on their compliance with U.S. risk committee and home country stress test
requirements under the Board’s Regulation YY1 and section 165 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act (Dodd-Frank Act)2. The FR Y-7 revisions would be
effective for foreign banking organizations with fiscal year-ends that end, and for FR Y-7 reports
submitted, on or after March 1, 2018. There are no changes to the FR Y-6, FR Y-10, or FR Y10E. The current annual reporting burden for the structure reporting forms is estimated to be
70,035 hours. The proposed revisions would result in an increase in burden of 486 hours.
Background and Justification
FR Y-6: This report collects financial data, an organization chart, verification of domestic
branch data, and certain information about shareholders from bank holding companies (BHCs),
savings and loan holding companies (SLHCs), employee share ownership plans/trusts, securities
holding companies, U.S. intermediate holding companies (IHCs) (collectively, HCs), and foreign
banking organizations (FBOs) that are non-qualifying. In the mid-1950s, the Federal Reserve
implemented the FR Y-6, which collects data annually on shareholders, directors, and officers of
HCs, which enables the Federal Reserve to monitor HC operations for purposes of ensuring that
operations are conducted in a safe and sound manner and determine HC compliance with the
BHC Act, Change in Bank Control Act, Home Owners’ Loan Act (HOLA), and the Board’s rules,
including Regulations Y, LL, and YY. In 2012 and 2016, the Federal Reserve expanded the
FR Y-6 reporting panel to include SLHCs and IHCs, respectively, and revised the reporting
instructions. Information on the principal owners and directors of an HC is of supervisory
importance because these individuals have a significant effect on the policies and condition of
banking organizations. In addition, data on outside business interests of directors and officers aid
in identifying chain-banking organizations by indicating when an individual owns 25 percent or
1
2

See 12 CFR part 252.
See 12 U.S.C. 5365.

more of each of two or more banking organizations. Section 5(c) of the Bank Holding Company
Act (BHC Act) authorizes the Federal Reserve to require BHCs to keep the Federal Reserve
informed of their financial condition, risk management systems, and transactions with bank
subsidiaries. The Federal Reserve has collected annual reports from BHCs in some form
beginning with the implementation of the BHC Act. Information on the outside business interests
of insiders can be useful in uncovering situations that involve a conflict of interest or preferential
treatment in the granting of credit. The FR Y-6 data are available to other federal banking
agencies for use in their supervision of national and state nonmember banks. In addition, the
FR Y-6 serves as a source of information on HCs for the public and for responses to information
requests from Congress. This information is not available from other sources.
FR Y-7: This report collects updates from qualifying FBOs on their financial and
organizational information. The Federal Reserve implemented the FR Y-7 in January 1972 and
required only foreign banks that controlled U.S. subsidiary banks to file the report. The Federal
Reserve expanded the report following enactment of the International Banking Act of 1978 (IBA),
which established a framework for federal regulation of foreign banks operating in U.S. financial
markets. Section 7 of the IBA authorizes the Federal Reserve to examine U.S. branches,
agencies, and subsidiary commercial lending companies of foreign banks and to assess the
condition of the multi-state banking operations of foreign banks. Section 8(a) of the IBA states
that foreign banks that engage in banking in the United States through a U.S. branch, agency, or
subsidiary commercial lending company and companies that control such foreign banks are
subject to the provisions of the BHC Act. In addition, section 165 of the Dodd-Frank Act and
Regulation YY require certain large FBOs to establish a U.S. risk committee and conduct, or be
subject to, home country stress testing to avoid additional requirements in the United States.
Among other purposes, the Federal Reserve uses information collected on the FR Y-7 to assess an
FBO’s ability to be a continuing source of strength to its U.S. operations, to determine eligibility
as a FBO that is qualifying, and to determine compliance with U.S. laws and regulations. This
information is not available from other sources.
FR Y-10: This report is an event-generated information collection that captures changes
in the regulated investments and activities of various entities. In 1985, the Federal Reserve began
collecting on the FR Y-6A (OMB No. 7100-0124) structure information for new BHCs or BHCs
that had undergone a change in their organizational structure. In September 2001, the Federal
Reserve replaced the FR Y-6A with the FR Y-10 and moved certain information on foreign
investments from the Report of Changes in Foreign Investments (FR 2064; OMB No. 7100-0109)
to the FR Y-10. These changes reduced burden on respondents by making submissions of
structure information by domestic HCs and FBOs more similar, increasing the thresholds for
investments to be included, reducing the types of investments to be included, streamlining the
method for indicating the percentage ownership of nonbanking investments, and simplifying the
submission of legal authority and activity codes. In 2012, the Federal Reserve expanded the
FR Y-10 reporting panel to include SLHCs, added a Savings and Loan Schedule, and made other
revisions.
The Federal Reserve uses the FR Y-10 to monitor the activities of reportable companies
for purposes of ensuring that the activities are conducted in a safe and sound manner and to
determine compliance with applicable laws and regulations, including the BHC Act, the Gramm-

