FRY14_20190107_omb

Supporting Statement for the
Capital Assessments and Stress Testing Reports
(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), has revised, without extension, the
Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No. 7100-0341). These
collections of information are applicable to top-tier bank holding companies (BHCs) with total
consolidated assets of $100 billion or more and U.S. intermediate holding companies (U.S.
IHCs) established by foreign banking organizations under 12 CFR 252.153.1
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 in connection with the supervision and regulation of these financial institutions.
The Board has adopted revisions to the FR Y-14Q report that add back items that require
respondents to report their total stressed net current exposure under the two supervisory stressed
scenarios and make conforming changes to the instructions. The revisions do not result in a
change to the estimated burden for this series of reports, as the burden from the revisions is
already captured in the burden estimates associated with the FR Y-14Q report.
Background and Justification
Prior to the financial crisis that emerged in 2007, many firms made significant
distributions of capital without due consideration of the effects that a prolonged economic
downturn could have on their capital adequacy and their ability to remain credit intermediaries
during times of economic and financial stress. In 2009, the Board conducted the Supervisory
Capital Assessment Program, 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 by conducting 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 Board’s stress test rules establish stress testing requirements for certain BHCs, state
member banks, savings and loan holding companies and foreign banking organizations.2 The
1

On July 6, 2018, the Board issued a statement regarding the impact of the Economic Growth, Regulatory Relief,
and Consumer Protection Act (EGRRCPA). See
www.federalreserve.gov/newsevents/pressreleases/files/bcreg20180706b1.pdf. The Board announced that it will not
take action to require FBOs with total global consolidated assets greater than or equal to $50 billion but less than
$100 billion to comply with subpart O of Regulation YY, except for the risk management and risk committee
requirements under section 252.155.
2
See 12 CFR 252, subparts B, E, F, and O.

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).3 Section 165(i)(2) requires the
Board to issue regulations that require certain companies to conduct company-run stress tests.
Additionally, the Board’s capital plan rule requires certain firms to submit capital plans to the
Board annually and requires such firms to request prior approval from the Board under certain
circumstances before making a capital distribution.4
In connection with submissions of capital plans to the Board, firms are required, pursuant
to 12 CFR 225.8(e)(3), to provide information including, but not limited to, the firm’s financial
condition, structure, assets, risk exposure, policies and procedures, liquidity, and management.
The FR Y-14 series of reports collects these data from top-tier BHCs with total consolidated
assets of $100 billion or more and U.S. IHCs.
Description of Information Collection
These collections of information are applicable to top-tier BHCs with total consolidated
assets of $100 billion or more and U.S. IHCs. This family of information collections is
composed of the following three reports:





The 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 either
annually or semi-annually.5
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 schedules,
and one detailed address-matching schedule to supplement two of the portfolio and loanlevel schedules.

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 CCAR 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, as well as
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
3

See 12 U.S.C. 5365(a).
See 12 CFR 225.8.
5
Firms that must re-submit their capital plan generally also must provide a revised FR Y-14A in connection with
their resubmission. See 12 CFR 225.8(d)(4).
4

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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.6 Compliance with the information collection is mandatory.
Proposed Revisions
In December 2017, the Board approved modifications to the FR Y-14 series of reports
and a notice was published in the Federal Register (December 15, 2017; 82 FR 59608). The
proposal modified the FR Y-14Q, Schedule L (Counterparty) effective as of the March 31, 2018,
report date. These changes included simplifying the ranking methodology required for reporting
positions and combining the previously separate collections of counterparties as ranked by
derivatives and securities financing transactions (SFTs), respectively. Following the finalization
and adoption of these proposed changes, the Board became aware of unintended omissions from
the report forms and instructions for the FR Y-14Q. The omitted items required respondents to
report their total stressed net current exposure under the two supervisory stressed scenarios.
To rectify the unintended changes, the Board proposed to revise sub-schedule L.5
(Derivatives and Securities Financing Transactions (SFT) Profile) on the FR Y-14Q by adding
the mistakenly omitted items. This modification allows continued operationalization of
supervisory modeling, and would provide for total stressed net current exposure reporting under
the two supervisory stressed scenarios.
With the addition of the total stressed net current exposure item, the instructions were
changed to modify the associated ranking methodologies for the yearly stressed/CCAR
submission in sub-schedule L.5 to require the top 25 counterparties to be reported as ranked by
the total stressed net current exposure. This modification ensures that top counterparties are
properly rank-ordered by the total stressed net current exposure added on sub-schedule L.5 in a
manner that captures both derivative and securities financing transaction exposures.
The revisions did not result in a change to the estimated burden for this series of reports,
as the burden from the revisions is already captured in the burden estimates associated with the
FR Y-14Q report.
Respondent Panel
The respondent panel consists of any top-tier BHC that has $100 billion or more in total
consolidated assets, as determined based on (1) 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 (2) 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. The respondent panel also consists of any U.S. IHC. Reporting is required as of the
6

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

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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 outlines, 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 Subschedules
Summary,
Macro Scenario
Operational Risk and
Business Plan Changes
Schedules
CCAR Market Shock
exercise
Summary schedule
 Trading Risk
 Counterparty
Regulatory Capital
Instruments

Submission Date
to Board

Data as-of-date

FR Y-14A - Semi-annual Schedules
 December 31st.
 April 5th of the following year.
 June 30th.
 October 5th of the same year.
FR Y-14A - Annual Schedules
December 31st.

