FR2034_20190726_omb

Supporting Statement for the
Senior Credit Officer Opinion Survey on Dealer Financing Terms
(FR 2034; OMB No. 7100-0325)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years,
without revision, the Senior Credit Officer Opinion Survey on Dealer Financing Terms (SCOOS)
(FR 2034; OMB No. 7100-0325).1 This survey collects qualitative and limited quantitative
information from senior credit officers at responding financial institutions on (1) stringency of
credit terms, (2) credit availability and demand across the entire range of securities financing and
over-the-counter derivatives transactions, and (3) the evolution of market conditions and
conventions applicable to such activities. The FR 2034 survey will be conducted quarterly, along
with the Senior Loan Officer Opinion Survey on Bank Lending Practices (FR 2018; OMB No.
7100-0058). The survey contains 79 core questions divided into three broad sections, as well as
additional questions on topics of timely interest.
Given the Board’s interest in financial stability, the information this survey collects is
critical to the monitoring of credit markets and capital market activity. Information from the
survey is also considered by the FOMC as it sets monetary policy. Aggregate survey results are
made available to the public on the Board’s website.2 In addition, selected aggregate survey
results may be discussed in Governor’s speeches and may be published in Federal Reserve
Bulletin articles and in the annual Monetary Policy Report to the Congress.
The current reporting panel consists of up to 25 U.S. banking institutions and
U.S. branches and agencies of foreign banks, the majority of which are affiliated with a Primary
Government Securities Dealer;3 however, other types of respondents, such as other depository
institutions, bank holding companies, or other financial entities, may be surveyed when
appropriate. The estimated total annual burden for the FR 2034 is 500 hours.
Background and Justification
The FR 2034 survey is modeled after the long-established Senior Loan Officer Opinion
Certain criteria apply to information collections conducted via the Board’s ad hoc clearance process. Such
information collections shall (1) be vetted by the Board’s clearance officer as well as the Division director
responsible for the information collection, (2) display the OMB control number and respondents shall be informed
that the information collection has been approved, (3) be used only in such cases where response is voluntary,
(4) not be used to substantially inform regulatory actions or policy decisions, (5) be conducted only and exactly as
described in the OMB submission, (6) involve only noncontroversial subject matter that will not raise concerns for
other Federal agencies, (7) include information collection instruments that are each conducted only one time,
(8) include a detailed justification of the effective and efficient statistical survey methodology (if applicable), and (9)
collect personally identifiable information (PII) only to the extent necessary (if collecting PII, the form must display
current privacy act notice). In addition, for each information collection instrument, respondent burden will be
tracked and submitted to OMB.
2
See https://www.federalreserve.gov/data/scoos.htm.
3
A list of the current Primary Dealers in Government Securities is available at
https://www.newyorkfed.org/markets/primarydealers.html.
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Survey on Bank Lending Practices (FR 2018), which provides qualitative information on
changes in the supply of, and demand for, bank loans to businesses and households. The
information obtained from the FR 2018, which has been conducted in different forms since 1964,
provides valuable insights on developments in the credit market and banking developments and
informs the formulation of monetary policy.
This information has been particularly valuable in recent years because it has provided
the Board with insight into the effects of financial conditions on the availability of credit to
households and businesses. However, the global financial crisis highlighted that a significant
volume of credit intermediation has moved outside of the traditional banking sector, which is the
primary focus of the FR 2018. In addition, some of the instruments that are commonly used in
connection with such intermediation (including for the financing of securities positions and overthe-counter derivatives) may have functioned as transmission mechanisms for financial distress
during the crisis by connecting together seemingly separate parts of the financial system. For
these reasons, the monetary policy responsibilities of the Board and the Board’s role in
promoting and maintaining the stability of the financial system,4 the Board decided to expand the
collection of qualitative information on the availability of credit and leverage beyond the
traditional banking sector to the extension of credit by dealers.5
On March 30, 2010, the Federal Reserve implemented FR 2034 to facilitate the regular
collection and analysis of information representing the informed judgment of market participants
on these additional forms of credit extension. Unlike the large domestically-chartered
commercial banks and branches and agencies of foreign banks that make up the pool of
respondents targeted by the FR 2018, this survey targets respondents of a different and smaller
subset of market participants, representing activities not conducted solely in a bank, but in
several different legal entities, focused on the consolidated entity.
Description of Information Collection
The questions on the Senior Credit Officer Opinion Survey are mainly qualitative in
nature. They are intended to elicit useful information without imposing an undue reporting
burden and do not request information that is collected through other means. To understand
certain market conventions and practices, however, the Board may occasionally need to ask
specific quantitative questions. When quantitative information is requested in response to special
questions, respondents may be asked to provide approximate or rough estimates.
The survey contains 79 core questions divided into three broad sections. The first section
focuses on credit terms applicable to counterparties of different types, spanning a variety of
different transactions. The second section contains credit terms applicable to over-the-counter
derivatives counterparties, distinguishing among contracts referencing different underlying
assets. The third section deals with information about the financing terms provided for certain
4