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Leach-Bliley Act, the Federal Reserve Act (FRA), HOLA, Regulation Y, Regulation K,
Regulation LL, and Regulation YY. Additionally, the FR Y-10 is the only source of information
collected by a banking agency that captures detailed information on the structure of these banking
organizations. This information is not available from other sources.
FR Y-10E: This collection is a free-form supplement that may be used to collect
additional structural information on an emergency basis. The Federal Reserve implemented the
FR Y-10E, effective June 30, 2007, to create a free-form supplement to the FR Y-10 so that,
should there be an immediate need for critical organizational structural information, the necessary
data could be collected on this supplement at the earliest practicable date. This supplement may
only be used to meet new legislative requirements, answer Congressional inquiries, or respond to
critical market events that could not be addressed in a timely manner if the Federal Reserve were
required to seek approval through the reports clearance process.
Description of Information Collection
As noted, the FR Y-6 is submitted annually by top-tier domestic HCs and FBOs that are
non-qualifying. The FR Y-6 requires the submission of an organizational chart, verification of
domestic branch data, and collection of information on the identity, percentage ownership, and
business interests of principal shareholders, directors, and executive officers. It also requires HCs
not registered with the U.S. Securities and Exchange Commission to submit to the Federal
Reserve their annual report to shareholders, if one is created.
The FR Y-7 is submitted annually by FBOs that are qualifying that are directly or
indirectly engaged in the business of banking in the United States as of the end of the
respondent’s fiscal year.3 The FR Y-7 collects financial, organizational, and managerial
information.
The FR Y-10 is submitted as required on an event-driven basis by FBOs; top-tier HCs;
state member banks that are not controlled by a HC; Edge and agreement corporations that are not
controlled by a member bank, a domestic HC, or an FBO; and nationally chartered banks that are
not controlled by a HC (with regard to their foreign investments only) and comprises eight data
schedules on organizational structural changes.
The FR Y-10E event-driven supplement is available for the Federal Reserve to collect
additional structural information deemed to be critical and needed in an expedited manner. This
supplement may only be used to meet new legislative requirements, answer Congressional
inquiries, or respond to critical market events that could not be addressed in a timely manner if the
Federal Reserve were required to seek approval through the reports clearance process.
Subsequent to the implementation of this supplement, if the data were needed on a permanent
basis, the Federal Reserve would complete the report clearance process, including a request for
public comment.
3

Banks organized under the laws of Puerto Rico and other American possessions are generally not required to file
the FR Y-7. Also, FBOs that are BHCs or that have a U.S. BHC subsidiary are required to report on the FR Y-6 all
interests held through the top-tier U.S. IHC or BHC.

