FFIEC030_FFIEC030S_20190215_omb

Supporting Statement for the
Foreign Branch Report of Condition
(FFIEC 030 and FFIEC 030S; OMB No. 7100-0071)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Foreign Branch Report of Condition
(FFIEC 030 and FFIEC 030S; OMB No. 7100-0071). Insured domestically chartered
commercial banks and savings associations (U.S. banks) that have one or more branch offices in
a foreign country are required to report balance sheet information for each of their foreign
branches on either the FFIEC 030 or the FFIEC 030S. The FFIEC 030 is collected annually as
of December 31 or quarterly for significant branches as of the last day of each calendar quarter;
the FFIEC 030S is an abbreviated reporting form filed annually by smaller institutions.
The Federal Reserve receives reports for all foreign branches of U.S. banks, regardless of
charter type, on behalf of the U.S. banks’ primary federal bank regulatory agency (Board,
Federal Deposit Insurance Corporation (FDIC), or Office of the Comptroller of the Currency
(OCC) (collectively the agencies)). The agencies use the FFIEC 030 and FFIEC 030S reports to
fulfill their statutory obligation to supervise foreign operations of domestic banks. Each of the
agencies separately clears the reports pursuant to the Paperwork Reduction Act, including with
regard to estimating respondent burden, for U.S. banks under their supervision. The Board
understands that the FDIC and the OCC are each submitting a similar request for OMB review
for U.S. banks under their supervision.
The agencies propose to revise the FFIEC 030 report by changing the instructions for
certain items to eliminate inconsistencies and to incorporate accounting changes related to
Financial Instruments—Credit Losses (Topic 326): Measurement of Credit Losses on Financial
Instruments” (ASU 2016-13). Additionally, the agencies propose to revise the FFIEC 030S
report to incorporate the effects of certain changes to the FFIEC 030 that are referenced in the
FFIEC 030S instructions. The current annual reporting burden for the FFIEC 030 and
FFIEC 030S is estimated to be 380 hours and would remain unchanged with the proposed
revisions.
Background and Justification
The FFIEC 030 and FFIEC 030S reports collect information on the structure and
geographic distribution of foreign branch assets and liabilities. The agencies use this information
to plan examinations and to analyze the foreign operations of U.S. banks, in connection with the
agencies’ statutory responsibility to assess the safety and soundness of the U.S. banks that they
supervise. The information collected by the FFIEC 030 and FFIEC 030S reports allows the
agencies to measure growth trends by bank, by country, and by bank within country.
Additionally, aggregate data that is publicly released by the agencies are a useful source of
information on U.S. bank activities for the general public. This series of data collected by these

reports is the oldest statistical series that exists for foreign branches of U.S. banks and is an
important source for measuring the growth of these offices.
The FFIEC 030 is the only report through which the agencies collect balance sheet
information on foreign branches of U.S. banks. The Board uses another report, the Quarterly
Report of Assets and Liabilities of Large Foreign Offices of U.S. Banks (FR 2502q; OMB No.
7100-0079), to collect less detailed balance sheet information from parent institutions of foreign
branches or subsidiaries (specifically, those with total assets of $500 million or more). The
FR 2502q report collects only gross assets and liabilities by the country of the principal address
of the customer, rather than the type of assets and liabilities of the branch. Although the
FR 2502q does not provide comparable information, the Board may check the FFIEC 030 to
verify that individual branches that report total assets greater than or equal to $500 million also
report on the FR 2502q.
Description of Information Collection
The FFIEC 030 is a two-page report that collects balance sheet information on all foreign
branches of U.S. banks, regardless of the size of the branch. Each data item of the FFIEC 030
relates directly to one or more data items on the Consolidated Reports of Condition and Income
for a Bank with Domestic and Foreign Offices (Call Report) (FFIEC 031; OMB No. 7100-0036);
no additional information is requested.
U.S. banks must file the report quarterly for foreign branches with total assets of at least
$2 billion or commitments to purchase foreign currencies and U.S. dollar exchange of at least
$5 billion (significant branches) and annually for all other foreign branches with total assets of
more than $250 million. Reporters may choose to file one consolidated report for all their
branches located in the same foreign country; however, reporters are not permitted to consolidate
data for significant branches with data for any other branches.
The FFIEC 030S is an abbreviated reporting form containing five data items that
branches with total assets between $50 million and $250 million file annually. These data items
are the minimum information needed to serve as indicators of higher business volume, risk, and
complexity in small-sized foreign branches. The reported information also is used to monitor
potential developments that may pose risks to the overall operations of the parent bank.
Branches with total assets of less than $50 million that do not meet the requirements to file the
FFIEC 030 quarterly are exempt from the filing requirements.
Proposed Revisions
FFIEC 030 Assets
All asset categories on the FFIEC 030 report are reported gross of any related allowances.
Allowances for credit losses, including loan and lease losses, are reported in line item 16, “Gross
due to head office, U.S. branches, and other foreign branches of this bank.” Currently, however,
the instructions for line item 8, “Gross due from head office, U.S. branches, and other foreign
branches of this bank,” also state that institutions should report any allowance for loan and lease