April 5th of the following year.

Data as of a specified date
in the first quarter that
would be communicated
by the Board.7

April 5th.

Data as-of December
31st.






7

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.8
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)).

See 12 CFR 252.14(b)(2). 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)).
8
The annual CCAR Instructions provide further information regarding adjustments a firm may make to its planned
capital distributions: https://www.federalreserve.gov/supervisionreg/ccar.htm.

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Schedules

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

Data as of each calendar
quarter-end.

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.

Due to the CCAR Market
Shock exercise, the as-of
date for the fourth quarter
would be communicated
in the subsequent quarter.

Trading Schedule
Counterparty Schedule

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

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

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 the
business day of each
following month.
calendar month.

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Legal Status
The Board has the authority to require BHCs to file the FR Y-14A/Q/M reports pursuant
to section 5 of the Bank Holding Company Act (BHC Act) (12 U.S.C. 1844), and to require the
U.S. IHCs of FBOs to file the FR Y-14 A/Q/M reports pursuant to section 5 of the BHC Act, in
conjunction with section 8 of the International Banking Act (12 U.S.C. 3106). The FR Y-14
A/Q/M reports are mandatory.
The information collected in these reports is collected as part of the Board’s supervisory
process, and therefore is afforded confidential treatment pursuant to exemption 8 of the Freedom
of Information Act (FOIA) (5 U.S.C. 552(b)(8)). In addition, individual respondents may
request that certain data be afforded confidential treatment pursuant to exemption 4 of FOIA if
the data has not previously been publically disclosed and the release of the data would likely
cause substantial harm to the competitive position of the respondent (5 U.S.C. 552(b)(4)).
Determinations of confidentiality based on exemption 4 of FOIA would be made on a case-bycase basis.
Consultation outside the Agency
On August 8, 2018, the Board published an initial notice in the Federal Register
(83 FR 39093) requesting public comment for 60 days on the revision, without extension, of
these reports. The comment period for this notice expired on October 9, 2018, and the Board
received one comment from a banking organization. The commenter requested that the Board
adopt these changes and publish the associated materials adopting these changes as soon as
possible to allow adequate time to implement the revision on the impacted schedules. Staff
strive to provide as much time as feasible in advance of the effective date for firms to implement
revisions. The draft forms and instructions were made available with the publication of the
initial notice. The revisions, including draft forms and instructions, will be implemented as
proposed with the reports as of December 31, 2018. On November 21, 2018, the Board
published a final notice in the Federal Register (83 FR 58771).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-14 is
estimated to be 858,384 hours. The proposed revisions would not result in an increase in burden.
These reporting requirements represent approximately 7.49 percent of the Board’s total
paperwork burden.
Estimated
number of
respondents9

Estimated
average hours
per response

Annual
frequency

Estimated
annual burden
hours

Current FR Y-14A
Summary

36

2

887

63,864

Macro scenario

36

2

31

2,232

9

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/document/support--table-size-standards.

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Estimated
number of
respondents9
36

1

Estimated
average hours
per response
18

Regulatory capital instruments

36

1

21

756

Business plan changes

36

1

16

576

5

1

100

500

Operational risk

Adjusted Capital Plan Submission

Annual
frequency

Current FR Y-14A Total

Estimated
annual burden
hours
648

68,576

Current FR Y-14Q
Retail

36

4

15

2,160

Securities

36

4

13

1,872

PPNR

36

4

711

102,384

Wholesale

36

4

151

21,744

Trading

12

4

1,926

92,448

Regulatory capital transitions

36

4

23

3,312

Regulatory capital instruments

36

4

54

7,776

Operational risk

36

4

50

7,200

MSR Valuation

15

4

23

1,380

Supplemental

36

4

4

576

Retail FVO/HFS

25

4

15

1,500

Counterparty

12

4

514

24,672

Balances

36

4

16

2,304

Current FR Y-14Q total

269,328

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

34

12

516

210,528

Home Equity

28

12

516

173,376

Credit Card

14

12

512

86,016

Current FR Y-14M total

469,920

Current Implementation and Ongoing Automation
Implementation
On-going revisions

0

1

7,200

0

36

1

480

17,280

Current Implementation and On-going
Automation total

17,280

Attestation
Implementation
On-going

0

1

4,800

0

13

1

2,560

33,280

7

Estimated
number of
respondents9
Current Attestation total

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours
33,280
858,384

Current Collection total

The estimated total annual cost to the public for this collection of information is $48,112,423.10
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 is $2,779,104 for ongoing costs.

10

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
$69, 15% Lawyers at $68, and 10% Chief Executives at $94). 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 2017, published March 30, 2018, www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

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