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Proposed Revisions to the FR Y-7
Section 165 of the Dodd-Frank Act directs the Board to establish enhanced prudential
standards for BHCs and FBOs with total consolidated assets of $50 billion or more and nonbank
financial companies that the Financial Stability Oversight Council has designated for supervision
by the Board. In addition, the Dodd-Frank Act directs the Board to issue regulations applying
certain standards to BHCs and FBOs with total consolidated assets of $10 billion or more. In
particular, the Board is directed to require publicly traded BHCs and FBOs with total consolidated
assets of $10 billion or more to establish risk committees.4 In addition, section 165 requires the
Board to issue regulations imposing company-run stress test requirements on BHCs, FBOs, state
member banks, and savings and loan holding companies with total consolidated assets of more
than $10 billion.5
In February of 2014, the Board adopted enhanced prudential standards for FBOs,
including risk committee and stress testing requirements for FBOs with total consolidated assets
of more than $10 billion. These standards are contained in the Board’s Regulation YY, which
applies different requirements to FBOs depending on their asset size. The risk committee and
stress testing requirements are located in the following subparts:
 Subpart L establishes stress testing requirements for FBOs with total consolidated
assets of more than $10 billion,
 Subpart M establishes risk committee requirements for publicly traded FBOs with
total consolidated assets between $10-$50 billion,
 Subpart N establishes enhanced prudential standards (including risk committee and
stress testing requirements) for FBOs with total consolidated assets of $50 billion or
more but combined U.S. assets of less than $50 billion, and
 Subpart O establishes enhanced prudential standards (including risk committee and
stress testing requirements) for FBOs with total consolidated assets of $50 billion or
more and combined U.S. assets of $50 billion or more.
With regard to risk committee requirements, an FBO subject to subpart M or N of
Regulation YY is required to certify that it has a risk committee that oversees the risk
management practices of the combined U.S. operations of the company and has at least one
member with appropriate risk expertise.6 This certification must be filed on an annual basis with
the Board concurrently with the FR Y-7. An FBO subject to subpart O of Regulation YY is
subject to additional U.S. risk committee requirements that are more prescriptive and must
employ a U.S. chief risk officer in the United States.7
With regard to stress testing, an FBO subject to subpart L, N, or O of Regulation YY must
be subject to a consolidated capital stress testing regime administered by the FBO’s home country
supervisor, meet the home country supervisor’s minimum standards, and, in some cases, provide
4

See 12 CFR 252.132(a) and 252.144(a).
See 12 U.S.C. 5365(i).
6
The combined U.S. operations of an FBO include its U.S. branches and agencies and U.S. subsidiaries (other than
any company held under section 2(h)(2) of the BHC Act, if applicable).
7
FBOs subject to subpart O are not required to certify that they have a U.S. risk committee because the Board
expects to gain sufficient information through the supervisory process to evaluate whether the U.S. risk committee
meets the requirements of this section.
5

4

information to the Board about the results of home country stress testing or face additional
requirements in the United States. In particular, the U.S. branches and agencies of the FBO
become subject to an asset maintenance requirement, and the FBO generally must conduct an
annual stress test of its U.S. subsidiaries. An FBO subject to subpart O also must stress test any
U.S. IHC.
The proposed revisions to the FR Y-7 would implement the U.S. risk committee
certification requirement in Regulation YY and provide FBOs with a standardized way to indicate
compliance with the home country stress testing requirements (and thus, avoid being subject to
additional requirements in the U.S.). The proposed revisions to the FR Y-7 also better describe
the risk committee requirements in Regulation YY and the scope of applicability of the report to
FBOs.
Respondent Panel
The FR Y-6 panel comprises top-tier HCs and FBOs that are non-qualifying. The FR Y-7
panel comprises all FBOs that are qualifying that engage in banking in the United States, either
directly or indirectly. The FR Y-10 and FR Y-10E panel comprises FBOs; top-tier HCs; state
member banks that are not controlled by a HC; Edge and agreement corporations that are not
controlled by a member bank, a domestic HC, or an FBO; and nationally chartered banks that are
not controlled by a HC (with regard to their foreign investments only).
Time Schedule for Information Collection and Publication
The FR Y-6 is submitted annually, no later than 90 calendar days after the end of the
respondent’s fiscal year. Individual respondent data are available to the public upon request
through the appropriate Reserve Bank. Under certain circumstances, however, respondents may
request confidential treatment.
All FBOs that are qualifying file the FR Y-7 annually as of the end of the FBO’s fiscal
year; the data are due no later than four months after the report date. Individual respondent data
are available to the public upon request through the appropriate Reserve Bank. Under certain
circumstances, however, respondents may request confidential treatment.
The FR Y-10 is event-generated, and the data are submitted within 30 calendar days of a
reportable transaction or event. Individual respondent data are available to the public upon
request through the appropriate Reserve Bank. Under certain circumstances, however,
respondents may request confidential treatment. Limited data from the FR Y-10 are published on
the National Information Center’s public website. The FR Y-10E is event-generated and the data
are submitted on an ad-hoc basis as needed.
Legal Status
The Board’s Legal Division has determined that the following statutes authorize the
Federal Reserve to require the collections of information:

