Country Exposure Report

Board of the Governors of the Federal Reserve System

Instructions for the Preparation of

Country Exposure Report
Reporting Form FFIEC 009
Effective March 2019

Contents

General Instructions for the Preparation of the Country Exposure Report

........................................................................................................................ GEN-1
A. Introduction and Purpose .............................................................................................................. GEN-1
B. Summary Description of this Report .............................................................................................. GEN-1
C. Administrative Issues ..................................................................................................................... GEN-2
D. Who Must Report ......................................................................................................................... GEN-2
E. Accounting Issues .......................................................................................................................... GEN-4
F. Submission of Reports ................................................................................................................... GEN-4
G. Legal Entity Identifier (LEI) .......................................................................................................... GEN-5
II. Reporting Definitions ..................................................................................................................... GEN-5
A. Claims .......................................................................................................................................... GEN-5
B. Liabilities ...................................................................................................................................... GEN-5
C. “Immediate-Counterparty” and “Ultimate-Risk” Claims ................................................................. GEN-5
D. Sector Definitions ......................................................................................................................... GEN-6
E. Cross-Border Claims and Claims on Local Residents ....................................................................... GEN-7
F. Required Risk Transfers ................................................................................................................. GEN-8
G. Netting and Offsetting ................................................................................................................... GEN-9
H. Reporting Credit Derivatives ........................................................................................................ GEN-10
III. Specific Instructions for Allocating Claims to the Rows .................................................................. GEN-11
A. The United States ........................................................................................................................ GEN-11
B. Foreign Countries ........................................................................................................................ GEN-11
C. International and Regional Organizations ..................................................................................... GEN-12
I. General Instructions

Line Item Instructions for the Preparation of the Country Exposure Report

................................................................................................................................ C-1
Schedule L—Foreign-Office Liabilities ...................................................................................................... L-1
Schedule O—Off-Balance-Sheet Items ...................................................................................................... O-1
Schedule D—Claims from Positions in Derivative Contracts ...................................................................... D-1
Appendix A—Summary of Reporting Bases by Schedule and Column ................................................ App A-1
Schedule C—Claims

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INSTRUCTIONS FOR PREPARATION OF THE

Country Exposure Report

I. General Instructions

and the purchase of credit protection as defined in
Sections II.F and II.H.

A. Introduction and Purpose

Schedule C, Part II, collects information on the reporter’s claims on an ultimate-risk basis and memorandum
items providing additional details related to those
claims. Claims on an ultimate-risk basis are shown in
Columns 1 through 11 of Schedule C, Part II. Schedule C, Part II, also contains memorandum items relating to claims reported on an ultimate-risk basis. Column 12 shows the amounts reported in Columns 1
through 10 of Schedule C, Part II, that are held-tomaturity and available-for-sale securities. Columns 13
through 16 collect information on collateral mitigants
that do not meet the criteria for the purposes of risk
transfers of claims as defined in this report. Column 17
shows the amount of claims, on an ultimate-risk basis
(reported in Columns 1 through 10 of Part II), that are
held for trading. Column 18 provides any offsetting
positions held for the trading book, where an effective
offset exists (see Section II.G for a discussion of effective netting and offsetting).

The FFIEC 009 provides information on the distribution, by country, of claims on, and liabilities to, the
United States (U.S.) and foreign residents held by U.S.
reporting entities. The data collected are used to determine the presence of credit and related risks, including
transfer and country risk. These data are also aggregated and released to the public. Aggregate data are
provided to the Bank for International Settlements
(BIS), as part of an international cooperative effort to
compile and publish global data on claims on local and
foreign residents. The aggregated data, along with
applicable individual data reported on the FFIEC
009a, are available electronically through the E.16 Statistical Release (http://www.ffiec.gov/E16.htm).

B. Summary Description of this Report
The FFIEC 009 consists of four schedules (with one,
Schedule C, containing two parts).
Schedule C, Part I, collects information on the claims
on an “immediate-counterparty” basis, i.e., on the
basis of the country of residence of the borrower
(except claims resulting from the fair value of derivative contracts). Part I also includes the redistribution of
immediate-counterparty claims to an “ultimate-risk”
basis, i.e., on the basis of the country of residence of
the guarantor or collateral provided (i.e., the “ultimate
obligor”). In Columns 1 through 12 of Part I, data are
collected on an immediate-counterparty basis. In
Columns 13 through 22 of Part I, the inward and outward redistribution of claims from an immediatecounterparty basis to an ultimate-risk basis is
shown. These redistributions arise from arrangements
such as formal guarantees, the provision of collateral,

Schedule L collects information on foreign-office
liabilities. Columns 1 and 2 show, by country and currency, foreign-office liabilities for which no payment is
guaranteed at locations outside the country of the
office, reported by the country of the foreign office.
Column 3 shows all liabilities booked at foreign offices
by the country of the creditor. Column 4 shows the net
positions of the foreign office with related offices in
other countries. These net positions are not reported
elsewhere on this report, due to the consolidation rules.
Schedule O collects information on off-balance-sheet
exposures from commitments, guarantees, and credit
derivatives. Column 1 collects any unused or undrawn
commitments, on an ultimate-risk basis, by country of
the ultimate obligor of the commitment. In Column 2,
the amount of all legally binding guarantees provided,
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General Instructions

except credit derivatives written, are reported by country of the counterparty to whom the guarantee is being
provided. Columns 3 through 6 provide a breakdown
of the notional amount of credit derivatives positions
purchased and sold (by country of the reference
entity), on a gross gross and gross-net basis (see Section II.H for definitions of these terms). Credit derivatives purchased that result in a risk transfer on Schedule C, Parts I and II, are excluded from this schedule.
Column 7 shows the claims, on an ultimate-risk basis
(reported in Columns 1 through 10 of Schedule C,
Part II, and Columns 1 and 2 of Schedule O), that are
trade finance related.
Schedule D collects information on the fair value of
derivative contracts of the reporter by country of
counterparty (including the United States). A sector
distribution and the total are collected in Columns 1
through 5. In Column 6, claims on bank branches that
are not formally and legally guaranteed by the head
office are reported in the country rows corresponding
to the country in which the branch is located (instead
of the country of the head office). These claims represent risk that could potentially remain in the countries
in which the branches are located.

C. Administrative Issues

• Federal Deposit Insurance Corporation – Sections 7
and 10 of the Federal Deposit Insurance Act
(12 U.S.C. 1817 and 1820)

2. Confidentiality
The individual FFIEC 009 reports are given confidential treatment under 5 U.S.C. 552(b)(4) and (b)(8).
However, aggregated data that do not reveal the activities of individual reporting entities do not receive confidential treatment and are made public. Portions of
the aggregated data are also reported to the Bank for
International Settlements as part of an international
cooperative effort to compile and publish worldwide
data on cross-border claims.

D. Who Must Report
Reporting Entities
The Country Exposure Report (FFIEC 009) is
required to be filed quarterly by banks, savings associations, Edge and/or Agreement corporations, bank
holding companies, intermediate holding companies,
and savings and loan holding companies meeting the
criteria listed below:
Schedules C, L, and O must be completed by:

1. Authority
This report is required to be filed by national banks,
federal savings associations, state member banks, Edge
and/or Agreement corporations, bank holding companies, savings and loan holding companies, intermediate
holding companies, insured state nonmember commercial and savings banks, and insured state savings associations pursuant to authority contained in the following statutes:
• Board of Governors of the Federal Reserve System –
Section 11a of the Federal Reserve Act (12 U.S.C.
248a), Section 5c of the Bank Holding Company Act
(12 U.S.C. 1844c), and Section 907 of the International Lending Supervision Act of 1983 (12 U.S.C.
3906), and Section 165(a) of the Dodd-Frank Act
(12 U.S.C. 5365(a)); and
• Office of the Comptroller of the Currency – the
National Bank Act, as amended (12 U.S.C. 161) and
Home Owners Loan Act (12 U.S.C. 1464);

(1) Every U.S. chartered insured bank or savings
association in the 50 States of the United States,
the District of Columbia, Puerto Rico, and U.S.
territories and possessions, that has, on a fully
consolidated basis, total outstanding claims on
residents of foreign countries exceeding $30 million in the aggregate, and has at least one of the
following:
• A branch in a foreign country;
• A consolidated subsidiary in a foreign
country;
• An Edge or Agreement subsidiary;
• A branch in Puerto Rico or in any U.S. territory or possession (except that a bank or savings association with its head office in Puerto
Rico or any U.S. territory or possession need
not report if it meets only this criterion); or
• An International Banking Facility (IBF).

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General Instructions

All references to “bank(s)” are inclusive of
“savings association(s),” unless otherwise
noted.
(2) Every Edge and/or Agreement corporation that
has total outstanding claims on residents of foreign countries exceeding $30 million, unless it is
majority owned by a bank or savings association
that is required to file a report.
(3) Every institution that meets the Schedule D
reporting requirements (see below).
(4) Every U.S. bank holding company that is required
to file the FR Y-6 report (Bank Holding Company
Annual Report) and has a subsidiary bank that is
required to file this report.
(5) Every savings and loan holding company and
intermediate holding company that meets the criteria for banks in (1) above. All references to
“bank holding company(s)” are inclusive of “savings and loan holding company(s),” and “intermediate holding company(s)” unless otherwise
noted.1
However, to reduce reporting burden:
(1) If a bank holding company has only one subsidiary bank that meets the reporting requirements
and that subsidiary bank accounts for 90 percent
or more of the consolidated holding company’s
total claims on foreigners, either the holding company or the bank (but not both) should prepare a
report. However, if the only subsidiary bank that
is required to report accounts for less than 90 percent of the consolidated holding company’s
claims, only the holding company should prepare
a (consolidated) report
(2) If a bank holding company has two or more subsidiary banks that meet the reporting requirements and these subsidiary banks, together,
account for 90 percent or more of the consolidated holding company’s total claims on foreign1. Savings and loan holding companies (SLHCs) do not include any
trust (other than a pension, profit-sharing, stockholders’ voting, or
business trust) which controls a savings association if such trust by its
terms must terminate within 25 years or not later than 21 years and
10 months after the death of individuals living on the effective date of
the trust, and (a) was in existence and in control of a savings association
on June 26, 1967, or, (b) is a testamentary trust.

ers, the holding company need not file a separate
report.
Column 3 of Schedule L—Total Liabilities Booked at
Foreign Offices (by country of creditor)—is required
to be reported only by those reporters that have one or
more branches or subsidiaries located outside the fifty
states of the United States, the District of Columbia,
or a U.S. military facility (regardless of where located)
that meet the following criteria:
• Branches filing the Foreign Branch Report of Condition (FFIEC 030) that report total assets of
$500 million or more (denominated in all currencies)
on Line Item 11 on a report date,
• Subsidiaries filing the quarterly Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314) that have a banking charter and
engage in banking business, and that report $2 billion or more in total assets in Schedule BS, item 10,
and $10 million or more in total deposits in Schedule BS-M, item 6.
The total assets test defined above applies to the total
of the foreign branch’s or subsidiary’s international
and local assets, regardless of the currency in which the
assets are payable. If any foreign office of a reporter
exceeds the reporting threshold, then column 3 should
be completed for the reporter’s entire organization and
not just for the offices exceeding the threshold.
A Schedule D must be completed by every institution
whose FFIEC 031 or FR Y-9C (or for Edge and/or
Agreement corporations the FR 2886b) as of December 31 of the previous year shows:
(1) Total gross notional values of derivative contracts
(the sum of items 7.a.(1) through 7.a.(4), Columns
A and B, and items 12.a. through 12e., Columns A
through D, on Schedule RC-L of the FFIEC 031
or the sum of items 7.a.(1) through 7.a.(4), Columns A and B, and items 11.a. through 11.e., Columns A through D, on Schedule HC-L of the
FR Y-9C) in excess of $10 billion.
or
(2) Total gross fair values of derivative contracts (the
sum of items 7.b.(1) and 7.b.(2), Columns A and B
and items 15.a. and 15.b., Columns A through D,
on Schedule RC-L of the FFIEC 031 or the sum
of items 7.b.(1) and 7.b.(2), Columns A and B,
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and items 14.a. and 14.b., Columns A through D,
on Schedule HC-L of the FR Y-9C) in an amount
greater than 5 percent of their total assets.
In addition, the bank regulatory authorities may specifically require a report (or any specific schedule
therein) to be filed by other banking organizations that
the authorities deem to have significant country
exposures.

