BHCs and SLHCs

D
R
A
FT

Draft Revisions to the Instructions ĨŽƌ
the Regulatory Capital Reporting for
Institutions Subject to the Advanced
Capital Adequacy Framework (FFIEC 101)
for the Proposed Credit Loss Accounting
Revisions Proposed to Take Effect
March 31, 2019

These draft instructions, which are subject to change, reflect the proposed
revisions to the FFIEC 101 that would take effect March 31, 2019, as
described in the federal banking agencies’ final Paperwork Reduction Act
Federal Register notice for this proposal that was
published in February 14, 2019.

Draft as of February 15, 2019

Draft Revisions to the Instructions to the FFIEC 101
Proposed to Take Effect March 31, 2019

D
R
A
FT

Contents

Impacted Items

Page

6FKHGXOH $ ,WHP 

A-

Schedule A, Item 50

$

Schedule A, Item 76

$

Schedule A, Item 77

$

Schedule A, Item 90

$

Schedule A, Item 1.8

$

LINE ITEM INSTRUCTIONS FOR

Advanced Approaches Regulatory
Capital
Schedule A

D
R
A
FT

An institution that has elected to apply the CECL transition provision (electing institution) should include its
applicable CECL transitional amount, in accordance with section 301 of the regulatory capital rules. Specifically,
an electing institution should include 75 percent of its CECL transitional amount during the first year of the
transition period, 50 percent of its CECL transitional amount during the second year of the transition period, and
25 percent of its CECL transitional amount during the third year of the transition period.

General Instructions

Information collected on this FFIEC 101 Schedule A
will be publicly available for reports filed after an
advanced approaches institution conducts a satisfactory parallel run and for reports filed by institutions
subject to the SLR only. While the institution conducts
its parallel run, the information collected on this schedule will be publicly available, except for line items 78,
79, as well as items 86 through 90.

Item 3 Accumulated other comprehensive income
(AOCI).
Report the amount of the institution’s AOCI as
reported in Schedule RC-R of the Call Report or
Schedule HC-R of the FR Y-9C, item 3.

Item 4 Directly issued capital subject to phase out from
common equity tier 1 capital.
Not applicable: do not complete this line item.

The instructions below should be read in conjunction
with the regulatory capital rules issued by the reporting
institution’s primary federal supervisor, as well as the
reporting instructions for the Call Report, Schedule RC-R, or the FR Y-9C, Schedule HC-R. References to Schedule RC-R and Schedule HC-R item
numbers in the instructions for this Schedule A are to
items in Part I, not to items in Part II, of Schedule RC-R and Schedule HC-R.

Item 5 Common equity tier 1 minority interest
includable in common equity tier 1 capital.
Report the amount of the institution’s common equity
tier 1 minority interest includable in common equity
tier 1 capital as reported in Schedule RC-R of the Call
Report or Schedule HC-R of the FR Y-9C, item 4.

Item Instructions

Common equity tier 1 capital: adjustments and
deductions

Common Equity Tier 1 Capital

Item 7 Prudential valuation adjustments.
Not applicable: do not complete this line item.

Item 1 Common stock plus related surplus, net of
treasury stock.
Report the amount of the institution’s common stock
plus related surplus, net of treasury stock, as reported
in Schedule RC-R of the Call Report or Schedule HC-R of the FR Y-9C, item 1.
Item 2 Retained earnings.
Report the amount of the institution’s total retained
earnings as reported in Schedule RC-R of the Call
Report or Schedule HC-R of the FR Y-9C, item 2.

Item 6 Common equity tier 1 capital before regulatory
deductions and adjustments.
Report the sum of items 1, 2, 3, and 5.

Item 8 Goodwill net of associated deferred tax
liabilities (DTLs).
Report the amount of the institution’s goodwill net of
associated DTLs as reported in Schedule RC-R of the
Call Report or Schedule HC-R of the FR Y-9C, item 6.
Item 9 Other intangible assets, net of associated
DTLs, other than goodwill and mortgage servicing
assets (MSAs).
Report the amount of the institution’s intangible assets
(other than goodwill and MSAs), net of associated
A-1

FFIEC 101

June 2017

Schedule A

Item 50: Electing Institutions subtract the applicable portion of the
eligible credit reserves transitional amount from this item, in
accordance with section 301 of the regulatory capital rules.
Specifically, an electing institution subtracts 75 percent of its eligible
credit reserves transitional amount during the first year of the
transition period, 50 percent of its eligible credit reserves transitional
amount during the second year of the transition period, and 25
percent of its eligible credit reserves transitional amount during the
third year of the transition period.