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FR Y-6: Section 5(c) of the BHC Act (12 U.S.C. 1844(c)); sections 8(a) and 13(a) of the
IBA (12 U.S.C. 3106(a) and 3108(a)); sections 11(a)(1), 25, and 25A of the FRA (12 U.S.C.
248(a)(1), 602, and 611a); sections 113, 165, 312, 618, and 809 of the Dodd-Frank Act (12 U.S.C.
5361, 5365, 5412, 1850a(c)(1), and 5468(b)(1)); and section 252.153(b)(2) of Regulation YY (12
CFR 252.153(b)(2)).
FR Y-7: Sections 8(a) and 13(a) of the IBA (12 U.S.C. 3106(a) and 3108(a)) and
sections 113, 165, 312, 618, and 809 of the Dodd-Frank Act (12 U.S.C. 5361, 5365, 5412,
1850a(c)(1), and 5468(b)(1)).
FR Y-10 and FR Y-10E: Sections 4(k) and 5(c)(1)(A) of the BHC Act (12 U.S.C.
1843(k) and 1844(c)(1)(A)); section 8(a) of the IBA (12 U.S.C. 3106(a)); sections 11(a)(1), 25(7),
and 25A of the FRA (12 U.S.C. 248(a)(1), 321, 601, 602, 611a , 615, and 625); sections 113, 165,
312, 618, and 809 of the Dodd-Frank Act (12 U.S.C. 5361, 5365, 5412, 1850a(c)(1), and
5468(b)(1)); and section 10(c)(2)(H) of the HOLA (12 U.S.C. 1467a(c)(2)(H)).
The obligation to respond is mandatory.
The Board’s Legal Division has also determined that, except as discussed below, the data
collected in the FR Y-6, FR Y-7, FR Y-10, and FR Y-10E, are generally not considered
confidential. With regard to information that a banking organization may deem confidential, the
institution may request confidential treatment of such information under one or more of the
exemptions in the Freedom of Information Act (FOIA) (5 U.S.C. 552). The most likely case for
confidential treatment will be based on FOIA exemption 4, which permits an agency to exempt
from disclosure “trade secrets and commercial or financial information obtained from a person
and privileged and confidential” (5 U.S.C. 552(b)(4)). To the extent an institution can establish
the potential for substantial competitive harm, such information would be protected from
disclosure under the standards set forth in National Parks and Conservation Association v.
Morton, 498 F.2d 765 (D.C. Cir. 1974). In particular, the disclosure of the responses to the
certification questions on the FR Y-7 may interfere with home country regulators’ administration,
execution, and disclosure of their stress test regime and its results, and may cause substantial
competitive harm to the FBO providing the information, and thus this information may be
protected from disclosure under FOIA exemption 4. Exemption 6 of FOIA might apply with
regard to the respondents’ submission of non-public personal information of owners,
shareholders, directors, officers and employees of respondents. Exemption 6 covers “personnel
and medical files and similar files the disclosure of which would constitute a clearly unwarranted
invasion of personal privacy” (5 U.S.C. 552(b)(6)). All requests for confidential treatment would
need to be reviewed on a case-by-case basis and in response to a specific request for disclosure.
Consultation Outside the Agency
On December 2, 2015, the Board published an initial notice in the Federal Register
(80 FR 75457) requesting public comment for 60 days on the revision, with extension, of the
FR Y-6, FR Y-7, FR Y-10, and FR Y-10E. The comment period for this notice expired on
February 1, 2016. The Board received two comment letters, one from an industry association and
one from a banking organization. One comment letter requested clarification on several of the