1. Differences between FFIEC 009 Reporting
and U.S. GAAP
The differences in accounting treatment between the
FFIEC 009 and U.S. GAAP are as follows:
Reporting Item

U.S. GAAP

FFIEC 009

Netting of Derivative Contracts

Offsetting of positive
and negative fair values are permitted
when a “right of setoff ” exists under
ASC Subtopic 21020, Balance SheetOffsetting (formerly
FASB Interpretation
No. 39, Offsetting of
Amounts Related to
Certain Contracts).
Although there is no
official FASB pronouncement, it is
industry practice to
net trading assets
against trading
liabilities in the same
security (i.e., with the
same CUSIP or
ISIN).

Offsetting of positive
and negative fair values
is permitted, consistent
with U.S. GAAP. However, only net positive
fair values are reported
on the FFIEC 009.

Consolidation Rules
The information should be reported on a fully consolidated basis. For reports from banks, the scope of coverage and the consolidation of information should be
in accordance with the procedures and tests of significance set forth in the instructions for preparation of
the FFIEC 031. For reports from bank holding companies, the information should be consolidated in
accordance with the principles set forth in the instructions for the preparation of the FR Y-9C. For Edge
and/or Agreement corporations, the information
should be consolidated in accordance with the principles set forth in the instructions for the preparation of
the FR 2886b.
As a best practice, the data reported on the
FFIEC 009 can be reconciled to the FR Y-9C (or Call
Report). However, there are no requirements to perform such a reconciliation.

E. Accounting Issues
All amounts should be reported in U.S. dollars regardless of the currencies in which the balances are denominated. The translations should be made on the same
basis used to prepare its (or its subsidiary bank’s)
FFIEC 031 and the FR Y-9C.
Claims, liabilities, and unused commitments should be
reported using the same accounting basis as used on
the FFIEC 031 and FR Y-9C, unless stated otherwise
in these instructions.
Edge and/or Agreement corporations should reference
the instructions for the preparation of the
FFIEC 031 for further information on reporting definitions and generally accepted accounting principles.
Round all amounts reported on this form to the nearest
million dollars. Negative amounts are only permissible
in Column 4 of Schedule L.

Netting of Trading
Assets

CUSIP netting is
allowed for the
FFIEC 009 report. In
addition, short positions in the same issuer
and asset class of the
trading asset may be
reported as an offsetting position on Schedule C, Part II, Column 18.

F. Submission of Reports
The FFIEC 009 report is to be prepared quarterly, as
of the last calendar day of March, June, September,
and December. For each quarter the reporting requirements are met (according to Section I.D), all reporting
entities must use the Federal Reserve System’s Reporting Central system to submit their completed report to
the Federal Reserve Bank of New York (FRBNY). The
submission deadline is 45 calendar days after the
March 31, June 30, and September 30 as of date. The
submission deadline is 50 calendar days after the
December 31 as of date.
If the submission deadline falls on a weekend or holiday, the report must be received on the first business
day after the Saturday, Sunday, or holiday.
The Federal Reserve System Website (http://
www.frbservices.org/centralbank/index.html) provides
additional information on Reporting Central. The

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General Instructions

Website also includes a link that reporters may use to
contact FRBNY for technical assistance.
Each reporting entity should keep a copy of each
report. This copy should be signed and certified by an
Executive Officer (as defined in 12 CFR 215.2(e)(1)) of
the reporting entity.

G. Legal Entity Identifier (LEI)
The LEI is a 20-digit alpha-numeric code that uniquely
identifies entities that engage in financial transactions.
A reporting institution must provide its LEI on the
cover page of this report only if it already has an LEI.
The LEI must be a currently issued, maintained, and
valid LEI, not an LEI that has lapsed. If a reporting
institution does not have an LEI, it is not required to
obtain one for purposes of reporting it on this report.

II. Reporting Definitions
A. Claims
The term “claims” follows the definition for assets in
the instructions for preparation of the FFIEC 031 and
FR Y-9C and includes, but is not limited to, the following types of assets:
• Deposit balances, both interest bearing and noninterest bearing, held at banks

cable to current or prior periods, but not yet
collected)
• Resale agreements and other financing agreements
(reported net if permitted under ASC Topic 210-20,
previously FIN 41)
• Asset sales with recourse
• Participations and syndications of loans
Exclude:
Premises, other real estate owned, goodwill, and other
intangible assets.

B. Liabilities
The term “liabilities” follows the definition in the
instructions for preparation of the FFIEC 031 and
FR Y-9C and includes, but is not limited to, the following types of liabilities:
• Deposit balances, both interest bearing and noninterest bearing.
• Brokerage balances
• Debt securities
• Borrowings
• Short sales

• Balances with central banks and official institutions

• Repurchase agreements and other financing agreements (reported net if permitted under ASC Topic
210-20, previously FIN 41)

• Securities

• Trade date payables

• Federal funds sold
• Loans
• Holdings of acceptances of banks
• Direct lease financing
• Investments in unconsolidated subsidiaries and associated companies
• Positive fair value of interest rate, foreign exchange,
equity, commodity and other derivative contracts
(reported in Schedule D)
• Customers’ liability on acceptances outstanding
• Accrued income receivables (including interest, commissions and income earned or accrued and appli-

C. “Immediate-Counterparty” and
“Ultimate-Risk” Claims
Claims are to be reported on an “immediatecounterparty” basis in Columns 1 through 12 of
Schedule C, Part I, and on an “ultimate-risk” basis in
Columns 1 through 10 of Schedule C, Part II. The obligor on an immediate-counterparty basis is the entity
that issued the security or otherwise incurred the liability. The obligor of a claim on an ultimate-risk basis is
any person, business, institution, or instrument that
provides any of the types of credit protection described
in Section II.F, “Required Risk Transfers” and Section II.H “Reporting Credit Derivatives.”
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D. Sector Definitions

3. Non-Bank Financial Institutions (NBFIs)

Reporting sectors are determined based on the legal
entity of the counterparty. The following sector definitions are used for all columns of this report that require
sector distinctions:

Non-bank financial institutions are defined as businesses and institutions other than “banks” and “public,” as defined above, that are primarily engaged in
proprietary investments and/or in the provision of
financial services to other organizations and households. These services include, but are not limited to,
financial intermediation services whose functions are
predominantly: the extension of credit for business
purposes, brokerage services (engaged in the brokering
of securities, commodities or other financial instruments), underwriting services, financial management
services, credit origination services, credit card services,
insurance services, and pension services. Types of nonbank financial organizations include, but are not limited to:

1. Banks
The definition of banks encompasses all institutions
included in “Banks, U.S. and Foreign” in the Report of
Condition as well as savings banks, savings associations, discount houses, and other similar depository
institutions. Banks also include banking institutions
owned by foreign governments, unless such institutions
function as central banks or banks of issue, in which
case they are treated as “public” institutions.
Exposures to banks are to be reported in Columns 1, 6,
13, and 18 of Schedule C, Part I; Columns 1 and 6 of
Schedule C, Part II; and Column 1 of Schedule D.

• Securities firms
• Bank holding companies (BHCs)
• Insurance firms
• Money market funds

2. Public
The definition of the public sector is similar to “Foreign Governments and Official Institutions” in the
Report of Condition, but also includes public sector
institutions in the U.S. Public sector institutions
include:
• Central, state, provincial and local governments and
their departments, and agencies
• Treasuries, ministries of finance, central banks, stabilization funds, exchange authorities, and diplomatic
establishments
• Those government owned banks, including development banks, that perform as an important part of
their activities, the functions of a treasury, central
bank, exchange control office, or stabilization fund
• International or regional organizations or subordinate or affiliated agencies thereof, created by treaty
or convention between sovereign states, including the
International Monetary Fund, the International
Bank for Reconstruction and Development (World
Bank), the Bank for International Settlements, the
Inter-American Development Bank, and the United
Nations

• Pension funds
• Investment banks
• Private equity companies
• Credit card issuers
• Hedge funds
• Trusts
• Finance companies
• Mortgage companies
• Factors and other financial intermediaries who
extend short-term business credit to finance inventories or carry accounts receivable
This sector excludes federal, state, and local governments; however, it includes agencies and instrumentalities of governments such as pension funds and insurance companies that provide nonbank financial
services that are not directly governmental in nature.
Exposures to NBFIs are to be reported in Columns 3,
8, 15, and 20 of Schedule C, Part I; Columns 3 and 8 of
Schedule C, Part II; and Column 3 of Schedule D.

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4. Corporate
The corporate sector is defined as any organization,
including a non-profit, that is principally engaged in
producing goods or non-financial services. This sector
excludes federal, state, and local governments; however, it includes agencies and instrumentalities of governments such as utilities that produce goods or nonfinancial services that are not strictly governmental in
nature.
Report as Corporate any organization that cannot be
classified as “Bank,” “Public,” “NBFI,” or
“Household.”
Exposures to corporate counterparties are to be
reported in Columns 4, 9, 16 and 21 of Schedule C,
Part I; Columns 4 and 9 of Schedule C, Part II; and
Column 4 (under “Other”) of Schedule D.

5. Households
Include in the household sector all claims on households, families, and individuals for personal expenditures (using the same definition of households as used
in the FR Y-9C, Schedule HC-C, item 6, “Loans to
individuals for household, family, and other personal
expenditures”). Therefore, any reportable claims on
households should be reported, regardless of the product type (e.g., loans and consumer leases).
Exposures to households would be reported in Columns 5, 10, 17, and 22 of Schedule C, Part I; Columns
5 and 10 of Schedule C, Part II; and Column 4 (under
“Other”) of Schedule D.