Item 53 Reciprocal cross-holdings in the tier 2 capital
of unconsolidated financial institutions.
Report the amount of the institution’s total reciprocal
cross-holdings in tier 2 capital of unconsolidated
financial institutions as included in Schedule RC-R of
the Call Report or Schedule HC-R of the FR Y-9C,
item 33.

D
R
A
FT

Item 48 Total capital minority interest that is not
included in tier 1 capital.
Report the amount of the institution’s total capital
minority interest not included in tier 1 capital as
reported in Schedule RC-R of the Call Report or
Schedule HC-R of the FR Y-9C, item 29.

Item 49 of which: instruments subject to phase out.
Report the portion of the institution’s total capital
minority interest that is not included in tier 1 capital
that is subject to phase out.

Item 50 Eligible credit reserves includable in tier 2
capital.
If the institution has completed its parallel run process:
If eligible credit reserves exceed total expected credit
losses, then report the amount by which eligible credit
reserves exceed expected credit losses, up to a maximum amount of 0.60 percent of credit risk-weighted
assets. or adjusted allowances for credit losses (AACL), if
applicable.

If the institution is in the parallel run process: Report
the amount of the institution’s allowable allowance for
loan and leases losses includable in tier 2 capital, as
reported in Schedule RC-R of the Call Report or
Schedule HC-R of the FR Y-9C, item 30.a. In addition, report eligible credit reserves includable in tier 2
capital in this Schedule A, item 79. This amount is confidential while the institution is in the parallel run process. Once the institution has completed its parallel run
process, the reported amount is publicly available on
this schedule and on Schedule RC-R of the Call Report
or Schedule HC-R of the FR Y-9C, item 30.b.
Item 51 Tier 2 capital before deductions.
Report the sum of items 46, 47, 48, and 50, plus the
amount reported in Schedule RC-R of the Call Report
or Schedule HC-R of the FR Y-9C, item 31.

Tier 2 capital deductions

Item 52 Investments in own tier 2 capital instruments.
Report the amount of the institution’s total investments in own tier 2 capital instruments as included in
Schedule RC-R of the Call Report or Schedule HC-R
of the FR Y-9C, item 33.

Item 54 Non-significant investments in the tier 2
capital of unconsolidated financial institutions that
exceed the 10 percent threshold for non-significant
investments.
Report the amount of the institution’s non-significant
investments in the tier 2 capital of unconsolidated
financial institutions that exceed the 10 percent threshold for non-significant investments, as included in
Schedule RC-R of the Call Report or Schedule HC-R
of the FR Y-9C, item 33.
Item 55 Significant investments in financial institutions
not in the form of common stock to be deducted from
tier 2 capital.
Report the amount of the institution’s total significant
investments in financial institutions not in the form of
common stock to be deducted from tier 2 capital as
included in Schedule RC-R of the Call Report or
Schedule HC-R of the FR Y-9C, item 33.
Item 56 Other deductions from tier 2 capital.
Report the amount of the institution’s other deductions from tier 2 capital as included in Schedule RC-R
of the Call Report or Schedule HC-R of the FR Y-9C,
item 33 that are not included in items 52 through 55 of
this schedule.
Advanced approaches institutions with insurance
underwriting activities: include 50 percent of the
amount equal to the regulatory capital requirement for
insurance underwriting risks established by the regulator of any insurance underwriting activities of the
institution.
Item 57 Total tier 2 capital deductions.
Report the sum of items 52 through 56.

Item 58 Tier 2 capital.
Report the greater of: item 51 less item 57 or zero.

A-6
June 2017
March 2019

FFIEC 101

Schedule A

For institutions that have not yet adopted ASU 2016-13, report

Limitations on the amount of provisions
included in tier 2 capital

Item 71 Minimum total capital ratio: 8.0%.
Not applicable: do not complete this line item.