6

underlying requirements in Regulation YY while the other comment letter requested clarification
on the instructions for the FR Y-6 and the FR Y-10. The Board proposes to adopt the revisions as
proposed, except that the FR Y-7 revisions would be effective for foreign banking organizations
with fiscal year-ends that end and for FR Y-7 reports submitted on or after March 1, 2018. The
Board is also clarifying several of the issues raised by commenters in the final Federal Register
notice, as further discussed below.
Detailed Discussion of Public Comments
The following is a detailed discussion of the two comments received regarding the FR Y7 proposal and the responses related to the changes in the FR Y-7 proposal. Although no
comments were received on the reporting burden estimates, the Board has reconsidered the
estimates given the clarifications provided to Regulation YY. Thus, the Board increased the
estimated hourly burden from 4 hours to 6 hours per response.
A commenter requested a number of clarifications regarding the provisions in
Regulation YY that require an FBO to maintain a committee of its global board of directors (or
equivalent thereof) that oversees the risk-management policies of the combined U.S. operations
of the FBO.8 Each of these questions are matters of interpretation of the requirements of
Regulation YY and are not related to the reporting requirements in the FR Y-7.
First, the commenter requested clarification on whether the committee that oversees U.S.
risk must be composed entirely of members of the FBO’s global board or may be configured in
other ways that take into account the size, scale, and complexity of an FBO’s combined U.S.
operations and more effectively utilize the expertise of personnel familiar with the risk of these
operations.
In response to this comment, to certify compliance with sections 252.132(a) and
252.144(a), the FBO is not required to form a special U.S. risk committee comprised of members
of the FBO’s board of directors. Rather, the FBO must ensure that the FBO’s board of directors
or a committee comprised of members of the FBO’s board of directors has primary responsibility
for oversight of the risks of the combined U.S. operations. The committee that oversees U.S.
risk for an FBO subject to Regulation YY is not required to (though it may) directly administer
the FBO’s U.S. risk management policies; rather the FBO may designate specific senior
management officials from the FBO’s U.S. operations to be responsible for administering the
U.S. risk management policies and for providing regular reports directly to the FBO’s board of
directors or risk committee.9 The rule is intended to allow an FBO flexibility in establishing its
oversight function so long as the FBO’s board of directors is informed about and provides the
appropriate level of guidance about the risks of the combined U.S. operations of the FBO.
However the FBO designs its oversight function, the FBO must also take appropriate measures
to ensure that the risk management policies for its combined U.S. operations are implemented
and that the risk committee is provided sufficient information on the combined U.S. operations to
allow it to carry out its responsibilities.10
8

See 12 CFR 252.132(a) and 252.144(a).
See 79 FR 17284 (March 27, 2014).
10
See 12 CFR 252.132(c) and 252.144(c).
9