6. Other
The “Other” sector applies only for reporting on
Schedule D and the FFIEC 009a “Country Exposure
Information Report.” The “Other” sector refers to
those counterparties classified as Corporate or Households, as defined above.

• All claims of its U.S. offices (including IBFs, Edge
and Agreement corporations, and offices in Puerto
Rico and U.S. territories and possessions) with residents of foreign countries, regardless of the currency
in which the claim is denominated; and,
• All claims of each of its offices in a foreign country
with residents of other countries (i.e., countries other
than the country in which the office is located,
including the United States), regardless of the currency in which the claim is denominated.
Since the reports are on a fully consolidated bank (or
bank holding company) basis, cross-border claims
exclude any claims against those branches or subsidiaries that are part of the consolidated bank (or bank
holding company). However, claims on unconsolidated
subsidiaries or associated companies of the reporter
should be reported. Thus, a banking subsidiary that
submits an FFIEC 009 report should include claims on
subsidiaries of the bank’s parent holding company.

2. Claims on Local Residents
Claims on local residents are all claims of the institution’s offices, regardless of location (including the
U.S.), on residents of the country in which the office is
located. The definition of “cross-border claims” and
“claims on local residents” is the same on an
“immediate-counterparty” basis and an “ultimaterisk” basis. However, some claims may be categorized
differently, or be placed in different sectors or country
rows, because the sector or country of residence of the
immediate obligor may differ from that of the ultimate
obligor.
Claims of the institution’s U.S. office(s) on a resident
of the United States should be reported as a claim on a
local resident, while claims of the institution’s foreign
office(s) on a resident of the United States should be
reported as a cross-border claim.

3. “Local” vs. “Non-Local” Currency

E. Cross-Border Claims and Claims on
Local Residents
1. Cross-Border Claims
Cross-border claims of each reporter cover:

A currency is considered to be a “local” currency of a
country only if the country, directly or through a currency union, has the authority to issue that currency.
Thus, U.S. dollars would not be considered to be the
local currency of any country other than the United
States, whereas euros would be considered to be the
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local currency of any country that is a member of the
European Monetary Union, but of no other country.

See Section II.F.5 for treatment of guarantees provided
in the form of cash and debt or equity securities held as
collateral. See Section II.H.1 for treatment of guarantees in the form of purchased credit derivatives.

F. Required Risk Transfers

Ownership of fund shares in an unconsolidated investment entity should be reported on an immediate and
ultimate risk basis according to the country and sector
of the investment entity. The underlying assets of the
investment fund do not provide an effective guarantee
for purposes of the FFIEC 009 report.

The outward and inward redistribution of claims from
an “immediate-counterparty” basis to an “ultimaterisk” basis is reported in Columns 13 through 22 of
Schedule C, Part I. Outward risk transfers are reported
in Columns 13 through 17, and inward risk transfers
are reported in Columns 18 through 22.
If full credit protection is provided by more than one
source, e.g., from multiple guarantors or multiple
forms of collateral, the ultimate-risk claim should be
determined by the sector and residence of the highest
rated credit enhancer (using the reporter’s internal rating system). For instance, for a claim on a bank branch
for which eligible collateral is posted, it should be
determined whether the counterparty’s parent bank or
the collateral has a higher credit rating. The claim
should then be reported, accordingly, on an ultimaterisk basis.

2. Insurance Policies
Insurance policies that guarantee payment of a claim if
the borrower defaults or if non-convertibility occurs
should be reallocated to the non-bank sector of the
country of residence of the entity providing the insurance. However, limited purpose policies, such as
“political risk insurance” policies should not be used as
a basis for reallocation. Conversely, if a reporter issues
an insurance policy guaranteeing the payment of a
claim if a foreign borrower defaults, the amount of the
protection sold should be reported in Column 2 of
Schedule O, “Guarantees (Excluding Credit Derivatives Sold).”

1. Guarantees
Guarantees are legally binding commitments by a third
party to repay a debt if the direct obligor fails to do so.
Guarantees include financial and performance standby
letters of credit and acceptances (for the amount of the
participation sold). Documents that do not establish
legal obligations, such as “comfort” letters, letters of
awareness, or letters of intent, are not guarantees for
the purpose of this report.
Guarantees provided by the reporter’s head office or
other consolidated units of the reporter should not be
considered guarantees for the purposes of this report.
Guarantees providing protection to the reporter
should result in the reallocation of the claim from the
sector and country row of the immediate borrower (in
Columns 13 through 17 of Schedule C, Part I) to the
sector and country row of the provider of the guarantee (in Columns 18 through 22 of Schedule C, Part I).
Conversely, if the reporter provides a guarantee on a
foreign credit, the amount of the guarantee should be
reported in Column 2 of Schedule O, “Guarantees
(Excluding Credit Derivatives Sold).”

3. Head Offices
For the purposes of this report, claims on a bank
branch (but not on a subsidiary) of a banking organization are considered to be guaranteed by the head
office of the organization, even without a legally binding agreement. Therefore, claims on bank branches
should be reallocated to the bank sector in the country
in which the parent institution is chartered.

4. Credit Derivatives
See Section II.H.

5. Collateralized Claims
Eligible collateral for risk transfers on the
FFIEC 009 includes collateral that is:
(1) Liquid and readily realizable, and
(2) Is realizable outside of the country of residence of
the borrower.
Eligible collateral includes:

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General Instructions

Cash
If collateral is in the form of cash, the sector and country of the “guaranteeing” party is the sector and country of residence of the legal entity where the cash is
held (i.e., the legal entity that has the liability for the
cash collateral). Cash collateral posted to the same sector and country as the immediate claim should result in
no risk transfer.

should be reported on Schedule D according to the
sector and country of the institution holding (or issuing) the collateral, and the uncollateralized portion
should be reported according to the sector and country
of the counterparty.
Assets such as real estate are not liquid or readily realizable and thus cannot be used for a risk transfer.

Debt and Equity Securities

6. Risk Participations

If collateral is in the form of investment grade debt or
marketable equity securities, the sector and country of
the “guaranteeing” party is the sector and country of
residence of the party issuing the security.

Loans and acceptances, where the reporting bank has
sold a legally binding risk participation, are considered
to be guaranteed by the purchaser of the participation
for the amount of the participation sold.

However, in the case of resale agreements, securities
lending arrangements, and other similar financing agreements, the claims should be allocated based on the counterparty, not the underlying collateral (i.e., no risktransfer should be made). These should be reported at
the value of the outstanding claim, regardless of the
amount of collateral provided. Resale agreements should
also be reported by country of the counterparty in the
memorandum section of Schedule C, Part II. (See Section V.B.2.)
If the collateral consists of a basket of convertible currencies or investment grade securities of different
countries in an amount equal to the immediate claim,
break out the underlying exposures on a pro-rata basis
and report opposite the appropriate country and
sector.
Collateral provided in the form of cash or securities in
excess of the amount of the outstanding claim (e.g., a
margin loan collateralized by securities with a fair
value that exceeds the amount of the margin loan)
should only be risk-transferred up to the amount of
the underlying claim (see Example 22 of Section V.C).
The ultimate-risk claim should be reported by the sector and country of the highest rated credit enhancer(s) (using the reporter’s internal rating system).
Collateral provided by obligors to offset positive fair
value positions of derivative contracts should be
reported in Schedule D, using the same methodology
for reporting securities and cash collateral as stated
above. If the reporter has a derivative contract with a
positive fair value, and cash (or securities) collateral is
provided, the collateralized portion of the fair value

G. Netting and Offsetting
Netting and offsetting of long and short positions is
not permitted on the FFIEC 009 report with the exception of the following:
(1) “CUSIP netting”2 may be conducted and
reported on Schedule C, Parts I and II, or Schedule L, as appropriate. CUSIP netting should only
be applied when the office of the reporter with the
position, the country of the issuer of the underlying security, and the counterparty to a short position are in the same country.
(2) On Schedule C, Part II, report in Column 18 positions entered into for the purpose of offsetting the
trading positions reported in Column 17, “Trading Assets.” See Section V.B.3.
(3) On Schedule O, report in Columns 5 and 6, as
appropriate, the net notional value of credit
derivative contracts purchased from and sold to
the same counterparty and on the same underlying reference entity. See Section VII.C.2.
(4) On Schedule D, the positive fair values of derivative contracts may be offset against negative fair
values of derivatives contracts if, and only if, the
positions were executed with the same counterparty under a legally enforceable master netting
agreement and the offsetting meets the ASC Sub2. “CUSIP netting” refers to the industry practice where trading
assets and trading liabilities in the same exact security (based on its
security identifier) may be reported on a net basis.

GEN-9
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General Instructions

topic 210-20 criteria. Otherwise, positive fair values must be reported gross.
In addition, reverse repurchase agreements may be
offset by repurchase agreements if, and only if, the
transactions were executed with the same counterparty under a legally enforceable master repurchase agreement (including multi-jurisdictional
and multi-branch master netting agreements) and
the offsetting meets the criteria in ASC Subtopic
210-20, Balance Sheet—Offsetting. When repurchase agreements are covered by master repurchase agreements, net claim positions should be
reported on Schedule C, Parts I and II. In addition, for purposes of the FFIEC 009, net claims
resulting from repurchase agreements under
multi-jurisdictional and/or multi-branch master
repurchase agreements are considered guaranteed
by counterparty’s head office, or the designated
office (“the counterparty”) subject to the agreement, and should be reported in the country of
the counterparty on both an immediate and ultimate risk basis.

H. Reporting Credit Derivatives
1. Risk Transfers
Reporters should report credit derivative contracts
purchased, (including, but not limited to, credit default
swaps and options, total return swaps and sovereign
risk options), as guarantees for purposes of this report,
provided the institution considers the arrangement to
be an effective credit risk mitigant based on its internal
criteria and provided the contract contains provisions
to pass the credit risk to the counterparty. A reporter’s
internal criteria should, at a minimum, include provisions that ensure the terms of credit derivatives provide
an effective guarantee, even in the case of a maturity
mismatch, prohibit clauses that reduce the effectiveness
of the guarantee in the case of default, contain effectual events of default, and reference the same legal
entity as the obligor.
Claims for which credit derivatives form an effective
risk transfer should be reallocated to the sector and
country of residence of the entity that is providing the
protection.