Item 76 Total allowance for loan and lease losses
(ALLL) under the standardized approach.
Report the amount of total ALLL under the standardized approach, which is equal to Schedule RC, item 4.c,
“Allowance for loan and lease losses,” less Schedule RI-B, part II, Memorandum item 1, “Allocated
transfer risk reserve included in Schedule RI-B, part II,
item 7, above,” plus Schedule RC-G, item 3, “Allowance for credit losses on off-balance sheet credit
exposures.”

D
R
A
FT

Item 70 Minimum tier 1 capital ratio: 6.0%.
Not applicable: do not complete this line item.

Amounts not deducted as a result of
applicable thresholds (before riskweighting)

Item 72 Non-significant investments in the capital of
unconsolidated financial institutions that are not
deducted.
Report the amount of non-significant investments in
the capital of unconsolidated financial institutions that
are not deducted from common equity tier 1, additional tier 1 or total capital (that is, not reported in
items 18, 39, and 54 of this Schedule A).
Item 73 Significant investments in the capital of
unconsolidated financial institutions in the form of
common, net of associated DTLs, stock that are not
deducted.
Report the amount of significant investments in the
capital of unconsolidated financial institutions in the
form of common stock, net of associated DTLs, that
are not deducted from common equity tier 1 (that is,
not reported in items 19 or 23 of this Schedule A).

Item 74 MSAs net of associated DTLs that are not
deducted.
Report the amount of MSAs net of associated DTLs
that are not deducted from common equity tier 1 capital (that is, not reported in items 20 or 24 of this Schedule A).

Item 75 DTAs arising from temporary differences that
could not be realized through net operating loss
carrybacks, net of related valuation allowances and net
of DTLs, that are not deducted.
Report the amount of DTAs arising from temporary
differences that could not be realized through net operating loss carrybacks, net of related valuation allowances and net of DTLs, that are not deducted from
common equity tier 1 capital (that is, not reported in
items 21 or 25 of this Schedule A).

See Insert A.

Item 77 Amount of ALLL includable in tier 2 capital
under the standardized approach. or AACL, if applicable,
Report the amount of the institution’s ALLL includable in tier 2 capital under the standardized approach
as reported in Schedule RC-R of the Call Report or
Schedule HC-R of the FR Y-9C, item 30.a.
Items 78 and 79 are kept confidential on reports filed
during an institution’s parallel run process.

Item 78 Total eligible credit reserves (calculated using
advanced approaches).
Report the amount of total eligible credit reserves.
Item 79 Amount of eligible credit reserves includable in
tier 2 capital.
If eligible credit reserves exceed total expected credit
losses, then report the amount by which eligible credit
reserves exceed expected credit losses, up to a maximum amount of 0.60 percent of credit risk-weighted
assets.

Non-qualifying capital instruments

Item 80 Cap on common equity tier 1 non-qualifying
capital instruments subject to phase-out.
Report 0 for this item.
Item 81 Amount of common equity tier 1
non-qualifying capital instruments excluded.
Report 0 for this item.
A-9

FFIEC 101

June 2017
March 2019

D
R
A
FT

Insert A
For Call Report filers that have adopted ASU 2016-13, report the amount of total AACL under
the standardized approach, which is equal to Schedule RI-B, part II, item 7, sum of Columns A
and B, "Balance end of current period: Loans and leases held for investment and Held-tomaturity debt securities," and Memorandum item 6, "Allowance for credit losses on other
financial assets carried at amortized cost (not included in item 7, above)" less Schedule RC-R,
part II, Memorandum items 4.a, 4.b, and 4.c, "Amount of allowances for credit losses on
purchased credit-deteriorated assets: Loans and leases held for investment, Held-to-maturity
debt securities, and Other financial assets measured at amortized cost," less Schedule RI-B,
part II, Memorandum item 1, "Allocated transfer risk reserve included in Schedule RI-B, part II,
item 7, column A, above," plus Schedule RC-G, item 3, "Allowance for credit losses on offbalance sheet credit exposures."
s
For FR Y-9C filers that have adopted ASU 2016-13, report the amount of total AACL under the
standardized approach, which is equal to Schedule HI-B, part II, item 7, sum of Columns A and
B, "Balance end of current period: Loans and leases held for investment and Held-to-maturity
debt securities," and Memorandum item 6, "Allowance for credit losses on other financial assets
carried at amortized cost (not included in item 7, above)," less Schedule HC-R, part II,
Memorandum items 5.a, 5.b, and 5.c, "Amount of allowances for credit losses on purchased
credit-deteriorated assets: Loans and leases held for investment, Held-to-maturity debt
securities, and Other financial assets measured at amortized cost," less Schedule HI-B, part II,
Memorandum item 1, "Allocated transfer risk reserve included in Schedule HI-B, part II, item 7,
column A, above," plus Schedule HC-G, item 3, "Allowance for credit losses on off-balance
sheet credit exposures."

