Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework

Forms and Documents

Document	Type	Status	Availability
FFIEC101_20180731_omb_emergency.pdf	Supporting Statement A	Uploaded 2018-07-31	Available
InteragencyStatement_EGRRCPA_20180706.pdf	Supplementary Document	Uploaded 2018-07-27	Available

IC Document Collections

IC ID	Collection	Type	Status	Form
45550	SMBs	Other-Call Report Supplemental Instructions June 2018	Modified
223012	IHCs	Other-Call Report Supplemental Instructions June 2018	Modified
223010	BHCs and SLHCs	Other-Call Report Supplemental Instructions June 2018	Modified

ICR Details

OMB Control No: 7100-0319	ICR Reference No: 201807-7100-017
Status: Historical Active	Previous ICR Reference No: 201705-7100-013
Agency/Subagency: FRS	Agency Tracking No: FFIEC 101
Title: Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 08/03/2018
OIRA Conclusion Action: Approved without change	Conclusion Date: 08/14/2018
	Date Received in OIRA: 07/31/2018
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	02/28/2019	6 Months From Approved	08/31/2020
Responses	112	0	112
Time Burden (Hours)	59,576	0	59,576
Cost Burden (Dollars)	0	0	0

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Abstract: The FFIEC 101 must be filed quarterly by certain large or internationally active state member banks, bank holding companies (BHCs), savings and loan holding companies (SLHCs), intermediate holding companies (IHCs), and also for those institutions that adopt the framework on a voluntary basis. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Federal Deposit Insurance Act (FDI Act) and the International Lending Supervision Act of 1983 (ILSA) require the agencies to have risk-based capital requirements and to ensure that banks maintain adequate capital. The Board uses these data to assess and monitor the levels and components of each reporting entity’s risk-based capital requirements and the adequacy of the entity’s capital under the framework. These data also allow the Board to evaluate the quantitative impact and competitive implications of the framework on individual respondents and on the financial industry. The reporting schedules also assist banks in understanding expectations surrounding the system development necessary for implementation and validation of the framework. The submitted data that is released publicly also provide other interested parties with information about banks’ risk-based capital. Finally, the submitted data supplement on-site examination processes.

Emergency Justfication: The agencies propose under the emergency clearance provisions of OMB’s regulations to revise the FFIEC 101 for the June 30, 2018, report date. The agencies have determined that (1) the collection of information within the scope of this request is needed prior to the expiration of time periods established under 5 CFR 1320.10, (2) this collection of information is essential to the mission of the agencies, and (3) the agencies cannot reasonably comply with the normal clearance procedures because an unanticipated event has occurred and the use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of information. These revisions arise from Congressional enactment of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). Section 214 of EGRRCPA requires the agencies to revise the definition of high volatility commercial real estate (HVCRE) exposures that institutions use to calculate risk-weighted assests and, hence, risk-based capital ratios. This provision became effective automatically when the law was signed on May 24, 2018. The agencies must receive data from the quarterly FFIEC 101 report to assess and monitor the levels and components of each reporting entity’s risk-based capital requirements and the adequacy of the entity’s capital under the framework. The next reports are due at the end of August 2018, based on information available as of June 30, 2018. In order for the agencies to implement section 214 as required by law, the agencies cannot comply with the normal clearance process and still receive the June 30, 2018, financial data in a timely manner.

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Authorizing Statute(s): US Code: 12 USC 324 Name of Law: Federal Reserve Act
   US Code: 12 USC 1844(c) Name of Law: Bank Holding Company Act
   US Code: 12 USC 1467a(b)(2) Name of Law: Homeowners’ Loan Act
   US Code: 12 USC 5365 Name of Law: Dodd-Frank Act
  

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 3

IC Title	Form No.	Form Name
SMBs	FFIEC 101	Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework
BHCs and SLHCs	FFIEC 101	Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework
IHCs	FFIEC 101	Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	112	112	0	0	0	0
Annual Time Burden (Hours)	59,576	59,576	0	0	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

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Annual Cost to Federal Government: $157,700

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     Yes

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Yes

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 07/31/2018

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