Credit protection purchased to guarantee a claim
reported on an immediate counterparty basis should
only be reported on Schedule C, Parts I and II. Credit
protection purchased to hedge or offset credit protection
sold, or for trading purposes, should be excluded from
Schedule C and reported in Columns 3 and 5 of Schedule O, as appropriate.
If the notional amount of the credit protection purchased is less than the amount of the immediate claim,
the notional amount of the guaranteed portion should
be reallocated to the sector and country of the credit
protection seller, and the non-guaranteed portion
should be reported opposite the sector and country of
the immediate obligor in Columns 1 through 10 of
Schedule C, Part II.
If the notional amount of the credit protection purchased exceeds the value of the immediate claim, the
immediate claim should be reported in Columns 13
through 17 and reallocated, at the same amount of the
immediate claim, to the sector and country of the seller
of the credit derivative in Columns 18 through 22 of
Schedule C, Part I, and in Columns 1 through 10 of
Schedule C, Part II. The excess or residual amount (the
full notional amount minus the amount risktransferred) should be reported in Column 3 of Schedule O (and in Column 5, if appropriate).
Contracts with a positive fair value should be reported
on Schedule D. For contracts with variable notional
principal amounts, report the notional principal
amounts as-of the report date.

2. Treatment of Multi-Name Credit Derivatives
Purchases and sales of credit derivatives guaranteeing
multiple underlying reference entities (i.e., multi-name
instruments, including portfolio or basket credit
default swaps (CDS), CDS indexes, and “tranched”
CDS contracts) should be reported on the
FFIEC 009. However, only non-tranche index and
single name CDS contracts may be used to risk transfer an immediate claim on Schedule C, Parts I and II.
Contracts purchased and sold which cannot be used
for risk transfer purposes as noted above are to be
reported in Columns 3 and 4 of Schedule O, according
to the country of residence of the underlying reference
entities. Do not report on Schedule O according to the
counterparty to the contract or the location of the
company that establishes the index.

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General Instructions

Regardless of whether reported on Schedule C or
Schedule O, if the underlying basket is composed of
reference entities located in one country, report the full
notional amount of the contract opposite the country
of the reference entity. If the underlying basket is composed of several securities from several countries, the
underlying reference entities should be reported on a
pro-rata basis.
CDS tranches, and bespoke CDS such as Nth-todefault contracts, and similar credit derivative contracts, should be reported on Schedule O. For these
types of contracts, if the underlying reference entities
are domiciled in multiple countries and payments to
the protection buyer are not triggered by a credit event
in a particular reference entity, but are triggered by a
default past a predetermined threshold, the notional
value of the contract should be reported in the “Unallocated” row.

3. Gross-Gross and Gross-Net Reporting
Purchases and sales of credit derivatives are reported
on a “gross-gross” and “gross-net” basis on Schedule O (excluding the portion included as a hedge on
Schedule C, Parts I and II) by country of the reference
entity. The residual notional amount of credit derivatives purchased to hedge a claim reported in Schedule C, Part I that is in excess of the underlying hedged
claim should be reported on Schedule O.
The gross notional value of credit derivatives purchased and sold should be reported on Schedule O,
Columns 3 and 4, as appropriate.
Report in Columns 5 and 6, as appropriate, the net
position of credit derivative contracts included in Column 3 and 4 where netting may be done only when all
the following apply:
(1) There are offsetting purchased and sold positions on the same reference entity (on a legal
entity basis),
(2) The contracts are with the same counterparty,
(3) The contracts are subject to a legally enforceable
master netting agreement.
Contracts that do not qualify to be netted should be
reported gross.

III. Specific Instructions for Allocating
Claims to the Rows
This report form contains rows for: (a) the United
States; (b) individual foreign countries; and (c) international or regional organizations. Subtotals for each
region (e.g., Total Europe, Total Asia) are to be
reported, in addition to the Total Foreign Countries
row which captures the sum of all data reported,
excluding the United States. Data should be allocated
to the rows as described below.

A. The United States
The “United States” is defined as the 50 states of the
United States, the District of Columbia, the Commonwealth of Puerto Rico, as well as U.S. territories and
possessions.3

B. Foreign Countries
A foreign country is any country other than the United
States as defined above. For claims reported on an
immediate-counterparty basis, report claims for the
corresponding country of legal residence (i.e., the
country of incorporation or charter, or, for a bank
branch, the country where the branch is licensed) of
the immediate counterparty. For claims reported on an
ultimate-risk basis, report claims in the row corresponding to the country of legal residence (i.e., the
country of incorporation or, for a bank branch, the
country where the parent bank is chartered) of the ultimate obligor. (See Section II.C for definitions of
immediate counterparty and ultimate obligor.)
The “Unallocated” row of Schedule L should only be
used for negotiable securities issued by the reporter,
where the country of the holder is unknown on the
report as-of date. The “Unallocated” row of Schedule O should only be used for credit default contracts
such as guarantees provided by selling protection on
“tranched” credit default swaps in which the ultimate
obligors of the referenced credits do not all reside in
the same country and the complexity of the product
makes allocating the countries of the reference credits
on a pro-rata basis, as could be done with index prod3. For purposes of the FFIEC 009 report, IBFs are considered a
U.S. entity.

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General Instructions

ucts, an inaccurate measure of the likely geographic
distribution of the guarantee.
Exposures on NBFIs should be reported for the country where the institution is incorporated, or otherwise
chartered. Institutions such as hedge funds and Special
Purpose Vehicles (SPV) should be reported according
to the country of legal residence (country of incorporation) of the fund/vehicle, not according to the location of the fund managers or beneficial owners of the
fund/vehicle.

C. International and Regional
Organizations

opposite the appropriate region: (a) International;
(b) European; (c) Latin American; (d) Caribbean
(e) Asian; (f) African; or (g) Middle Eastern. The
“International” entry covers most organizations of a
global character, such as the International Monetary
Fund and the World Bank. The regional entries cover
organizations that are regional in scope such as the
European Coal and Steel Community (European), the
Inter-American Development Bank (Latin American)
or the Asian Development Bank (Asian).
All international and regional institutions are considered to be “public” sector organizations.

Claims on international and regional organizations,
even if located in the United States, should be reported

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FFIEC 009

SPECIFIC INSTRUCTIONS FOR PREPARATION OF

Claims
Schedule C

IV. Specific Instructions for Schedule C,
Part I—Claims on an Immediate Risk
Basis
A. Immediate-Counterparty Claims
(Columns 1 through 12)
All data in Columns 1 through 12 should be based only
upon the immediate obligor; do not consider any guarantees or other risk transfers.

Claims by Sector
In Columns 1 through 5 report all cross-border claims,
as defined in Section II.E.1, denominated in any
currency.
In Columns 6 through 10 report all claims on local residents in currencies other than the official currency of
the country in which the local office exists, as defined
in Sections II.E.2 and II.E.3.

Debt securities held for trading should be reported as
maturing in less than one year. All other debt securities
should be reported according to the remaining
maturity.

Claims on Local Residents in the Local
Currency
In Column 12, report all claims on local residents in the
official currency of the country in which the local office
exists (see Sections II.E.2 and II.E.3).
All claims on residents of another country and claims
in a non-local currency on residents of the same country as the office holding the claim should be reported in
Columns 1 through 10 and excluded from this column.
Examples for Columns 1 through 12 only:
(1) The London branch of the respondent has a claim
of $10 million, denominated in Brazilian reais,
and another claim of $20 million, denominated in
U.S. dollars, on a bank located in Brazil. The
claims mature in 8 months. Entries would be:

For Columns 1 through 12, allocate the claims to each
sector (see Section II.D) and each country row (see
Section III) based upon the country of residence and
sector of the direct obligor.

Part I

Brazil

Remaining Maturity of One Year or Less
In Column 11, show all claims reported in Columns 1
through 10 that have a remaining contractual maturity
of one year or less except as described below. The definition of “one year” should be consistent with the definition used in the FFIEC 031 and the FR Y-9C.
Marketable equity investments, both trading and
available-for-sale, should be reported as maturing in
less than one year.

Column 1 Banks

Column 11 Rem Maturity

30

30

(2) The Brazilian branch of the respondent has a
claim worth $10 million, denominated in a currency other than reais, on a bank located in Brazil.
Entries would be:
Part I
Col. 6 - Banks
Brazil

10

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FFIEC 009

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Schedule C

(3) The Brazilian branch of the respondent issued a
loan worth $10 million, denominated in Brazilian
reais, to a bank located in Brazil. Entries would be:

2. Inward Risk Transfers

Part I

Brazil

in Columns 5, 10 and 12 from households located in
that country.

Column 6 Banks

Column 12 Cl Lcl Cur

---

10

B. Redistribution of Claims for Required
Risk Transfers (Columns 13 through 22)
Redistribute all claims subject to a required risk transfer (see Sections II.F and II.H) from the sector and
country of the immediate counterparty and to the sector and country of the ultimate obligor. Show the
required risk transfers between different countries or
between different sectors in the same country. Exclude
risk transfers within the same country and sector.
The sum of the outward required risk transfers (in Columns 13 through 17) on a grand-total basis should
equal the sum of the inward required risk transfers (in
Columns 18 through 22), because all transfers from a
sector or country must also be transfers to another sector or country.

Report in Columns 18 through 22 required risk transfers as defined in Section II.F by country and sector of
the ultimate obligor—i.e., of the guarantor or issuer/
holder of collateral.
In Column 18, show, for each country row, all required
risk transfers of claims reported in Columns 13
through 17 to banks located in that country.
In Column 19, show, for each country row, all required
transfers of claimsreported in Columns 13 through
17 to the public sector located in that country.
In Column 20, show, for each country row, all required
transfers of claims reported in Columns 13 through
17 to NBFIs located in that country.
In Column 21, show, for each country, all required
transfers of claims reported in Columns 13 through
17 to non-financial corporations located in that
country.
In Column 22, show, for each country, all required
transfers of claims reported in Columns 13 through
17 to individuals located in that country.

1. Outward Risk Transfers
In Column 13, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 1, 6, and 12 from banks located in that
country.

V. Specific Instructions for Schedule C,
Part II—Claims on an Ultimate Risk
Basis and Memorandum Items

In Column 14, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 2, 7, and 12 from the public sector located
in that country.

A. Ultimate-Risk Claims (Columns 1
through 11)

In Column 15, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 3, 8, and 12 from NBFIs located in that
country.
In Column 16, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 4, 9 and 12 from non-financial corporations located in that country.
In Column 17, show (as a positive number), for each
country, all required risk transfers of claims reported

1. Cross-border Claims
In Columns 1 through 5, report all claims that, on an
ultimate-risk basis, are cross-border claims, i.e., claims
for which the ultimate obligor, after required risk transfers, is a resident of a country other than the country of
the office that holds the claim.
The claims should be allocated to each column based
upon the sector of the ultimate obligor (see Section II.C)
and to each row based upon the country in which the
ultimate obligor is located (see Section III).

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FFIEC 009

Schedule C

2. Claims on Local Residents
In Columns 6 through 10, report all claims that, on an
ultimate-risk basis, are claims on local residents, i.e.,
claims for which the ultimate obligor, after required
risk transfers, is a resident of the country in which the
reporter’s office is located.
The claims should be allocated to each column based
upon the sector of the ultimate obligor and to each row
based upon the country in which the ultimate obligor is
located.

3. Claims on Local Residents in Non-Local
Currencies
In Column 11, show all claims reported in Columns 6
through 10 that are claims in currencies other than the
official currency (see Section II.E.3) of the country in
which the office is located.