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The same commenter requested clarification regarding how the requirement in
Regulation YY for an FBO to have a committee that oversees U.S. risk would apply to an FBO
with a two-tier board structure. The two-tier board structure is a common feature of FBOs in
European countries, and generally consists of a supervisory board independent from management
that sets the direction of the company and oversees the company’s senior management, and a
management/executive board that implements the company’s strategies and risk management.
The purpose of the risk committee requirements in Regulation YY is to ensure that the FBO
parent is aware of and takes responsibility for the oversight of the risks of its combined U.S.
operations. This oversight function can be integrated into various board structures that currently
exist in different foreign countries. In a two-tier board structure, a committee of either the
supervisory board or the management/executive board (or a combination thereof) could be
considered a committee of the FBO board of directors for purposes of complying with the
requirement under Regulation YY for an FBO to maintain a committee that oversees U.S. risk.
Both tiers of a two-tier board are typically involved in evaluating risk management at an FBO
with the same goals as those of a single board of directors in the United States.
The same commenter requested clarification regarding various requirements in
Regulation YY relating to capital stress testing and liquidity stress testing.11 To be exempt from
additional U.S. capital stress testing requirements, Regulation YY requires an FBO to be subject
on a consolidated basis to an annual capital stress testing regime in its home country that meets
certain requirements and to actually meet any minimum stress testing standards set by the FBO’s
home country supervisor.12 In reporting Item 5 of the FR Y-7, an FBO is expected to evaluate
the stress testing regime to which it is subject and make a reasonable conclusion about whether
this regime meets the home country stress testing criteria in Regulation YY.
Moreover, the same commenter requested clarification as to whether an FBO would meet
the home country stress test requirements upon a satisfactory completion of an Internal Capital
Adequacy Assessment Process (ICAAP). If the ICAAP satisfies the underlying requirements for
a capital stress test, including all applicable information requirements in Regulation YY,
satisfactory completion of the ICAAP would be sufficient to satisfy these requirements.
Regulation YY requires an FBO to report on an annual basis the results of an internal
liquidity stress test for either the consolidated operations of the FBO or the FBO’s combined
U.S. operations. In either case, the liquidity stress test must incorporate three specified planning
horizons. The same commenter requested guidance on how an FBO should report when the
FBO’s home country uses fewer or different planning horizons.
In the event that an FBO is not required to conduct an internal liquidity stress test for its
consolidated operations using the three specified planning horizons in Regulation YY or chooses
not to do so, the FBO may instead choose to provide an internal liquidity stress test for just the
combined U.S. operations. Under Regulation YY, if an FBO does not comply with the internal
11

See 12 CFR 252.122(a), 12 CFR 252.145(a), 12 CFR 252.146(b), and 12 CFR 252.158(b).
The capital stress testing regime must include (1) an annual supervisory capital stress test conducted by the
relevant home country supervisor or an annual evaluation and review by the home country supervisor of an internal
capital adequacy stress test conducted by the FBO and (2) requirements for governance and controls of stress testing
practices by relevant management and the board of directors (or equivalent thereof).
12

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liquidity stress testing reporting requirements, it must limit the net aggregate amount owed by
the parent or other non-U.S. affiliates to the U.S. operations to 25 percent or less of the third
party liabilities of the combined U.S. operations.
The Board also is clarifying in the Federal Register notice that, although Regulation YY
does not prescribe the information that must be reported to the Board regarding the internal
liquidity stress tests, given the diversity in liquidity reporting requirements across jurisdictions,
FBOs are expected to provide sufficient information in the internal liquidity stress test to allow
the Board to assess the liquidity position of the FBO.13
The same commenter requested guidance on an FBO’s compliance with the stress testing
requirement when annual stress testing is not required by the FBO’s home country supervisor.
Regulation YY requires an FBO to be subject to a stress testing regime that includes an annual
supervisory stress test or annual supervisory evaluation of the FBO’s internal stress test. A biannual stress test, for example, would not satisfy this requirement.
The same commenter requested guidance on whether an FBO would be deemed to satisfy
the requirement to report and certify compliance with its home country capital adequacy
requirements by completing the FR Y-7Q. In addition, the commenter requested confirmation of
the as-of date and frequency of the certification of the FR Y-7Q. Regulation YY requires an
FBO to report compliance with capital adequacy measures that are consistent with the Basel
Capital Framework (as defined in 12 CFR 252.143(a) and 252.154(a)) concurrently with filing
the FR Y-7Q; however, Regulation YY does not specify the frequency or the as-of date for an
FBO’s certification of compliance with its home country capital requirements. On December 2,
2016, the Board approved a final notice to amend the FR Y-7Q to expand reporting regarding an
FBO’s home country capital ratios consistent with Regulation YY. An FBO’s completion of the
FR Y-7Q on a quarterly basis would satisfy both the requirement to report and the requirement to
certify to the Board its compliance with capital adequacy measures that are consistent with the
Basel Capital Framework. If an FBO is unable to report that it is in compliance with such capital
adequacy measures, the Board may impose requirements, conditions, and restrictions relating to
the U.S. operations of the FBO.14
A second commenter requested clarification on the definition of an inactive company
when an entity is in the liquidation process. Respondents should refer to the definition of
“Liquidation” in the Banking, Savings and Loan, and Nonbanking Schedules in the FR Y-10
instructions on how to classify an entity during the liquidation process. Specifically, the
instructions state “liquidation refers to final distribution of assets, satisfaction of liabilities, and
closing of capital accounts of a company, as opposed to sale or transfer of the company.”
The same commenter also requested that the instructions be expanded on reporting when
a nonbanking company is a functionally regulated subsidiary since the mere registration with a
functional regulator does not necessarily qualify a company as being functionally regulated for
these purposes. In response to the commenter’s request, the Board notes that respondents should
refer to the definition of “Functionally Regulated Subsidiary” in the FR Y-10 instructions, which
13
14