For example, as a member of the Financial Stability Board formed at the behest of the G-20 Finance Ministers and
Central Bank Governors.
5
The Group of Twenty (G-20) consists of finance ministers and central bank governors from 19 systemically
important industrial and developing countries plus the European Union, who convene regularly to consider key
issues related to global economic stability.

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security positions. In addition, a small number of non-recurring questions relating to current
developments in credit and capital markets are generally asked. The survey is conducted through
a web interface designed and maintained by the Statistics Function of the Federal Reserve Bank
of New York, with follow-up as necessary via telephone. The primary contact at each responding
institution is a senior credit officer who has perspective on all relevant activities conducted by
the institution.
Respondent Panel
The activities that are the focus of the adopted Senior Credit Officer Opinion Survey may
be conducted by large financial institutions through multiple business units. For example, a
significant volume of securities financing may be conducted from a prime brokerage platform,
but this does not preclude similar activities from also occurring on trading desks in order to make
markets in the securities being financed or on centralized securities financing desks. Similarly,
over-the-counter derivative transactions may occur on dedicated equity volatility or interest rate
derivatives desks that are primarily engaged in derivatives transactions, but also may occur in
entities that trade both derivatives and cash such as corporate credit or commodities units.
The panel of up to 25 firms includes, with respect to respondents that are primary dealers,
the consolidated entities affiliated thereof. Respondents may also include institutions that, while
not primary dealers, play a significant role in over-the-counter derivatives or securities financing
activities.
Time Schedule for Information Collection and Publication
The FR 2034 is voluntary. The survey is conducted once each quarter by the Statistics
Function of the Federal Reserve Bank of New York. The Statistics Function electronically
transmits the survey responses to the Board, where the data are tabulated and summarized in a
public release, which is made available on the Board’s website. In addition, selected aggregate
survey results may be discussed in Governor’s speeches, and may be published in Federal
Reserve Bulletin articles and in the annual Monetary Policy Report to the Congress.
Legal Status
The FR 2034 is authorized pursuant to sections 2A and 12A of the Federal Reserve Act
(FRA). Section 2A of the FRA requires that the Board and the Federal Open Market Committee
(FOMC) maintain long-run growth of the monetary and credit aggregates commensurate with the
economy’s long run potential to increase production, so as to promote effectively the goals of
maximum employment, stable prices, and moderate long-term interest rates (12 U.S.C. § 225a).
Under section 12A of the FRA, the FOMC is required to implement regulations relating to the
open market operations conducted by Federal Reserve Banks. Those transactions must be
governed with a view to accommodating commerce and business and with regard to their bearing
upon the general credit situation of the country (12 U.S.C. § 263). The Board and the FOMC use
the information obtained from the FR 2034 to help fulfill these obligations. The FR 2034 is
voluntary.

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Information collected on the FR 2034 is granted confidential treatment under exemption
(b)(4) of the Freedom of Information Act (5 U.S.C. § 552(b)(4)), which protects from disclosure
“trade secrets and commercial or financial information obtained from a person and privileged or
confidential.”
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On April 17, 2019, the Board published an initial notice in the Federal Register
(84 FR 16014) requesting public comment for 60 days on the extension, without revision, of the
FR 2034. The comment period for this notice expired on June 17, 2019. The Board did not
receive any comments. On July 19, 2019, the Board published a final notice in the Federal
Register (84 FR 34890).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2034 is 500
hours. Actual respondent burden for this survey would likely vary depending on how many of
the authorized surveys are actually carried out and on the specific content of each questionnaire.6
These reporting requirements represent less than 1 percent of the Board’s total paperwork
burden.

FR 2034

Estimated
number of
respondents7

Current

25

Estimated
Estimated
Annual
average hours annual burden
frequency
per response
hours
4

5

500

The estimated total annual cost to the public for this collection of information is
$28,800.8
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
6

Actual burden underlying the average assumed five hour response time varies considerably not only from survey to
survey, depending on the number and nature of the questions, but also among respondents for any one survey.
7
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/content/small-business-size-standards.
8
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 $19, 45% Financial Managers at
$71, 15% Lawyers at $69, and 10% Chief Executives at $96). 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 2018, published March 29, 2019 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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OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
survey is $84,200.

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