FFIEC 101

Schedule A

deduct from item 29 the amount of expected credit loss
that exceeds eligible credit reserves, reported in item 86,
subject to the transition provisions. To calculate the
denominator of this ratio, the institution must use the
amount of the advanced approaches risk-weighted
assets reported in item 87. Round the ratio to four decimal places.

D
R
A
FT

Example: A depository institution holding company
has $100 in tier 1 non-qualifying capital instruments
subject to phase out as of January 1, 2014. These are
the amounts that it would report in items 82 and 84,
notwithstanding any reduction in tier 1 non-qualifying
capital instruments subject to phase out:
Calendar year

2014
2015
2016
2017

Item 82: Cap on
additional tier 1 nonqualifying capital
instruments subject
to phase out

Item 84: Cap on tier 2
non- qualifying capital
instruments subject to
phase out

50 (table 4)
25 (table 4)
0 (table 4)
0 (table 4)

50 (table 4)
75 (table 4)
60 (table 6)
50 (table 6)

b. Depository institutions: multiply the aggregate
principal amount of non-qualifying tier 2 capital
instruments that were outstanding as of January 1, 2014 by the percentage in Table 5 for the
corresponding calendar year.

Item 85 Amount of tier 2 non-qualifying capital
instruments excluded.
Report the total amount of instruments that were
excluded from tier 2 capital as a result of the application of the cap in Schedule A, item 84.

Memoranda

Note: Items 86-90 are kept confidential on reports filed
during an institution’s parallel run process.

Item 86 Expected credit loss that exceeds eligible credit
reserves.
Report the amount of expected credit loss that exceeds
the amount of eligible credit reserves, as calculated
under the advanced approaches rules.
Item 87 Advanced approaches RWA (from
FFIEC 101, Schedule B, item 36).
Report the amount of the institution’s total RWAs calculated under the revised advanced approaches rules.

Item 88 Common equity tier 1 capital ratio (calculated
using advanced approaches).
If an institution is in the parallel run process: Report
common equity tier 1 capital ratio calculated using the
revised advanced approaches rules. Specifically, to calculate the numerator of this ratio, an institution must

After the institution completes its parallel run process:
Report common equity tier 1 capital ratio calculated
under the revised advanced approaches rules as item 29
divided by item 60, rounded to four decimal places.
Item 89 Tier 1 capital ratio (calculated using advanced
approaches).
If an institution is in the parallel run process: Report
tier 1 capital ratio calculated using the revised
advanced approaches rules. Specifically, to calculate
the numerator of this ratio, add (i) common equity tier
1 capital reported in item 29, net of expected credit loss
that exceeds eligible credit reserves, reported in item 86,
subject to the transition provisions, and (ii) additional
tier 1 capital as reported in item 44. To calculate the
denominator of this ratio, the institution must use the
amount of the advanced approaches risk-weighted
assets reported in item 87. Round the ratio to four decimal places.
After the institution completes its parallel run process:
Report tier 1 capital ratio calculated using the
advanced approaches rule as item 45 divided by
item 60, rounded to four decimal places.
Item 90 Total capital ratio (calculated using advanced
approaches).
If an institution is in the parallel run process: Report
total capital ratio calculated using the revised advanced
approaches rules. Specifically, to calculate the numerator of this ratio, add (i) common equity tier 1 capital
reported in item 29, net of expected credit loss that
exceeds eligible credit reserves, reported in item 86,
subject to the transition provisions, (ii) additional tier 1
capital as reported in item 44, and (iii) tier 2 capital
reported in item 58, net of the institution’s allowance
for loan and lease losses reported in item 50 and plus
eligible credit reserves includable in tier 2 capital as
reported in item 79. To calculate the denominator of
this ratio, the institution must use the amount of the
advanced approaches risk-weighted assets reported in
item 87. Round the ratio to four decimal places.