B. Memorandum Items for Schedule C,
Part II
1. Securities (HTM and AFS) (Column 12)
Report in Column 12, by country of issuer, securities
the reporter owns and reports in Columns 1 through 10
of Schedule C, Part II, that are classified as held-tomaturity or available-for-sale. Held-to-maturity securities should be reported at amortized cost and availablefor-sale securities should be reported at fair value.

2. Collateral Held Against Claims with No Risk
Transfers (Columns 13 through 16)
In Column 13 through 16 of Schedule C, Part II,
report claims included in Columns 1 through 10 of
Schedule C, Part II, for which the obligor provided
collateral that did not meet the definition of collateral
for the risk-transfers of claims (See Section II.F). See
Section V.C “Examples for Schedule C, Parts I and II.”
In Column 13, report total claims, by country of the
counterparty, included in Columns 1 through 10 of
Schedule C, Part II, for which the obligor provided
collateral that did not meet the definition of collateral
for the risk-transfers of claims, namely through resale
agreements, securities lending arrangements and other
similar financing agreements. Reverse repurchase
agreements and securities borrowed may be reported

net, consistent with ASC Topic 210-20. Also include
any other collateralized claims that do not result in a
risk transfer of claims. Collateral in the form of real
estate should be excluded from this report.
In Column 14, report, by country of the counterparty,
claims (regardless of whether cross-border or on local
residents, or currency denomination) where cash collateral was provided and held as part of a securities
lending arrangement or other similar financing
agreement.
In Column 15, report claims held where the country of
the ultimate obligor (i.e., the issuer of the collateral or,
for cash collateral, the legal entity where the cash is
held, which is the legal entity with the liability for the
cash collateral) is the same as the country of the immediate counterparty. Also include in this column claims
where collateral was provided as part of a resale or
securities lending agreement where the country of
issuer of the collateral is the same as the country of the
counterparty to the agreement. If multiple securities
are provided as collateral, only include in Column 15
the amount attributable to the same country.
In Column 16, report by country of the counterparty,
claims reported in Columns 1 through 10 of Schedule C, Part II, that arise from resale agreements, securities lending transaction, or similar financing agreements. These claims should be reported both on an
immediate and ultimate risk basis, based on the counterparty, not the underlying collateral (see Section II.F.5).
Columns 14 through 16 are not mutually exclusive (i.e.,
the same claim may be reported in more than one of
these columns). If the value of the collateral exceeds
that of the underlying claim, report the amount of the
claim in Columns 13 through 16. If the claim is partially collateralized, only report the amount of the
claim that is collateralized.

3. Trading Assets (Columns 17 and 18)
In Column 17, report the fair value of the reporter’s
trading account assets that are included in Columns 1
through 10 of Schedule C, Part II. Exclude from this
column derivative claims, as these should be reported
on Schedule D. “CUSIP netting” is permissible if the
position was reported net on Schedule C, Part II, Columns 1 through 10.
C-3

FFIEC 009

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Schedule C

In addition, for each instrument type for each issuer, if
the short position in Column 18 exceeds the long positions in Column 17, report only up to the amount of
the long position reported in Column 17.

In Column 18, report short positions in securities that
have the same issuer (on a legal entity basis) and broad
instrument type (i.e., debt versus debt and equity versus equity), as the long positions reported in Column 17.

C. Examples for Schedule C, Part II
(1) The respondent’s offices located outside of Hong Kong and Japan have $50 million in claims, denominated in
U.S. dollars, on a private manufacturer in Hong Kong that are guaranteed by a bank located in Japan. Entries
would be:
Part I

Part II

Col. 4 - Corp

Col. 16 - Outw
Corp

Col. 18 - Inw
Banks

Col. 1 - Banks

Col. 4 - Corp

50
---

50
---

--50

--50

-----

Hong Kong
Japan

(2) The respondent’s offices in Japan have $50 million in claims, denominated in Hong Kong dollars, on a securities company in Hong Kong that are guaranteed by a bank located in Japan. Entries would be:
Part I

Hong Kong
Japan

Part II

Col. 3 - NBFIs

Col. 15 - Cl on
NBFIs

Col. 18 - Cl on
Banks

Col. 1 - Banks

Col. 6 - Banks

Col. 11 - Cl NonLcl Curr

50
---

50
---

--50

-----

--50

--50

(3) The reporter’s U.S. branch parent bank issues a $75 million loan (held for investment) to a construction company incorporated in Japan. The loan is denominated in Japanese yen. As collateral, the Japanese company
posts $50 million in Japanese government debt. Entries would be:
Part I

Part II

Col. 4 - Corp

Col. 16 - Outw
Corp

Col. 19 - Inw Public

Col. 2 - Public

Col. 4 - Corp

75

50

50

50

25

Japan

(4) The respondent’s offices located outside of Denmark and Greece have a total of $100 million in claims, all
denominated in U.S. dollars, on residents of Denmark, $70 million on banks, $20 million on public sector entities and $10 million on households. Of the claims on banks, $20 million is guaranteed (legally binding) by the
counterparties’ parent bank located in Greece. Entries would be:
Part I

Denmark
Greece

Part II

Col. 1 Banks

Col. 2 Public

Col. 5 Households

Col. 13 Outw
Banks

Col. 18 Inw Banks

Col. 1 Banks

Col. 2 Public

Col. 5 Households

70
--

20
--

10
--

20
--

-20

50
20

20
--

10
--

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Schedule C

(5) The respondent’s offices located outside of the Bahamas and the United States have $10 million in claims, not
denominated in Bahamian dollars, on the Nassau, Bahamas branch of a U.S. bank. Entries would be:
Part I

Bahamas
United States

Part II

Col. 1 - Banks

Col. 13 - Outw Banks

Col. 18 - Inw Banks

Col. 1 - Banks

10
---

10
---

--10

--10

(6) The respondent’s office in Spain has $10 million in claims, not denominated in euros, on a manufacturing company in Spain, guaranteed by a bank located in Denmark. Entries would be:
Part I

Spain
Denmark

Part II

Col. 9 - Corp

Col. 16 - Outw
Corp

Col. 18 - Inw
Banks

Col. 1 - Banks

Col. 9 - Corp

10
---

10
---

--10

--10

-----

(7) The respondent’s U.S. office has a $10 million claim, denominated in U.S. dollars, on a U.S. bank that has a
parent in the United Kingdom. The parent provides a legally binding guarantee of payment. Entries would be:
Part I

United Kingdom
United States

Part II

Col. 12 - Cl Lcl Cur

Col. 13 - Outw Banks

Col. 18 - Inw Banks

Col. 1 - Banks

--10

--10

10
---

10
---

(8) The respondent’s Italian office has a $10 million claim, not denominated in euros, on a U.S. branch of an Italian bank. Entries would be:
Part I

Italy
United States

Part II

Col. 1 - Banks

Col. 13 - Outw
Banks

Col. 18 - Inw
Banks

Col. 6 - Banks

Col. 11 - Cl Non-Lcl
Curr

--10

--10

10
---

10
---

10
---

(9) The respondent’s U.S. office has a $10 million claim, denominated in euros, on a household in France that is
fully guaranteed by collateral in the form of securities issued by a French bank. Entries would be:
Part I

France

Part II

Col. 5 - Households

Col. 17 - Outw Households

Col. 18 - Inw Banks

Col. 1 - Banks

10

10

10

10

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Schedule C

(10) The respondent’s Hong Kong office has a $10 million claim, denominated in Hong Kong dollars, on a bank in
Hong Kong that is a wholly-owned subsidiary of a Japanese bank. There is no legally-binding guarantee.
Entries would be:
Part I

Part II

Col. 12 - Cl Lcl Cur

Col. 13 - Outw Banks

Col. 18 - Inw Banks

Col. 6 - Banks

10
---

-----

-----

10
---

Hong Kong
Japan

(11) The respondent’s U.S. office has a $10 million claim, denominated in U.S. dollars, on a U.S. manufacturing
company that is guaranteed by a U.K. bank. Entries would be:
Part I

Part II

Col. 12 - Cl Lcl Cur

Col. 16 - Outw Corp

Col. 18 - Inw Banks

Col. 1 - Banks

--10

--10

10
---

10
---

United Kingdom
United States

(12) The Brazilian branch of the respondent has a $10 million claim, not denominated in reais, on a Brazilian manufacturer guaranteed by the United States Export-Import Bank. Entries would be:
Part I

Part II

Col. 9 - Corp

Col. 16 - Outw Corp

Col. 19 - Inw Public

Col. 2 - Public

10
---

10
---

--10

--10

Brazil
United States

(13) The Brazilian branch of the respondent has issued loans for $50 million, denominated in Brazilian reais, to a
Brazilian non-banking subsidiary of a Belgian financial services company. The counterparty’s parent provides
a legally binding guarantee for only $20 million of the claims. Entries would be:
Part I

Brazil
Belgium

Part II

Col. 12 - Cl Lcl
Cur

Col. 15 - Outw
NBFIs

Col. 20 - Inw
NBFIs

Col. 3 - NBFIs

Col. 8 - NBFIs

Col. 11 - Cl NonLcl Cur

50
---

20
---

--20

--20

30
---

-----

(14) The reporter’s Cayman Islands branch enters into an overnight reverse repurchase agreement (for $50 million,
denominated in U.S. dollars) with an NBFI domiciled in the U.K. The underlying collateral is U.K. corporate
debt securities. Entries would be:
Part I

United Kingdom

Part II

Col. 3 - NBFIs

Col. 11 - Rem
Maturity

Col. 3 - NBFIs

Col. 13 - Total
Coll

Col. 15 - Same
Country

Col. 16 - Resale
& Sec Lend

50

50

50

50

50

50

C-6
March 2019

FFIEC 009

Schedule C

(15) The respondent’s U.S. office has a $20 million claim, denominated in U.S. dollars, on a Malaysian financial
services company. The respondent purchased credit protection from a German bank against the risk of default
by the Malaysian obligor through a credit derivative. The credit derivative has a notional value of $20 million.
The arrangement is considered an effective risk transfer based on the respondent’s internal criteria. Entries
would be:
Part I

Part II

Col. 3 - NBFIs

Col. 15 - Outw NBFIs

Col. 18 - Inw Banks

Col. 1 - Banks

20
---

20
---

--20

--20

Malaysia
Germany

(16) The respondent’s U.S. office has a $20 million claim, denominated in Brazilian reais, on a Brazilian financial
company. The respondent purchased credit protection from a German bank against the risk of default by the
Brazilian financial company through a credit derivative. The credit derivative has a notional value of $30 million, exceeding the value of a guaranteed claim. The arrangement is considered an effective risk transfer based
on the respondent’s internal criteria. Entries would be:
Part I

