FFIEC009_FFIEC009a_20190909_omb

Supporting Statement for the
Country Exposure Report (FFIEC 009; OMB No. 7100-0035) and the
Country Exposure Information Report (FFIEC 009a; OMB No. 7100-0035)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Country Exposure Report
(FFIEC 009; OMB No. 7100-0035) and the Country Exposure Information Report (FFIEC 009a;
OMB No. 7100-0035). U.S. commercial banks, savings associations, Edge or agreement
corporations, bank holding companies (BHCs), savings and loan holding companies (SLHCs),
and intermediate holding companies (IHCs) (collectively, U.S. financial institutions) that meet
certain criteria set forth in the FFIEC 009 instructions must file the quarterly FFIEC 009 with the
Board, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller of the
Currency (OCC) (collectively, the agencies) to report information on international claims. The
agencies use this information to monitor the degree of country risk and transfer risk in U.S.
financial institutions’ portfolios and the potential impact of adverse international developments
on the financial institutions. The FFIEC 009a is a supplement to the FFIEC 009 that must be
filed by FFIEC 009 filers that have exposure exceeding certain thresholds set forth in the
FFIEC 009a instructions. The FFIEC 009a collects quarterly information on material foreign
country exposures of U.S. financial institutions.
The agencies collect the FFIEC 009 and FFIEC 009a under the auspices of the FFIEC.
The Board is responsible for collecting and compiling the data reported on the FFIEC 009 and
FFIEC 009a on behalf of all three agencies. Each of the agencies submits a separate supporting
statement to OMB for this collection of information for relevant financial institutions under their
supervision. For the Board, these institutions are state member banks, Edge or agreement
corporations, BHCs, SLHCs, and IHCs.
The agencies propose to revise the FFIEC 009 and FFIEC 009a by reporting short sales
based on the immediate counterparty and sector of the issuer rather than that of the counterparty
to the short-sale transaction; and excluding certain items from the instructions that were
previously considered financial claims. The current estimated total annual burden for the
FFIEC 009 and FFIEC 009a with respect to financial institutions supervised by the Board is
26,516 hours and will remain unchanged as a result of the revision. The form and instructions for
the FFIEC 009 and FFIEC 009a are available on the FFIEC’s website at
https://www.ffiec.gov/ffiec_report_forms.htm.
Background and Justification
In 1977, the agencies, under the auspices of the FFIEC, implemented the mandatory
FFIEC 009 in response to substantial growth in U.S. banks’ international lending and a lack of
information on banks’ country risk exposures. In 1984, the FFIEC increased the frequency of
FFIEC 009 reporting from semiannual to quarterly to implement provisions of the International
Lending Supervision Act of 1983 (the Act) for the purpose of obtaining more timely data on

changes in the composition and maturity of banks’ loan portfolios subject to transfer risk, which
is the possibility that an asset cannot be serviced in the currency of the payment because the
obligor’s country lacks the necessary foreign exchange or has put restraints on its availability.
The agencies use the information collected by the FFIEC 009 to supervise the overseas
lending activities of U.S. financial institutions. The information is used to monitor the degree of
country risk and transfer risk in U.S. financial institutions’ portfolios and the potential impact of
adverse international developments on these financial institutions. The FFIEC 009 is the source
of information about the geographic distribution of bank claims that the Board provides to other
U.S. government agencies and, in aggregate form, to the Bank for International Settlements
(BIS). The information collected in the FFIEC 009 is not available from any other source.
In 1984, the agencies, under the auspices of the FFIEC, implemented the mandatory
FFIEC 009a as a supplement to the FFIEC 009 in accordance with provisions of the Act. The
FFIEC 009a provides public disclosures of information regarding material country risk exposure.
Description of Information Collection
The FFIEC 009 report collects information, by country,1 on four schedules (one of these
schedules, Schedule C, contains 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 for claims resulting from the fair value of derivative contracts. Part I also
collects the redistribution of immediate-counterparty claims to adjust for required risk transfers.
Schedule C, Part II, collects information on the reporter’s claims on an ultimate-risk basis (i.e.,
on the basis of the country of residence of the guarantor or collateral provided) and includes
memorandum items providing additional details related to those claims. Schedule L collects
information on foreign-office liabilities. Schedule O collects information on off-balance-sheet
exposures from commitments, guarantees, and credit. Schedule D collects information on the fair
value of derivative contracts of the reporter by country, including the United States, of
counterparty.
The FFIEC 009a requests detailed information on all exposures to a country in excess of
1 percent of total assets or 20 percent of capital, whichever is less, of the reporting institution.
The FFIEC 009a also requires that respondents provide a list of the countries in which exposures
are between 0.75 percent and 1 percent of total assets or between 15 and 20 percent of capital,
whichever is less. Data are reported net of adjustments for transfers of exposure (through
guarantees, for example).
Respondent Panel
The FFIEC 009 and FFIEC 009a are filed by any U.S. commercial banks, savings
associations, BHCs, SLHCs, Edge or agreement corporations, and IHCs that meet certain criteria
1

The country names and country codes used for reporting FFIEC 009 data are based on the geographical
classification published by the Department of the Treasury. The reporting form may be modified, from time to time,
to reflect country consolidations or countries that have recently gained independence.