or adjusted allowances for credit losses, if applicable,
FFIEC 101

A-11
June 2017
March 2019

Schedule A
An institution that has elected to apply the CECL transition provision (electing institution) should include its
applicable CECL transitional amount, in accordance with section 301 of the regulatory capital rules. Specifically,
an electing institution should include 75 percent of its CECL transitional amount during the first year of the
transition period, 50 percent of its CECL transitional amount during the second year of the transition period, and
25 percent of its CECL transitional amount during the third year of the transition period.

for exposures to derivatives transactions in SLR
Table 1, item 1.4, and repo-style transactions in SLR
Table 1, item 1.5, that are reported on a quarter end
basis and the mean of the amount calculated for these
components as of each day of the reporting quarter.

D
R
A
FT

This amount may be positive, negative, or zero. The
value will be zero for this item if there is no difference
between the quarter end value reported in SLR Table 1,
item 1.1 and the mean of the amount of total consolidated assets calculated as of each day of the reporting
quarter. Report this amount as a negative value if the
mean of the amount of total consolidated assets calculated as of each day of the reporting quarter is greater
than the quarter end value reported in SLR Table 1,
item 1.1. Report this amount as a positive value if the
mean of the amount of total consolidated assets calculated as of each day of the reporting quarter is less
than the quarter end value reported in SLR Table 1,
item 1.1.

any such repo-style transaction. Also include in this
item the amount of on-balance sheet cash and collateral received from a counterparty in derivative transactions and the amount of on- balance sheet receivable
(or other) assets resulting from the posting of cash to
counterparties in derivative transactions.

Item 1.8 Total leverage exposure.
Report the sum of SLR Table 1, items 1.1 through 1.6,
minus items 1.7a and 1.7b. This item must equal SLR
Table 2, item 2.21.

SLR Table 2: Supplementary leverage ratio

On-balance sheet exposures

An institution must report the following amounts with
respect to its on-balance sheet exposures.

Item 1.2 The balance sheet carrying value of all
on{balance sheet assets (excluding on{balance sheet
assets for derivative transactions and repo{style
transactions, but including collateral).
Report the balance sheet carrying value, of all on{
balance sheet assets (excluding on{balance sheet carrying value for derivative transactions and repo{style
transactions), net of allowance for loan and lease losses
(ALLL) as defined in the regulatory capital rule. Specifically, do not include in this item the value of receivables in reverse repurchase transactions. However,
include in this item securities provided in a repurchase
agreement, securities pledged in a securities borrowing
transaction, securities lent in a securities lending transaction, and cash and other collateral received under

Report this item as the mean of the amount calculated
as of each day of the reporting quarter.
Financial subsidiaries:

If a financial subsidiary is not consolidated into the
institution for purposes of the institution’s balance
sheet, exclude from this item the quarterly average for
the institution's ownership interest in the financial subsidiary accounted for under the equity method of
accounting that is included in the institution’s balance
sheet carrying value of all on-balance sheet assets in
this item 2.1.
If a financial subsidiary is consolidated into the institution for purposes of the institution’s balance sheet,
exclude from this item the quarterly average of the
assets of the subsidiary that is included in the institution’s balance sheet carrying value of all on-balance
sheet assets in this item 2.1, minus any deductions from
common equity tier 1 capital and additional tier 1 capital attributable to the financial subsidiary that have
been included in SLR Table 2, item 2.2. Include in this
item the quarterly average of institution assets representing claims on the financial subsidiary, other than
the institution’s ownership interest in the subsidiary,
that were eliminated in consolidation.
Because the institution’s claims on the subsidiary were
eliminated in consolidation, these assets would not
otherwise be included.
Non-includable subsidiaries:

A savings association with a non-includable subsidiary
should make similar exclusions from SLR Table 2,
item 2.1, determined in the same manner as described
above for financial subsidiaries, except that for a nonincludable subsidiary accounted for under the equity
method of accounting, the exclusion should be the
quarterly average for the savings association’s outstanding investments (both equity and debt) in, and
extensions of credit to, the subsidiary.

A-15
FFIEC 101

June 2017
March 2019