Part II

Col. 3 - NBFIs

Col. 15 - Outw NBFIs

Col. 18 - Inw Banks

Col. 1 - Banks

20
---

20
---

--20

--20

Brazil
Germany

In addition, the excess $10 million (the difference between the $30 million notional amount and the $20 million
underlying claim) should be reported on Schedule O, Column 3, and, if appropriate after netting, in Column 5
against Germany.
Note regarding Schedule D (applies to examples 15 and 16):
If the credit derivative has a positive fair value of $2 million, the positive fair value would be reported in Schedule D in the country row of the country of residence of the counterparty to the credit derivative contract.
Entries would be:
Schedule D

Germany

Col. 1 - Banks

Col. 5 - Total

2

2

(17) The respondent’s Japanese office has a $100 million claim, denominated in Korean Won, on a Korean branch
of a Hong Kong bank. The Korean obligor provides $60 million in Japanese government bonds as collateral.
Entries would be:
Part I

Hong Kong
Korea
Japan

Part II

Col. 1 - Banks

Col. 13 - Outw
Banks

Col. 18 - Inw
Banks

Col. 19 - Inw
Public

Col. 1 - Banks

Col. 7 - Public

--100
---

--100
---

40
-----

----60

40
-----

----60

C-7
FFIEC 009

March 2019

Schedule C

(18) The respondent’s German office engages in an overnight resale agreement with a hedge fund located in the Cayman Islands for $50 million, denominated in U.S. dollars. $50 million in cash is exchanged for $52 million in
U.K. government securities. Entries would be:
Part I

Part II

Col. 3 - NBFIs

Col. 11 - Rem
Maturity

Col. 3 - NBFIs

Col. 13 - Total Coll

Col. 16 - Resale &
Sec Lend

50

50

50

50

50

Cayman Islands

(19) The reporter’s branch in Brazil issues a mortgage for a private residence to an individual, also in Brazil. The
mortgage is for $2 million (denominated in Brazilian reais) and is secured by the residence. Entries would be:
Part I

Part II

Col. 12 - Cl Lcl Cur

Col. 10 - Households

2

2

Brazil

Collateral in the form of real-estate is not considered eligible collateral (see Section II.F.5) for the purposes of
the FFIEC 009 and would not result in a risk transfer or be included as “Collateral Held Against Claims with
No Risk Transfer.”
(20) The reporter’s Cayman Islands branch issues a (short-term) margin loan to an insurance company domiciled in
Switzerland. The loan is for $50 million (denominated in euros). For collateral, the insurance company posts
$10 million in cash (denominated in euros) that is held at a bank domiciled in Switzerland and $25 million in
German government debt (denominated in euros). Entries would be:
Part I

Switzerland
Germany

Part II

Col. 3 NBFIs

Col. 11 Rem
Maturity

Col. 15 Outw
NBFIs

Col. 18 Inw Banks

Col. 19 Inw Public

Col. 1 Banks

Col. 2 Public

Col. 3 NBFIs

50
--

50
--

35
--

10
--

-25

10
--

-25

15
--

(21) The reporter’s Cayman Islands branch issues a (short-term) margin loan to a bank domiciled in the Bahamas.
The loan is for $50 million (denominated in euros). For collateral, $20 million in cash (denominated in euros) is
posted to a third-party bank domiciled in the Bahamas. Entries would be:
Part I

Bahamas

Part II

Col. 1 - Banks

Col. 11 - Rem Maturity

Col. 1 - Banks

50

50

50

C-8
March 2019

FFIEC 009

Schedule C

(22) The reporter’s U.K. office makes a short-term margin loan to a non-bank financial services client domiciled in
Germany for $50 million (denominated in euros). The client posts $55 million in U.K. government debt as collateral. Entries would be:
Part I

Germany
United Kingdom

Part II

Col. 3 - NBFIs

Col. 11 - Rem
Maturity

Col. 15 - Outw
NBFIs

Col. 19 - Inw Public

Col. 7 - Public

50
---

50
---

50
---

--50

--50

C-9
FFIEC 009

March 2019

SPECIFIC INSTRUCTIONS FOR PREPARATION OF

Foreign-Office Liabilities
Schedule L

A. Foreign-Office Liabilities by Country
of Foreign Office (Columns 1 and 2)
Report in Columns 1 and 2, the liabilities of the reporter’s foreign offices by country of each foreign office that
represent liabilities of the foreign offices to all creditors, regardless of location, for which no payment is
guaranteed at locations outside the country of the
office. Deposits of a foreign branch are assumed to be
the liabilities of the foreign branch, unless they are
explicitly redeemable outside the country in which the
branch is located. Exclude the negative fair value of
derivative contracts.
In Column 1, report foreign-office liabilities that are in
a currency other than one which the country’s government has authority to issue. (See Section II.E.)
In Column 2, report foreign-office liabilities that are in
a currency which the country’s government has
authority to issue. (See Section II.E.)

B. Foreign-Office Liabilities by Country
of Creditor (Column 3)
Column 3—total liabilities booked at foreign
offices—is required to be reported only by those
reporters meeting certain conditions described in Section I.D of these instructions.
In Column 3, report by country of the creditor, all
liabilities that are booked at any of the reporter’s foreign offices, regardless of the currency and regardless
of whether payment is guaranteed at locations outside
the country of the office. Liabilities in Column 3
should be reported against the country where the counterparty is located (i.e., on an immediate-counterparty
basis) and not the location of the parent of the creditor. Liabilities to creditors located in the United States

should be reported. Exclude the negative fair value of
derivative contracts.
Short sales by a foreign office should be reported in
Column 3 opposite the country of the party to which
the foreign office owes delivery until the settlement
date.
If the country of the creditor cannot be determined—
because the customer was not known to the bank (as
would be the case with negotiable certificates of
deposit)—then these liabilities should be reported in
the “Unallocated” row.
In any row and on a grand-total basis, the amount in
Column 3 (which is by country of creditor) may not
equal the sum of amounts in Column 1 and 2 (which
are by country of foreign office).

C. Net Due To (or Due From) Own
Related Offices in Other Countries
(Column 4)
Report for each country in which the reporter has an
office or offices, that office’s (or those offices’) net
liabilities to (or claims on) all other offices of the
respondent that are located in other countries, including offices in the United States (e.g., the net amount a
German branch has “due to” or “due from” the head
office and all other consolidated non-German offices
of the parent). Only a single net figure should be
reported for all the offices of the reporter in a given
country. If the offices in a given country taken together
have a net “due to” position with all related offices in
all other countries combined, a positive figure should
be reported; a net “due from” position should be indicated by a negative sign.
For the purposes of this report, the computation of net
due to or due from should include unremitted profits
L-1

FFIEC 009

March 2019

Schedule L

and capital contribution accounts of branch offices
and the equity investment in consolidated subsidiaries.
Include all claims and liabilities that are reflected as
balance sheet items (e.g., loans, borrowings, derivative
contracts).

The amounts reported in Column 4 represent the internal position of offices within the consolidated bank or
the consolidated holding company. They are, therefore,
not reflected in any other columns of the report.

D. Examples for Schedule L
(1) The reporter’s branch located in the U.K. holds $10 million in interest-bearing deposits placed by a non-bank
financial company located in the U.K. (denominated in GBP). The funds are not payable outside the U.K.
Entries would be:
Schedule L

United Kingdom

Col. 2 FO Liab Non-Lcl Cur

Col. 3 Total Liab at FO

10

10

(2) The reporter’s parent bank takes out a loan directly from a third-party bank domiciled in Japan. The amount
of the loan is $5 million and is denominated in U.S. dollars. Entries would be:
None. Only liabilities incurred by the reporter’s offices located outside the U.S. should be reported in Columns
1 through 3 of Schedule L.
(3) The reporter’s branch located in the U.K. holds $100 million in deposits (denominated in euros) placed by a
U.K. branch of a German bank. The funds are payable anywhere the reporter has an office. Entries would be:
Schedule L
Col. 3 Total Liab at FO
United Kingdom

100

Since the deposits are payable outside the country of the office, there are no foreign-office liabilities to report in
Columns 1 and 2 of Schedule L. However, the deposit should be reported in Column 3 against the country
where the (immediate) counterparty is located, regardless of whether payment can be made at locations outside
the country of the office (see Section VI.B).
(4) The reporter’s German securities broker subsidiary has a trade date payable for the purchase of $25 million of
U.K. sovereign debt, denominated in GBP, with an insurance company counterparty located in Switzerland.
Entries would be:
Schedule L

Germany
Switzerland

Col. 1 FO Liab Lcl Cur

Col. 3 Total Liab at FO

25
---

--25

L-2
March 2019

FFIEC 009

Schedule L

(5) The reporter’s Cayman Islands branch enters into a repurchase agreement for $2 million (denominated in U.S.
dollars) with a hedge fund counterparty located in the Bahamas. Entries would be:
Schedule L

Cayman Islands
Bahamas

Col. 1 FO Liab Lcl Cur

Col. 3 Total Liab at FO

2
---

--2

(6) The reporter’s U.K. branch enters into a securities lending arrangement (U.K. government securities were lent)
for $5 million (denominated in GBP) with a pension fund domiciled in the Netherlands. Entries would be:
Schedule L

United Kingdom
Netherlands

Col. 2 Liab Non-Lcl Cur

Col. 3 Total Liab at FO

5
---

--5

(7) The reporter’s U.K. branch sold a put option on a German manufacturer’s equity securities. The counterparty
is a non-bank financial institution domiciled in Luxembourg. The notional value of the derivative is $100 million and has a negative fair value of $2 million, denominated in U.S. dollars. Entries would be:
No entries. Liabilities from derivative contracts are not reported on Schedule L of the FFIEC009 report.
(8) The reporter’s U.K. broker/dealer subsidiary receives an intracompany loan from the Cayman branch of the
reporter (for $10 million, denominated in euros). In addition, the U.K. branch of the reporter placed deposits
of $4 million (denominated in U.S. dollars) with the reporter. Entries would be:
Schedule L
Col. 4 Net Due to Own Rel Off
United Kingdom
Cayman Islands
United States
Grand Total

6
(10)
4
0

The U.K. offices have a combined net due to position of $6 million ($10 million due to the Cayman Islands and
a $4 million due from the U.S.). See Section VI.C.
(9) The reporter’s security subsidiary located in Germany sells short $20 million in U.K. government debt it does
not own to a fund manager
domiciled in Luxembourg. Assume the settlement date is the day after the FFIEC 009 report as-of date. Entries
would be:
Schedule L

Germany
Luxembourg

Col. 1 FO Liab Lcl Cur

Col. 3 Total Liab at FO

20
---

--20

L-3
FFIEC 009

March 2019

Schedule L

“Short sales” are to be reported opposite the country of the office entering into the short sale in Columns 1 and
2 (in this example, Germany), and in Column 3 opposite the country of the counterparty to the short sale, to
whom delivery is owed (in this example, Luxembourg). Do not report according to the country of the issuer of
the security.

