Country Exposure Information Report

Instructions for Preparation of

FFIEC 009a
Country Exposure Information Report

September 30, 2016

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INSTRUCTIONS FOR THE PREPARATION OF THE

Country Exposure Information Report
FFIEC 009a

(Effective September 2016)

GENERAL INSTRUCTIONS
This report is a supplement to the Country Exposure Report (Form FFIEC 009) filed with the banking
regulatory agencies for bank examination purposes. The purpose of the Country Exposure Information
Report is to provide public disclosure of significant country exposures of U.S. banking institutions.
Copies of the report are available to the public by accessing the following website
http:/www.ffiec.gov/E16.htm.

Who Must Report
This report must be filed by every institution that submits Form FFIEC 009 and that has exposure meeting
the reporting requirements for Form FFIEC 009a as defined in these instructions.
This supplemental disclosure report (Form FFIEC 009a) has two parts: Part A and Part B. Part A will be
completed when exposure, as defined for Column 4, Part A, to a single country, excluding the United
States, exceeds one percent of the banking institution’s total assets or exceeds 20 percent of the banking
institution’s total capital, whichever is less. All columns included in Part A should only be completed for
the countries that exceed these thresholds. Part B will be used to report the names of the countries where
the amount of exposure exceeds 0.75 percent but does not exceed 1 percent of the banking institution’s
total assets or is between 15 percent and 20 percent of the banking institution’s total capital, whichever is
less. The banking institution must only list the names of the countries and the aggregate amount of
exposure for all countries listed under Part B. For the purposes of meeting these criteria, exposure is
defined as the amount of total claims computed in accordance with the instructions to Column 4, Part A.
Total assets of reporting banks are those submitted on the Report of Condition to the federal bank
supervisors as of the same date. For bank holding companies total assets are those submitted on the most
recent Form FR Y-9C.
Total capital is as defined in the agencies’ guidelines on capital adequacy and consists of Tier 1 plus
Tier 2 capital.

Public Release of Country Exposure Information Reports
The individual FFIEC 009a reports are made publicly available.
A reporting institution may request confidential treatment for some or all of the portions of the FFIEC
009a if the institution is of the opinion that disclosure of specific commercial or financial information in
the report would likely cause substantial harm to its competitive position. In certain limited
circumstances, the reporting institution’s primary federal supervisor may approve confidential treatment
of some or all of the items for which such treatment has been requested if the institution has clearly
provided a compelling justification for the request. A request for confidential treatment must be submitted
in writing prior to the electronic submission of the report. The written request must identify the specific
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items for which confidential treatment is requested, provide justification for the confidential treatment
requested for the identified items, and demonstrate the specific nature of the harm that would result from
public release of the information. Merely stating that competitive harm would result is not sufficient.
Information for which confidential treatment is requested may subsequently be released by the reporting
institution’s primary federal supervisor in accordance with the terms of 12 CFR 4.16 (OCC), 12 CFR
261.16 (Board), 12 CFR 309.6 (FDIC), or as otherwise provided by law.

Filing of Reports
The report is to be prepared quarterly, as of the last calendar day of March, June, September, and
December. All respondents should submit their completed report, each quarter they meet the reporting
requirements, to the Federal Reserve Bank of New York (FRBNY), via the Federal Reserve System’s
Reporting Central system, within 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.
Any FFIEC 009a respondent who needs filing guidance is encouraged to visit the Federal Reserve System
Website http://www.frbservices.org/centralbank/index.html for additional information on Reporting
Central. The Website also includes a link that respondents may use to contact the Federal Reserve Bank
of New York.

Rounding
Round all amounts reported on this form to the nearest million dollars.

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.

PART A
Country
The countries listed in Part A should be those where exposure, as defined for Column 4, Part A, exceeds 1
percent of total assets or 20 percent of total capital, whichever is less. The names of the countries reported
should be as they appear on Form FFIEC 009. The United States should be excluded from this report.

Column 1: Amount of Cross-border Claims Outstanding After Mandated Adjustments
for Transfer of Exposure (excluding derivative products)
For each country line reportable on the FFIEC 009a report, report in Column 1 the sum of Columns 1
through 5 from Schedule C, Part II, of the FFIEC 009 report.

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Column 2:
products)

Amount of Foreign–Office Claims on Local Residents (excluding derivative

For each country line reportable on the FFIEC 009a report, report in Column 2 the sum of Columns 6
through 10 from Schedule C, Part II, of the FFIEC 009 report.

Column 3: Amount of Gross Claims Outstanding from Derivative Products after
Mandated Adjustments for Transfer of Exposure
List the total amount of claims from derivative products: From the FFIEC 009 report, Column 5 of
Schedule D.

Column 4:
Residents

Total Amount of Cross-Border Claims and Foreign–Office Claims on Local

Total of Columns 1 through 3.

Column 5:

Gross Foreign-Office Liabilities

List the total amount of gross foreign-office liabilities as reported on the FFIEC 009 report, Columns 1
and 2 of Schedule L. Note that Columns 1 and 2 of Schedule L include foreign-office liabilities to both
local and non-local residents.