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losses and other valuation allowances in this line item. Effective March 31, 2019, the agencies
propose to remove this language from the line item 8 instructions since the allowance for loan
and lease losses and other valuation allowances are reported in line item 16. Additionally, the
agencies propose to add a statement to the instructions for balance sheet item 10, “Other assets,”
that specifies that institutions that have adopted ASU 2016-13 should exclude from this item any
accrued interest receivable that is reported elsewhere on the balance sheet as part of the related
financial asset’s amortized cost.
FFIEC 030 Liabilities
The gross due to amounts reported in Liabilities item 16, “Gross due to head office, U.S.
branches, and other foreign branches of this bank,” include any allowance for loan and lease
losses on the books of the reporting branch. To address the change in allowance nomenclature
arising from the broader scope of allowances under ASU 2016-13, effective March 31, 2019, the
agencies propose to revise the reporting instructions for Liabilities item 16, to change “any
allowance for loan and lease losses” to “any allowances for credit losses.” From March 31,
2019, through September 30, 2022, the instructions for item 16 would specify that institutions
that have not adopted ASU 2016-13 should continue to include the allowance for loan and lease
losses in this item.
FFIEC 030S Financial Data
Branches that file the FFIEC 030S report their “Gross due to related institutions” in
item 3. The instructions for item 3 state that this item corresponds to FFIEC 030 Liabilities
items 16 and 17.1 Thus, the effect of the proposed revisions to the instructions for FFIEC 030
Liabilities item 16, described above, would carry over to FFIEC 030S item 3.
Time Schedule for Information Collection
The FFIEC 030 and FFIEC 030S are collected annually as of December 31 from
U.S. banks with one or more branch offices in a foreign country and quarterly from U.S. banks
with significant branches as of the last calendar day of March, June, September, and December.
The FFIEC 030 and FFIEC 030S must be submitted within forty-five days of the report date by
qualifying U.S. banks, regardless of charter type, to the Federal Reserve Bank in the district in
which the U.S. bank’s main office is located. The Federal Reserve then compiles the reported
information and makes it available to the FDIC and the OCC four months after the as-of date for
both quarterly and annual reporters. Aggregate data are published in the Federal Reserve Annual
Report and the Department of Commerce’s Annual Statistical Digest. The individual responses
are confidential.
Legal Status
The Board is authorized to collect the information contained on the FFIEC 030 and
FFIEC 030S reports from state member banks under sections 9(3), 9(6) and 25(4) of the Federal

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Liabilities item 17 is used to report a branch’s “Gross due to consolidated subsidiaries of this bank.”

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Reserve Act (12 U.S.C. 321, 324, and 602). The obligation to respond is mandatory for U.S.
institutions with a foreign branch that has $50 million or more in total assets.
The information that is required to be provided on the FFIEC 030 and FFIEC 030S
reports is collected as part of the Board’s supervisory process. Accordingly, such information is
afforded confidential treatment under exemption 8 of the Freedom of Information Act (FOIA),
which protects information from disclosure that is contained in or related to the examination or
supervision of a financial institution (5 U.S.C. 552(b)(8)). In addition, publicly disclosing data
submitted by an individual respondent would likely cause substantial harm to the competitive
position of that respondent. Accordingly, such information may be withheld under exemption 4
of the FOIA (5 U.S.C. 552(b)(4)). In limited circumstances, aggregate data for multiple
respondents, which does not reveal the identity of any individual respondent, may be released.
Public Comments and Response
On September 28, 2018, the agencies, under the auspices of the FFIEC, published an
initial notice in the Federal Register (83 FR 49160) requesting public comment for 60 days on
the extension, with revision, of the FFIEC 030 and FFIEC 030S. The comment period for this
notice expired on November 27, 2018. No comments were received on the FFIEC 030 and
FFIEC 030S and the agencies will proceed with the revisions as originally proposed. On
February 14, 2019, the agencies published a final notice in the Federal Register (84 FR 4131).
Consultation outside the Agency
There has been no consultation outside of the Federal Reserve System.
Estimate of Respondent Burden
The current total annual reporting burden associated with the FFIEC 030 and
FFIEC 030S for U.S. banks supervised by the Board is estimated to be 380 hours, and would
remain unchanged with the proposed revisions. The total annual burden represents less than
1 percent of the total Federal Reserve System paperwork burden.

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FFIEC 030 and
FFIEC 030S
FFIEC 030
Annual (branches)
Quarterly (branches)
FFIEC 030S
Annual (branches)
Total

Number of
respondents2

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

14
24

1
4

3.4
3.4

48
326

11

1

0.5

6
380

The total cost to the public is estimated to be $21,299.3
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimated Cost to the Federal Reserve System
The annual cost to the Federal Reserve System for collecting and processing the
FFIEC 030 is estimated to be $30,300 and FFIEC 030S is estimated to be $4,900. The Federal
Reserve System collects and processes the data for all three of the agencies.

2

Of these respondents, 18 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.
3
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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