L-4
September 2016

FFIEC 009

SPECIFIC INSTRUCTIONS FOR PREPARATION OF

Off-Balance-Sheet Items
Schedule O

A. Unused Commitments (Column 1)
In Column 1, report, on an “ultimate-risk” basis (i.e.,
after risk transfers due to head offices of bank
branches or credit protection provided by third parties), the unused portions of all outstanding crossborder and local office commitments to provide credit,
by country of residence of the ultimate obligor if the
commitment were to be drawn. Include the unused
portion of all outstanding letters of credit and
amounts outstanding of purchases of risk
participations.
The definition of commitments is identical to that used
for Schedule HC-L of the FR Y-9C.
Exclude “best efforts” letters and letters in which the
pricing is indicative and not determined until launch
date, or for which the banking institution has no commitment to buy the assets for its own account. Exclude
cross- border commitments (such as those under commercial letters of credit) that can be cancelled, at the
option of the reporter, upon the occurrence of a sovereign event. Also exclude financial and performance
standby letters of credit. (Outstanding and unused
financial and performance standby letters of credit
should be reported as guarantees in Column 2.)
In cases of commitments for syndicated loans, the lead
underwriter should report only the underwriter’s proportional share of the unused commitment. Similarly,
contractual underwriting commitments (e.g., revolving
underwriting facilities) and other underwriting agreements may be shown net of firm commitments from
other parties to purchase the assets without recourse
within a short and specific period of time. Accordingly,
the reporter should also include its unused obligations
to participate in syndicated loans and underwritings
managed by other institutions.

Commitments of U.S. and foreign offices to local residents should be included.

B. Guarantees (Excluding Credit
Derivatives Sold) (Column 2)
In Column 2, report, on an ultimate-risk basis, all
legally binding guarantees and insurance contracts (see
Sections II.F.1 and II.F.2) issued by the reporter’s U.S.
or foreign offices, excluding credit derivatives sold. Do
not include guarantees which provide protection only
between consolidated units of the reporter. Include the
full amount of outstanding and unused financial and
performance standby letters of credit in Column 2.
Guarantees and insurance contracts of foreign offices
to local residents should also be included.

C. Credit Derivatives Purchased and Sold
(Columns 3 through 6)
Report in Columns 3 through 6, by country of the
underlying reference entity, the notional value of all
outstanding credit derivatives sold and of those credit
derivatives purchased that are not reported as a risk
transfer in Schedule C, Parts 1 and II (see Section II.H.1).
Credit protection purchased to hedge/offset credit protection sold, or for speculative purposes, should be
excluded as a risk transfer from Schedule C, Parts I and
II, and reported in Columns 3 and 5 of Schedule O, as
appropriate.

1. Gross-Gross (Columns 3 and 4)
Report in Columns 3 and 4 the gross notional value of
credit derivatives purchased and sold opposite the
country of the underlying reference entity.
O-1

FFIEC 009

September 2016

Schedule O

Report in Column 3, by country of the ultimate obligor of the reference credit, credit derivatives where the
reporter (or its consolidated offices) is a protection
purchaser (see Section II.H) and that were not used as
part of a risk transfer on Schedule C, Parts I and II.
Include in Column 3 any residual notional value of
credit derivatives purchased, in excess of the amount of
the underlying claim where the credit derivative was
used as part of a risk transfer on Schedule C, Parts I
and II.

(1) there are offsetting purchased and sold positions
on the same reference entity (on a legal entity
basis),
(2) the contracts are with the same counterparty,
(3) the contracts are subject to a legally enforceable
master netting agreement.
Contracts that do not meet all three conditions above
should be reported on a gross basis in Columns 5
and 6.

Report in Column 4, by country of the ultimate obligor of the reference credit, all credit derivatives where
the respondent is a protection seller (see Section II.H).
For example, if a reporter is a guarantor providing
credit risk protection to a U.K. bank for a claim on an
Argentine bank, by means of a credit derivative, the
reporter would report the notional amount in Column 4 in the row for Argentina.

D. Trade Finance (Column 7)

2. Gross-Net (Columns 5 and 6)
Report in Columns 5 and 6, as appropriate, the consolidated net position of credit derivative contracts
included in Column 3 and 4. Netting may be done only
when all the following apply:

In Column 7, report total extensions of credit with
maturities one year and under that are included in Columns 1 through 10 of Schedule C, Part II, or Columns
1 or 2 of Schedule O and that: (1) are directly related to
imports or exports and (2) will be liquidated through
the proceeds of international trade. Provided these two
conditions are met, such credit extensions may include
customers’ liability on acceptances outstanding, own
acceptances discounted, acceptances of other banks
purchased, pre-export financing where there is a firm
export sales order, commercial letters of credit, as well
as other loans and advances whenever such extensions
directly relate to international trade. Include credit
extensions for pre-export financing when there is a
firm export sales order and the proceeds of the order
will pay off indebtedness.

E. Examples for Schedule O
(1) The respondent (through any office) issued a $10 million loan commitment, denominated in U.S. dollars, to a
manufacturing company located in Ireland. Entry would be:
Schedule O
Col. 1 - Unused Commitments
Ireland

10

(2) The respondent (through any office) has provided credit protection to a German bank, against the risk of
default by a French non-financial company through a credit derivative. The credit derivative has a notional
value of $10 million, denominated in euros. Entry would be:
Schedule O

France

Col. 4 - Gr - Gr Cred
Deriv Sold

Col. 6 - Gr - Net Cred
Deriv Sold

10

10

O-2
March 2019

FFIEC 009

Schedule O

Note regarding Schedule D:
If the credit derivative has a positive fair value of $1 million, the positive fair value would be reported in Schedule D in the country row of the country of residence of the counterparty to the credit derivative contract.
Entries would be:
Schedule D

Germany

Col. 1 - Banks

Col. 5 - Total

1

1

(3) The respondent’s U.S. office has provided a company in Brazil with a $20 million line of credit, denominated in
Brazilian reais, and has provided a bank in the United Kingdom with a $30 million (notional value) credit
derivative, denominated in GBP, based upon the credit of a German industrial company. Entries would be:
Schedule O

Brazil
United Kingdom
Germany

Col. 1 - Unused
Comm

Col. 4 - Gr- Gr Cred
Deriv Sold

Col. 6 - Gr - Net Cred
Deriv Sold

20
-----

----30

----30

Note regarding Schedule D:
If the credit derivative has a negative fair value of $2 million, the fair value would not be reported on Schedule D.
(4) The Brazilian branch of the respondent has a loan commitment of $10 million, denominated in Brazilian reais,
to a Brazilian manufacturer. The United States Export-Import Bank has written a guarantee that would guarantee $7 million of the loan, should it be extended. Entries would be:
Schedule O
Col. 1 - Unused Comm
Brazil
United States

3
---

(5) The reporter purchases a CDS index (notional value of $150 million, denominated in U.S. dollars) with 15
equally-weighted reference entities, 5 in Germany, 5 in the U.K. and 5 in Japan. Assuming the reporter has no
other CDS contracts, entries would be:
Schedule O

Germany
United Kingdom
Japan

Col. 3 - Gr-Gr Cred
Deriv Purch

Col. 5 - Gr-Net Cred Deriv
Purch

50
50
50

50
50
50

O-3
FFIEC 009

March 2019

Schedule O

(6) The reporter enters into the following transactions with bank B (located in Germany) and bank C (located in
Spain). The reporter has legally enforceable master netting agreements with banks B and C and all contracts are
executed under the agreements as follows (all contracts denominated in U.S. dollars).
a. The reporter buys from bank B $100 million notional of CDS protection referencing sovereign debt issued
by Germany.
b. The reporter sells to bank B $90 million notional of CDS protection referencing sovereign debt issued by
Germany (different CUSIP from transaction 1).
c. The reporter buys from bank C $50 million of CDS protection referencing the debt of Company XYZ in
the U.K.
d. The reporter sells to bank C $70 million of CDS protection referencing the debt of Company XYZ in
the U.K.
e. The reporter buys from bank C $30 million of CDS protection referencing sovereign debt issued by the
U.K. government.
These transactions would be reported as follows:
Schedule O
Col. 3 - Gr-Gr
Cred Deriv
Purch

Col. 4 - Gr- Gr
Cred Deriv Sold

Col. 5 - Gr-Net
Cred Deriv
Purch

Col. 6 - Gr - Net
Cred Deriv Sold

100
80

90
70

10
30

--20

Germany
United Kingdom

(7) The reporter enters into the following transactions with bank E (located in France), bank F (located in Germany) and a central counterparty located in the U.K. (Company G) as follows (all contracts denominated in
euros).
a. The reporter sells to bank E $50 million notional of CDS protection referencing the sovereign debt of
France and $100 million notional of CDS protection referencing corporate debt issued by Company ABC
domiciled in Ireland. The contracts are cleared through Company G.
b. The reporter purchases from bank F $30 million notional of CDS protection referencing the sovereign
debt of France. The contract is cleared through Company G.
These transactions would be reported as follows:
Schedule O

France
Ireland

Col. 3 - Gr-Gr
Cred Deriv
Purch

Col. 4 - Gr- Gr
Cred Deriv Sold

Col. 5 - Gr-Net
Cred Deriv
Purch

Col. 6 - Gr - Net
Cred Deriv Sold

30
---

50
100

-----

20
100

O-4
March 2019

FFIEC 009

SPECIFIC INSTRUCTIONS FOR PREPARATION OF

Claims from Positions in Derivative
Contracts
Schedule D

Report by country of the counterparty, the positive
fair value of all derivative contracts. Positive fair values
can be offset against negative fair values if, and only if,
the transactions were executed with the same counterparty under a legally enforceable master netting agreement under ASC Subtopic 210-20, Balance Sheet—
Offsetting (formerly FASB Interpretation No. 39,
“Offsetting of Amounts Related to Certain Contracts”). When contracts are covered by master netting
agreements, the net residual amount, if positive, is
reported in the country of residence of the ultimate
counterparty.
All claims reported on Schedule D are to be reported
on an ultimate-risk basis (see Section II.C). Therefore,
amounts that are guaranteed are reported in the sector
and country of the guarantor. Similarly, if cash collateral is held, amounts that are collateralized are
reported in the sector and country of the legal entity
where the cash collateral is held; when securities are
held as collateral, the exposure is reported in the sector
and country of the issuer of the securities (see Section II.F).

