FR3052_20190219_omb

Supporting Statement for the
Supervisory and Regulatory Survey
(FR 3052; OMB No. 7100-0322)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated
authority from the Office of Management and Budget (OMB), proposes to extend for three years,
without revision, the Supervisory and Regulatory Survey (FR 3052; OMB No. 7100-0322). The
FR 3052 collects information from financial institutions specifically tailored to the Federal
Reserve’s supervisory, regulatory, and operational responsibilities. Examples of past surveys
include collected information related to regulatory capital, operational risk loss event history, and
transactions by securities dealers. The frequency and content of the questions depend on
changing economic, regulatory, supervisory, or legislative developments. Respondents may
include bank holding companies (BHCs), state member banks (SMBs), savings and loan holding
companies (SLHCs), intermediate holding companies (IHCs), U.S. branches and agencies of
foreign banking organizations (FBOs), Edge Act and agreement corporations, non-bank financial
companies that the Financial Stability Oversight Council (FSOC) has determined should be
supervised by the Board, or the combined domestic operations of FBOs. Since the collected data
may change from survey to survey, there is no fixed reporting form.
The surveys would be conducted on a voluntary basis. The number of respondents per
survey and the number of surveys conducted per year may fluctuate. Based on past use of the
FR 3052, the Board estimates that the survey could be conducted up to 24 times per year, with an
average of 5,000 respondents per survey. The annual reporting burden for the FR 3052 would be
capped at 60,000 hours.
Background and Justification
The Board has long conducted surveys to help fulfill its statutory responsibilities of
supervising and regulating financial institutions to ensure safe and sound banking practices and
compliance with regulations. In some cases, surveys have provided the only available source of
information with regard to certain financial conditions and business activities. Surveys are
driven by the specific needs of the Board, but aggregated findings have also been used
extensively by researchers outside the Federal Reserve System and other financial industry
regulators.
The Board occasionally needs to gather time-sensitive data from the banking and
financial industries on financial conditions or particular business activities outside of the
standard regulatory reporting process. The data may be particularly needed in times of critical
economic or regulatory changes or when issues of immediate concern arise from supervisory
initiatives, requests from the Board of Governors, or the U.S. Congress.
The Board implemented the FR 3052 in 2009 to facilitate certain supervisory and
regulatory surveys. Past surveys have collected information related to regulatory capital,
Comprehensive Capital Analysis and Review, operational risk loss event history, transactions by

government securities dealers, small debit card issuers, and the Basel III framework.
Description of Information Collection
The Board utilizes the survey process, as needed, to collect information on specific issues
that affect its decision making. The principal value of the FR 3052 is the flexibility it provides
the Federal Reserve to respond quickly to the need for data due to unanticipated economic,
financial, supervisory, or regulatory developments. The Board cannot predict what specific
information will be needed, but such needs are generally very time sensitive. Because the
relevant questions may change with each survey, there is no fixed reporting form.
Written qualitative questions or questionnaires may include categorical questions, yes-no
questions, ordinal questions, and open-ended questions. Written quantitative surveys may
include dollar amounts, percentages, numbers of items, interest rates, and other such information.
Institutions may also be required to provide copies of existing documents (for example,
pertaining to practices and performances for a particular business activity). Before conducting a
survey, the Board reviews any information to be collected to determine if the information is
available by other means.
Surveys are generally conducted by the staff at the Board and Reserve Banks as part of
ongoing supervisory activities. The decision to conduct a particular survey takes into
consideration resource requirements. In most cases, the Federal Reserve uses examination staff
to conduct the survey, leveraging existing contacts and work assignments.
The Board welcomes feedback from firms on surveys conducted under the FR 3052, both
formally, through frequently asked questions, and informally via outreach sessions, ad-hoc
discussions, and e-mails. As a general matter, the Board is unable to guarantee the release of
surveys under the FR 3052 for notice and comment because of the quick turnarounds sometimes
required. However, when a survey template is available in advance of the planned distribution
date, the Board works to distribute the template to respondents early for information purposes,
and when time allows, to obtain feedback.
Time Schedule for Information Collection and Publication
The data submission timeline for each survey would be determined before distribution of
the survey materials to respondents. In soliciting participation, the Board would explain to
respondents the purpose of the survey and how the data would be used.
The Board will choose whether to publish survey data that it obtains from respondents
and will inform the respondents beforehand if the data are to be published on an individualinstitution basis. Aggregate survey information may be cited in published material such as
Board studies or working papers, professional journals, the Federal Reserve Bulletin, testimony
and reports to the Congress, or other vehicles.