Columns 6 to 14:
Column 13)

Distribution of Amounts Outstanding in Columns 1 and 2 (except

Column 6 - Banks
Report the amounts included in Columns 1 and 2 of this report where the counterparties are banks, as
defined in Section II.D.1 of the FFIEC 009 instructions. These amounts are included on FFIEC 009 report
on Schedule C, Part II, Columns 1 and 6, and Schedule D, Column 1.
Column 7 - Public
Report the amounts included in Columns 1 and 2 of this report where the counterparties are public
organizations, as defined in Section II.D.2 of the FFIEC 009 instructions. These amounts are included on
FFIEC 009 report on Schedule C, Part II, Columns 2 and 7, and Schedule D, Column 2.
Column 8 - Non-Bank Financial Institutions (NBFIs)
Report the amounts included in Columns 1 and 2 of this report where the counterparties are NBFIs, as
defined in Section II.D.3 of the FFIEC 009 instructions. These amounts are included on FFIEC 009 report
on Schedule C, Part II, Columns 3 and 8, and Schedule D, Column 3.
Column 9 - Other
Report the amounts included in Columns 1 and 2 of this report where the counterparties cannot be
classified as Banks, Public or NBFIs (see Section II.D.6 of the FFIEC 009 instructions). These amounts
are included on the FFIEC 009 report on Schedule C, Part II, Columns 4, 5, 9 and 10, and Schedule D,
Column 4.
Columns 10 and 11 - By Maturity
For each country, distribute the amounts reported in Columns 1 and 2 according to time remaining to
maturity as defined in Section IV.A of the FFIEC 009 instructions: One Year and Under (Column 10) and
Over One Year (Column 11).
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In completing Columns 10 and 11, estimates may be used.
Columns 12 and 13 - Trading Assets
For each country, distribute the amounts reported in Columns 1 and 2 that are claims classified as held for
trading. The amounts are included on the FFIEC 009 report on Schedule C, Part II, Column 17.
In Column 13, report amounts included on the FFIEC 009 report on Schedule C, Part II, Column 18 that
represent short positions in the same securities, at the issuer (on a legal entity basis) and instrument level
(i.e., debt versus debt and equity versus equity) as the long positions reported in Column 12 of this report.
Column 14 - Securities (HTM and AFS)
For each country, distribute the amounts reported in Columns 1 and 2 that represent securities that the
reporter owns and that are classified as held-to-maturity or available-for-sale. These amounts are included
on the FFIEC 009 report on Schedule C, Part II, Column 12.

Columns 15 to 18:

Collateral Held Against Claims with No Risk Transfers

Columns 15 through 18 below are to be reported based on the location of the counterparty and are not
mutually-exclusive.
In Column 15, report for each country claims included in Columns 1 and 2 that represent claims for which
the obligor provided collateral that did not meet the definition of collateral for risk-transfers of claims,
namely through resale agreements, securities lending arrangements and other similar financing
agreements. This amount is included on the FFIEC 009 report on Schedule C, Part II, Column 13.
In Column 16, report for each country the amounts included in Column 15 of this report where the
collateral provided was cash. This amount is included on the FFIEC 009 report on Schedule C, Part II,
Column 14.
In Column 17, report for each country the amounts included in Column 15 where the holder of the cash
collateral or the issuer of the securities provided for collateral are in the same country as the counterparty
to the transaction. This amount is included on the FFIEC 009 report on Schedule C, Part II, Column 15.
In Column 18, report for each country the amounts included in Column 15 that represent claims resulting
from resale agreements, securities lending transaction, or similar financing agreements. This amount is
included on the FFIEC 009 report on Schedule C, Part II, Column 16.

Columns 19 and 20:

Cross-Border and Foreign-Office Commitments and Guarantees

Column 19 - Unused Commitments
Report for each country the amounts included on the FFIEC 009 report on Schedule O, Column 1, that
represent unused commitments. See Section VII.A of the FFIEC 009 instructions for additional details.
Column 20 - Guarantees (Excluding Credit Derivatives Sold)
Report for each country the amounts included on the FFIEC 009 report on Schedule O, Column 2, that
represent legally binding guarantees and insurance contracts issued by the reporter’s U.S. or foreign
offices for which the ultimate obligor is not a U.S. resident, excluding credit derivatives sold. Reporting
should be done based on the location of the ultimate obligor.

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Columns 21 through 24:

Credit Derivatives (By Reference Entity)

Columns 21 and 22 - Gross-Gross
Report in Column 21, by country of the underlying reference asset, the notional value of total credit
derivatives purchased. The amounts are included on the FFIEC 009 report on Schedule O, Column 3.
Report in Column 22, by country of the underlying reference asset, the notional value of total credit
derivatives sold. The amounts are included on the FFIEC 009 report on Schedule O, Column 4.
Columns 23 and 24 - Gross-Net
Report in Columns 23 and 24, as appropriate, the consolidated net position of credit derivative contracts
included in Columns 21 and 22. Netting should be done as specified in Section VII.C.2 of the FFIEC 009
instructions. The amounts are included on the FFIEC 009 report on Schedule O, Columns 5 and 6.

PART B
Provide the name of each country not listed in Part A where the institution has exposure, as defined for
Column 4 of Part A, which exceeds 0.75 percent but does not exceed 1 percent of the reporting
institution’s assets or is between 15 percent and 20 percent of its total capital, whichever is less. In the
box provided, give the total amount of exposure to all of the countries listed in Part B.

Optional Management Statement Concerning the Country Risk Information Reported On
the FFIEC 009a
The management of the reporting institution may, if it wishes, submit a brief statement concerning the
data submitted on this report. This statement may be used by management to explain any differences
between the information contained in this report and information filed with the Securities and Exchange
Commission pursuant to U.S. securities laws, or to provide any other information concerning the data that
management believes would further public understanding of the reporting institution’s country exposure.
All information in the narrative statement must be accurate and not misleading. Appropriate efforts shall
be taken by the filing institution to ensure the statement’s accuracy.
As this optional statement will be made available to the public as submitted, institutions choosing to
submit it should ensure that the statement does not contain information that they are not willing to have
made public or that would compromise the privacy of their customers.
The optional statement should be entered in the remarks section of the Reporting Central application.

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