A. Positive Fair Value of Derivative
Contracts (Columns 1 through 5)
Report the positive fair value of derivative contracts by
sector (see Section II.D) in Columns 1 through 4, and
the total in Column 5. For Schedule D, sectors consist
of Banks, Public, NBFIs, and “Other.” “Other” consists of the residual claims which cannot be classified in
the other three categories.
Contracts not covered by a master netting agreement
must be reported gross.
The positive fair value of derivative contracts can be
offset against the negative fair value of derivative contracts and cash collateral held by the reporter if the

transactions are executed under a legally enforceable
master netting agreement and the offsetting is in accordance with ASC Subtopics 815-10 and 210-20. For
derivative contracts executed under such a master netting agreement, only the net residual fair value, if positive, is reported in Schedule D according to the sector
and country of residence of the ultimate counterparty.
For contracts covered by a multi-branch or multijurisdiction master netting agreement, the net positive
residual amount (i.e., the larger of zero or the gross
positive fair value less the gross negative fair value of
those contracts covered by the same master netting
agreement) must be reported in Columns 1 through 4,
as appropriate, as well as in Column 5. (The term
multi-jurisdiction or multi-branch agreement refers to
a master netting agreement that covers the head office
and other offices of the reporter.)
For contracts covered by a single netting agreement (a
master netting agreement entered into by a single office
of the reporter with another party), the net positive
residual amount qualifies to be reported in Columns 1
through 5.
When a contract is entered into with a branch of a
commercial bank, a claim (i.e., positive fair value) is
reported in the country of the head office because
claims on a bank’s branches are assumed to have an
implicit credit guarantee of the head office. Claims on
(i.e., contracts having a positive fair value) U.S.
branches of foreign banks are reported in the country
of the head office. (Refer also to instructions for Column 6, which treats claims on bank branches
differently.)

B. Claims on Branches with No
Guarantee from Parent (Column 6)
In memorandum Column 6, reporters are asked to
identify claims on bank branches according to the
D-1

FFIEC 009

March 2019

Schedule D

country of residence of the branch in those instances in
which the claim is not formally and legally guaranteed
by the head office of the branch (and in which the
country of residence of the branch is different than the
country of residence of the head office). Amounts
reported in Column 6 are also reported in Columns 1
and 5 (although in Columns 1 and 5 they are reported
in the country row of the head office). If the claims on
a bank branch are formally and legally guaranteed by
the head office of the branch (or if the branch is
located in the same country as the head office) then the
claims are not reported in Column 6. Contracts covered by master netting agreements are deemed to carry
the legal guarantee of the head office and are therefore
not reported in Column 6.
For example, an unguaranteed claim on a branch of a
foreign bank would be reported in Columns 1 and 5 in
the country of the head office and in Column 6 in the
country of the branch.

For example, the German office of the respondent has
a contract with a positive fair value of $100 million
with the German branch of a U.S. bank.
Schedule D

Germany
United States

Col. 1 - Banks

Col. 5 - Total

Col. 6 - Cl With
No Guar

--100

--100

100
---

If parties to a multi-branch netting agreement specify
that transactions with branches in certain jurisdictions
are subject to transfer risk, any exposure in that jurisdiction is reported in memorandum Column 6 in order
to reflect the transfer risk in that location.

C. Examples for Schedule D
(1) The reporter’s U.K. securities broker subsidiary has a portfolio of OTC derivative trades with a notional value
of $1 billion and a positive fair value of $150 million with the U.K. securities broker subsidiary of a bank
domiciled in Germany. The German bank posts $120 million in cash as collateral which is held by a third-party
bank domiciled in the U.K. Assuming there is no master netting agreement in place, the entries would be:
Schedule D

Germany
United Kingdom

Col. 1 - Banks

Col. 5 - Total

30
120

30
120

(2) The same fact pattern as Example 1, except the reporter and the German bank have a multi-jurisdiction master
netting agreement encompassing all the subsidiaries and branches of the two counterparties.
Schedule D

Germany

Col. 1 - Banks

Col. 5 - NBFIs

Col. 4 - Total

30

---

30

The amount in Column 1 against Germany represents the uncollateralized portion of the positive fair value
position against the parent bank under the master netting agreement. Because a master netting agreement is in
place, the positive fair value can be netted with the cash collateral.
(3) The reporter’s U.K. securities broker subsidiary has a foreign exchange swap contract with a notional value of
$500 billion and a positive fair value of $100 million with the Cayman Islands nonbank subsidiary of a bank
domiciled in the U.K. The reporter and the U.K. bank have a multi-jurisdiction master netting agreement

D-2
March 2019

FFIEC 009

Schedule D

encompassing all the subsidiaries and branches of the two counterparties. For collateral, the Cayman Islands
subsidiary posts $50 million in U.K. sovereign debt and $20 million in cash as collateral which is held directly
by the reporter’s U.K. subsidiary. Entries would be:
Schedule D

United Kingdom

Col. 1 - Banks

Col. 2 - Public

Col. 3 - NBFIs

Col. 5 - Total

30

50

---

80

The amount in Column 2 represents the sovereign debt posted as collateral (collateral in the form of securities
are reported opposite the country and sector of the issuer). The amount in Column 1 represents the uncollateralized portion of the positive fair value position against the parent bank of the counterparty under the master
netting agreement. The cash collateral held by the reporter’s U.K. subsidiary is not reportable since a multijurisdiction master agreement is in place and the cash is held directly by the reporter.
Assume the following fact pattern for Examples 4 through 6:
The respondent (U.S. Bank), and its consolidated U.S. and foreign offices, enters into various derivative contracts with a counterparty (Japan Bank and its various branches). The balances with the various branches of
Japan Bank on the books of U.S. Bank’s various locations as of the reporting date are shown below, in millions
of dollars:

U.S. Bank - Hong Kong branch with:
Japan Bank - Hong Kong branch
Japan Bank - London branch
Japan Bank - Tokyo branch
Total
U.S. Bank - London branch with:
Japan Bank - Hong Kong branch
Japan Bank - London branch
Japan Bank - Tokyo branch
Total
U.S. Bank - New York branch with:
Japan Bank - London branch
Japan Bank - New York branch
Japan Bank - Tokyo branch
Total
U.S. Bank - Tokyo branch with:
Japan Bank - Hong Kong branch
Japan Bank - London branch
Japan Bank - New York branch
Japan Bank - Tokyo branch
Total
Grand Total
Total Net Aggregate Residual

Gross Positive
Fair Value

Gross Negative
Fair Value

Net by Location

Net Aggregate
Residual Amount

15
45
60
120

11
75
40
126

4
-30
20
-6

-6

190
79
67
336

70
41
34
145

120
38
33
191

191

57
10
41
108

75
85
40
200

-18
-75
1
-92

-92

115
75
15
144
349
913

225
25
100
64
414
885

-110
50
-85
80
-65

-65
28

D-3
FFIEC 009

March 2019

Schedule D

(4) Assuming the respondent has no master netting agreement and that claims on bank branches are not formally
and legally guaranteed by the head office. Entries would be:
Schedule D
Col. 1 - Banks

Col. 5 - Total

Col. 6 - Cl With No
Guar

913
-------

913
-------

--320
256
25

Japan
Hong Kong
United Kingdom
United States

(5) Assuming the respondent has a master netting agreement and with Japan Bank. Entries would be:
Schedule D
Col. 1 - Banks

Col. 5 - Total

Col. 6 - Cl With No
Guar

28
-------

28
-------

---------

Japan
Hong Kong
United Kingdom
United States

(6) Assuming the same fact pattern as Example 5, but that the parties have also agreed to a bilateral collateralization agreement under which exposures greater than $10 million are collateralized with cash or liquid U.K. government securities. Assume that collateral is pledged in minimum incremental amounts of $5 million and that
U.K. government securities were pledged. Entries would be:
Schedule D

Japan
Hong Kong
United Kingdom
United States

Col. 1 - Banks

Col. 2 - Public

Col. 5 - Total

Col. 6 - Cl With
No Guar

8
-------

----20
---

8
--20
---

---------

Assume the following fact pattern for Examples 7 and 8 for Schedule D:
The respondent, and its consolidated U.S. and foreign offices, enters into various derivative contracts with foreign corporate customers and banks. Assume the corporate customers are non-financial companies. The balances with these parties on the books of the respondent’s various locations as of the reporting date are shown
below, in millions of dollars:

D-4
March 2019

FFIEC 009

Schedule D

U.S. Bank - Hong Kong branch with:
Hong Kong Corporate
Singapore Corporate
U.K. Bank - Hong Kong branch
Total
U.S. Bank - London branch with:
U.K. Corporate
Hong Kong Bank - London branch
Total
U.S. Bank - New York branch with:
Argentine Corporate
Venezuela Bank
Total
Grand Total
Total Net Aggregate Residual

Gross Positive
Fair Value

Gross Negative
Fair Value

Net by Location

Net Aggregate
Residual Amount

15
45
60
120

11
75
40
126

4
-30
20
-6

-6

190
79
269

70
41
111

120
38
158

158

57
10
67
456

75
85
160
397

-18
-75
-93

-93
59

(7) Assuming the respondent has no master netting agreement and claims on bank branches are not formally and
legally guaranteed by the head office.
Schedule D

United Kingdom
Argentina
Venezuela
Hong Kong
Singapore

Col. 1 - Banks

Col. 4 - Other

Col. 5 - Total

Col. 6 - Cl With
No Guar

60
--10
79
---

190
57
--15
45

250
57
10
94
45

79
----60
---

(8) Assuming the respondent has no master netting agreement but that claims on bank branches are formally and
legally guaranteed by the head office. Also assume that the liabilities of the Argentine corporate customer are
legally guaranteed by its U.S. parent. Entries would be:
Schedule D

United Kingdom
Argentina
Venezuela
Hong Kong
Singapore

Col. 1 - Banks

Col. 4 - Other

Col. 5 - Total

60
--10
79
---

190
----15
57

250
--10
94
57

D-5
FFIEC 009

March 2019

Summary of Reporting Bases by
Schedule and Column
Appendix A

Schedule

Column/s

Schedule C, Part I
Schedule C, Part I
Schedule C, Part I
Schedule C, Part II
Schedule C, Part II
Schedule C, Part II
Schedule C, Part II
Schedule C, Part II
Schedule L
Schedule L
Schedule L
Schedule O
Schedule O
Schedule O

1 through 12
13 through 17
18 through 22
1 through 11
12
13 through 16
17
18
1, 2
3
4
1
2
3, 4

Schedule O

5, 6

Schedule O
Schedule D
Schedule D

7
1 through 5
6

Reporting Criteria
Country/sector of obligor
Country/Sector of outward risk transfer
Country/Sector of inward risk transfer
Country/sector of ultimate obligor/issuer of guarantee
Country of issuer of HTM and AFS securities
Location of counterparty
Location of issuer of trading assets
Issuer of offsetting position for trading book
Location of foreign-office obligor
Location of creditor
Location of affiliated counterparty
Location of party (after risk transfers) receiving commitment
Country of issuer of obligor for guarantees/insurance contracts
Gross position of credit derivatives purchased and sold (by country of reference
entity)
Net position of offsetting credit derivatives purchased and sold (by country of reference entity)
Location of recipient of trade financing
Location of counterparty or issuer of collateral
Location of branch if not guaranteed by parent

Reporting Basis
Immediate
Immediate
Ultimate
Ultimate
Ultimate
Ultimate
Ultimate
Ultimate
Ultimate
Immediate
Immediate
Ultimate
Ultimate
Ultimate
Ultimate
Ultimate
Ultimate
Immediate

APP A-1
FFIEC 009

September 2016