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set forth in detail in the FFIEC 009 and FFIEC 009a instructions. Generally, these criteria
include having total outstanding claims of at least $30 million on residents of foreign countries
and, for U.S. commercial banks and savings associations, having one of the following: (1) a
branch in a foreign country, (2) a subsidiary in a foreign country, (3) an Edge or Agreement
subsidiary, (4) an International Banking Facility subsidiary, or (5) a branch in Puerto Rico or any
U.S. territory or possession. The respondents differ by reporting schedule for the FFIEC 009, as
described in the instructions.
If the Board, the FDIC, or the OCC determines that the country exposure of a U.S.
financial institution that is not required by the FFIEC 009 or FFIEC 009a instructions to submit a
report (or a given schedule therein) is material in relation to the institution’s capital and assets,
the agencies may order the financial institution to file the FFIEC 009 and FFIEC 009a or any
schedule therein.
Proposed Revisions to the FFIEC 009 and FFIEC 009a
During the initial public comment period, the agencies received a comment from a
banking trade association. The commenter noted that Schedule L of the FFIEC 009 requires
reporting of short sales by country of the counterparty to which the foreign office owes delivery
until the settlement date. The commenter believed this treatment to be inconsistent with the
corresponding treatment in the Board’s FR 2510, which provides that the immediate
counterparty country and sector for short sale contracts are those of the issuer of the financial
instrument that has been sold short. The commenter recommended that the reporting of short
sales in Schedule L of the FFIEC 009 should be revised to conform with the treatment provided
in the Board’s FR 2510. The agencies also note that the reporting of short sales in the Board’s
FR 2510 is consistent with the BIS guidelines for reporting CBS data (CBS Guidelines).
Therefore, the agencies agree with the commenter and propose to revise the instructions for
Schedule L so that reporting of short sales is based on the immediate counterparty and sector of
the issuer rather than that of the counterparty to the short-sale transaction.
The commenter also suggested that items to be excluded under Schedule C and
Schedule L of the FFIEC 009 should be more specifically identified and that the list of
exclusions should be expanded. The commenter recommended that certain cross-border claims
(i.e., bank-owned or company-owned life insurance, deferred tax assets, physical commodities
held in inventory, initial margin, pension assets, and cash in vault) should be excluded from
Schedule C of the FFIEC 009 and that deferred tax liabilities should be excluded from
Schedule L.
As a general matter, the agencies believe that the decision to include or exclude items as
in Schedule C of the FFIEC 009 should be based on whether the items represent financial claims
(or, for Schedule L, foreign office financial liabilities) in order to provide a proper and
meaningful basis for the agencies to analyze country exposure, and should be consistent with the
CBS Guidelines in order that data collected in the FFIEC 009 and FFIEC 009a would be
comparable with data being provided to CBS by other jurisdictions.
In this context, the agencies agree with the commenter that bank-owned and company-

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owned life insurance, physical commodities held in inventory, and pension assets should not be
considered financial claims for purposes of the FFIEC 009 and FFIEC 009a. Therefore, the
agencies propose to revise the instructions to exclude these items from reporting in the
FFIEC 009 and FFIEC 009a by adding them to the list of “Exclude” items in section II.A of the
instructions to the FFIEC 009.
To provide sufficient time for respondents to make any changes to their reporting systems
that may be needed to reflect the agencies’ proposed instructional revisions discussed above, the
agencies will permit respondents to file the FFIEC 009 and FFIEC 009a for the periods ending
September 30, 2019, and December 31, 2019, using either the existing definitions or the revised
definitions for the items discussed above.
Time Schedule for Information Collection and Publication
Respondents must file the FFIEC 009 and FFIEC 009a quarterly, as of the last calendar
day of March, June, September, and December. Each report must be submitted within 45 days of
the reporting date for the March, June, and September quarters and within 50 days of the
reporting date for the December quarter.
The FFIEC publishes aggregate data from the FFIEC 009 in the quarterly E.16 statistical
release, Country Exposure Lending Survey. Both FFIEC 009 aggregated data and applicable
individual FFIEC 009a data are included in this release. In addition, the Federal Reserve makes
aggregate data available to the BIS, which publishes statistical data on consolidated bank claims
on foreign borrowers as its “consolidated international banking statistics” on its website
(https://www.bis.org/statistics/consstats.htm) and in its Quarterly Review.
Legal Status
The FFIEC 009 and FFIEC 009a are authorized pursuant to sections 9(6), 11(a), 25, and
25A of the Federal Reserve Act for state member banks, agreement corporations, and Edge
corporations, respectively (12 U.S.C. §§ 324, 248(a), 602, and 625); section 5(c) of the Bank
Holding Company Act of 1956 (BHC Act) for BHCs (12 U.S.C. § 1844(c)); and section 10(b)(3)
of the Home Owners’ Loan Act for SLHCs (12 U.S.C. § 1467a(b)(3)). With respect to foreign
banking organizations (FBOs) and their subsidiary IHCs, section 5(c) of the BHC Act, in
conjunction with section 8 of the International Banking Act of 1978 (12 U.S.C. § 3106),
authorizes the Board to require FBOs and any subsidiary thereof to file the FFIEC 009 and
FFIEC 009a. The FFIEC 009 and FFIEC 009a are mandatory.
Individual respondents may request that information submitted to the Board through the
FFIEC 009 and FFIEC 009a be kept confidential. If a respondent requests confidential treatment,
the Board will determine whether the information is entitled to confidential treatment on a caseby-case basis. Information may be kept confidential under exemption 4 for the Freedom of
Information Act (FOIA), which protects privileged or confidential commercial or financial
information (5 U.S.C. § 552(b)(4)) or under FOIA exemption 6, which covers personal
information, the disclosure of which would constitute an unwarranted invasion of privacy
(5 U.S.C. § 552(b)(6).).