See 79 FR 17239, 17301 (March 27, 2014).
See 12 CFR 252.143(c) and 252.154(c).

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provides that certain companies may be required to be registered with one of the enumerated
regulators without necessarily qualifying as being functionally regulated by that regulator; for
example, publicly held companies may be required to be registered with the U.S. Securities and
Exchange Commission (SEC) without necessarily qualifying as functionally regulated by the
SEC as a securities broker-dealer, investment adviser, investment company, or company that
engages in commodity futures trading.
On January 23, 2018, the Board published a final notice in the Federal Register
(83 FR 3141) on the revision of the FR Y-6, FR Y-7, FR Y-10, and FR Y-10E.
Estimate of Respondent Burden
The current annual reporting burden associated with the Federal Reserve’s share of the
structure report forms and instructions is estimated to be 70,035 hours. The FR Y-7 proposed
revisions would result in an increase in burden of 486 hours due to the increase in estimated
average hours per response from 4 to 6. While the overall FR Y-7 reporting burden is estimated
to increase by 2 hours on average for all FR Y-7 respondents, the proposed reporting requirements
only apply to a subset of the respondents (approximately 143). The burden is estimated to
increase by 3 hours and 20 minutes per response for each respondent subject to the proposed
reporting requirements. These reporting requirements represent less than 1 percent of the total
Federal Reserve System paperwork burden.

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Number of
respondents15

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

13
4,827
243
5,298
5,298

1
1
1
3
1

10
5.50
4
2.50
0.50

130
26,549
972
39,735
2,649
70,035

13
4,827
243
5,298
5,298

1
1
1
3
1

10
5.50
6
2.50
0.50

Total

130
26,549
1,458
39,735
2,649
70,521

Change

486

Current
FR Y-6 initial
FR Y-6 ongoing
FR Y-7
FR Y-10
FR Y-10E
Total
Proposed
FR Y-6 initial
FR Y-6 ongoing
FR Y-7
FR Y-10
FR Y-10E

The current total annual reporting cost to the public for this family of reports is estimated to
increase by $26,681 from $3,844,922 to $3,871,603.16
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The current cost to the Federal Reserve System for collecting and processing these reports
is estimated to be $2,362,850 per year.

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Of these respondents, 3,356 for the FR Y-6; none for the FR Y-7; 3,693 for the FR Y-10; and 3,693 for the FR Y10E, 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-sure-you-meet-sba-sizestandards/table-small-business-size-standards.
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Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$67, 15% Lawyers at $67, and 10% Chief Executives at $93). Hourly rates for each occupational group are the
mean (rounded up) hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and
Wages May 2016, published March 31, 2017, www.bls.gov/news.release/ocwage.nr0.htm. Occupations are defined
using the BLS Occupational Classification System, www.bls.gov/soc/.

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