FRTT_20190826_omb

Supporting Statement for the
Reporting Requirements Associated with Regulation TT
(FR TT1; OMB No. 7100-0369)
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, with
revision, the Reporting Requirements Associated with Regulation TT (FR TT; OMB No.
7100-0369). The Board’s Regulation TT - Supervision and Regulation Assessments of Fees
(12 CFR 246) implements section 11(s) of the Federal Reserve Act (FRA),2 which directs the
Board to collect assessments, fees, or other charges (collectively, assessments) from bank
holding companies (BHCs) and savings and loan holding companies (SLHCs) that meet a
statutory size threshold and from all nonbank financial companies designated for Board
supervision by the Financial Stability Oversight Council (FSOC) (collectively, assessed
companies) in an amount equal to the total expenses the Board estimates are necessary or
appropriate to carry out its supervisory and regulatory responsibilities with respect to such
companies. Pursuant to Regulation TT, the Board issues an annual notice of assessment to each
assessed company. As described below, assessed companies may file a written appeal with the
Board regarding the assessment.3
Section 401(c) of the Economic Growth, Regulatory Relief, and Consumer Protection
Act (EGRRCPA) raised the size threshold in section 11(s) of the FRA for assessments for BHCs
and SLHCs from $50 billion to $100 billion in total consolidated assets. Therefore, BHCs and
SLHCs with total consolidated assets of at least $50 billion but less than $100 billion are no
longer subject to section 11(s) assessments.4 Accordingly, the Board has revised this collection
of information so that it no longer applies to such BHCs and SLHCs.
The current estimated total annual burden for the FR TT is 120 hours, and would remain
the same. There are no reporting forms associated with this information collection.
Background and Justification
Section 11(s) of the FRA directs the Board to collect assessments from assessed
companies equal to the expenses the Board estimates are necessary or appropriate to carry out its
supervision and regulation of those companies. Each calendar year is an assessment period.
Effective with the enactment of EGRRCPA, a BHC or SLHC is an assessed company for an
assessment period if the company’s average total consolidated assets over the assessment period
were at least $100 billion, and a nonbank financial company is an assessed company if it is a
1

The internal Agency Tracking Number previously assigned by the Board to this information collection was
“Reg TT”. The Board is changing the internal Agency Tracking Number for the purpose of consistency.
2
12 U.S.C. § 248(s). Section 11(s) of the Federal Reserve Act was added by section 318 of the Dodd-Frank Wall
Street Reform and Consumer Protection Act.
3
12 CFR 246.5(b).
4
The Board intends to publish a final rule to implement section 401(c) of EGRRCPA, which also requires the Board
to adjust the amount charged to assessed companies to reflect any changes in supervisory and regulatory
responsibilities resulting from EGRRCPA, in the near future.

Board-supervised nonbank financial company on December 31 of the assessment period.
Regulation TT provides that the Board must notify assessed companies of the amount of their
assessment no later than June 30 of the year following each assessment period.
Description of Information Collection
Section 246.5(b), Notice of Assessment and Appeal. Each assessed company has
30 calendar days from June 30 to submit a written statement to appeal the Board’s determination
that the company is an assessed company or its determination of the company’s total assessable
assets.
Respondent Panel
The FR TT panel comprises BHCs and SLHCs that meet a statutory size threshold and all
nonbank financial companies designated for Board supervision by the FSOC in an amount equal
to the total expenses the Board estimates are necessary or appropriate to carry out its supervisory
and regulatory responsibilities with respect to such companies.
Revisions to the FR TT
The Board has revised the respondent panel for the FR TT to include BHCs and SLHCs
with total consolidated assets of $100 billion or more, as well as all nonbank financial companies
designated for Board supervision by the FSOC. BHCs and SLHCs with total consolidated assets
of at least $50 billion but less than $100 billion have been removed as respondents to the revised
FR TT, as they are no longer subject to assessments under section 11(s) of the FRA.
Time Schedule for Information Collection
This information collection is event-generated. An assessed company electing to appeal
the Board’s assessment determination has 30 calendar days from June 30 to submit a written
appeal.
Public Availability of Data
There is no data related to this information collection available to the public.
Legal Status
The FR TT is authorized pursuant to section 11(i) of the FRA (12 U.S.C. § 248(i)),
which provides that the Board shall make all rules and regulations necessary to enable the
Board to effectively perform the duties, functions, or services specified in the FRA. The
FR TT is voluntary.
An assessed company may request confidential treatment of its appeal if it believes that
disclosure of specific commercial or financial information in the statement would likely result in
substantial harm to its competitive position. The determination that such information is

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confidential and not subject to disclosure under the Freedom of Information Act (FOIA) would
need to be made on a case-by-case basis, consistent with FOIA exemption 4 (5 U.S.C.
§ 552(b)(4)).
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On April 8, 2019, the Board published an initial notice in the Federal Register
(84 FR 13918) requesting public comment for 60 days on the extension, with revision, of the
FR TT. The comment period for this notice expired on June 7, 2019. No comments were
received. On August 12, 2019, the Board published a final notice in the Federal Register
(84 FR 39847).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR TT is 120
hours, and would stay the same with the revisions. The estimated average hours per request is 40
hours and would remain unchanged. However, the Board has adjusted the estimated number of
assessed companies that would submit a written request for appeal downward based on historical
experience. These reporting requirements represent less than 1 percent of the Board’s total
paperwork burden.

FR TT
Section 246.5(b)

Estimated
number of
respondents5

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

3

1

40

120

The estimated total annual cost to the public for this information collection is $6,912.6
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.

5

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), https://www.sba.gov/document/support--table-size-standards.
6
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, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Occupational Classification System, https://www.bls.gov/soc/.

3

Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting this information is
negligible.

4