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Legal Status
The FR 3052 is authorized pursuant to section 9 of the Federal Reserve Act (FRA) (12
U.S.C. 324) for SMBs; section 5 of the Bank Holding Company Act (12 U.S.C. 1844(c)(1)(A))
for BHCs and their subsidiaries; section 10 of the Home Owners’ Loan Act (12 U.S.C.
1467a(b)(1)) for SLHCs and their subsidiaries; section 7(c)(2) of International Banking Act
(IBA) (12 U.S.C. 3105(c)(2)) for the U.S. branches and agencies of foreign banks; section 8 of
the IBA (12 U.S.C. 3106) for FBOs; sections 25 and 25A of the FRA (12 U.S.C. 602 and 625)
for Edge Act and agreement corporations; and section 161 of the Dodd-Frank Wall Street
Reform and Consumer Protection Act (12 U.S.C. 5361) for nonbank financial companies
designated by FSOC for supervision by the Board. The surveys would be conducted on a
voluntary basis.
The questions asked on each survey would vary, so the ability of the Board to maintain
the confidentiality of information collected would be determined on a case by case basis. It is
possible that the information collected would constitute confidential commercial or financial
information, which may be kept confidential under exemption 4 to the Freedom of Information
Act (FOIA) (5 U.S.C. 552(b)(4)). In circumstances where the Board collects information related
to individuals, exemption 6 to FOIA would protect information “the disclosure of which would
constitute a clearly unwarranted invasion of personal privacy” (5 U.S.C. 552(b)(6)). To the
extent the information collected relates to examination, operating, or condition reports prepared
for the use of an agency supervising financial institutions, such information may be kept
confidential under exemption 8 to FOIA (5 U.S.C. 552(b)(8)).
Consultation outside the Agency
At this time, there has been no consultation outside the Federal Reserve System;
however, surveys can be conducted jointly with other agencies. If this were to occur, the Federal
Reserve would consult with other agencies, to the extent practicable, to create a consistent set of
questions or a substantively similar information collection.
On August 28, 2018, the Board published an initial notice in the Federal Register
(83 FR 43870) requesting public comment for 60 days on the extension, without revision, of the
FR 3052. The comment period for this notice expired on October 29, 2018. The Board did not
receive any comments. On January 31, 2019, the Board published a final notice in the Federal
Register (84 FR 720).
Estimate of Respondent Burden
The annual burden for the proposed FR 3052 survey would be capped at 60,000 hours as
shown in the table below. Because the number of surveys and respondents will fluctuate
depending on the number and types of topics being considered, it is not possible to predict
exactly how many will be conducted in a given year. For the purposes of this estimate, it is
assumed that the survey will be conducted up to 24 times per year and average 5,000 respondents
per survey. Respondents may include BHCs, SMBs, SLHCs, IHCs, U.S. branches and agencies
of FBOs, Edge Act and agreement corporations, nonbank financial companies that the FSOC has

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determined should be supervised by the Board, and the combined domestic operations of FBOs.
Based on previous data collections, the Board estimates that the average time per response will
be approximately 30 minutes. These reporting requirements represent less than 1 percent of total
Federal Reserve System paperwork burden.

FR 3052

Number of
respondents1

Annual
frequency

5,000

24

Estimated
average hours
per response
0.5

Estimated
annual burden
hours
60,000

The current annual cost to the public of these reports is estimated to be $3,363,000.2
Sensitive Questions
This information collection would contain no questions of a sensitive nature, as defined
by OMB guidelines.
Estimate of Cost to the Federal Reserve System
The cost of the surveys depends on the size of the sample, the number of questions asked,
the type and complexity of the questions asked, and the frequency of the surveys. The cost to the
Federal Reserve System for the FR 3052 is estimated to be $201,500.

1

Of these respondents, 4,150 respondents 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-sizestandards.
2
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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