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Consultation Outside the Agency
The Board developed the FFIEC 009 and FFIEC 009a in consultation with the FDIC and
OCC. There has been no consultation outside the agency with respect to the proposed extension,
with revision, of this collection of information.
Public Comments
On April 29, 2019, the agencies published an initial notice in the Federal Register
(84 FR 18120) requesting public comment for 60 days on the extension, without revision, of the
FFIEC 009 and FFIEC 009a. The comment period for this notice expired on June 28, 2019. The
agencies received one comment covering several different subjects from a banking trade
association.
The commenter raised issues related to consistency in certain defined terms and reporting
treatments between the FFIEC 009 and FFIEC 009a, on the one hand, and other information
collections undertaken by the FFIEC, its member entities, and Treasury, on the other, and
recommended that the agencies provide additional detail regarding certain reporting items and
expand the list of exclusions from Schedule C and Schedule L.
First, the commenter stated that, while the FFIEC 009 and FFIEC 009a instructions
define domicile of counterparties on the basis of “country of incorporation or charter,” the
definition is not uniform across all FFIEC and Board reports. This definition, while consistent
with that used in some non-FFIEC reports (i.e., Treasury International Capital (TIC) reports and
the Board’s FR Y-15), is inconsistent with the terms “principal business address” and “country in
which the obligor is headquartered” used in the Call Report2 as well as the Board’s FR Y-9C and
FR Y-14Q. The agencies believe the definition of domicile using “country of incorporation or
charter” provides a clearer basis for determination of domicile and a more consistent basis over
time for the purposes of the FFIEC 009 and FFIEC 009a, which is designed to provide a more
detailed and accurate view of cross-border country exposures than the other reports.
Accordingly, the agencies propose to retain the “country of incorporation or charter” definition
for reporting the domicile of counterparties in the FFIEC 009 and FFIEC 009a instructions.
Second, the commenter stated the FFIEC 009 and FFIEC 009a instructions, in defining
financial institutions for sector reporting, include some different categories of institutions in the
non-bank financial institutions sector when compared to three Board reports (FR Y-15, FR 2510,
and FR Y-9C). The FFIEC 009 instructions specifically include private equity companies,
finance companies, and mortgage companies along with other types of institutions in the
definition of non-bank financial institutions, while the instructions for the Board’s FR Y-15
specifically exclude finance companies and do not mention private equity companies or
mortgage companies in the definition of “financial institutions” used in specifying
interconnectedness indicators (Schedule B). The agencies note that the definition of non-bank
financial institutions in the Board’s FR 2510 corresponds to the definition used in the
FFIEC 009, and the definition of “non-depository financial institutions” used in the Board’s
2

The Consolidated Reports of Condition and Income, also referred to as the FFIEC 031, FFIEC 041, and FFIEC 051
reports.

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FR Y-9C (Schedule HC-C) includes finance companies, mortgage companies, and mortgage
finance companies among other types of institutions. The agencies believe that private equity
companies, finance companies, and mortgage companies are meaningful components of the nonbank financial sector for purposes of the FFIEC 009 and that collected data on exposures to these
types of companies would be less useful if included together with the corporate sector. The
agencies also note that it is important for data collected in the FFIEC 009 to be comparable to
data gathered for the same purpose by other jurisdictions, so that these data can be combined by
the BIS into meaningful global aggregate statistical data that are issued as the BIS Consolidated
Banking Statistics (CBS); these aggregate data are relied upon by FFIEC member entities
(including the agencies) and many others to monitor and analyze global banking and financial
conditions. The definition in the FFIEC 009 instructions of these types of companies as non-bank
financial companies conforms with the definition under the CBS. Therefore, the agencies
propose to retain the definition of non-bank financial sector that includes these types of
companies.
Third, the commenter stated that, as a result of a recent change in U.S. generally accepted
accounting principles (GAAP), the FFIEC 009 and FFIEC 009a would collect operating lease
liabilities without capturing corresponding operating lease assets. The commenter considered this
treatment to be inappropriately asymmetric and recommended that operating lease liabilities be
excluded from reporting on Schedule L of the FFIEC 009. The agencies agree that operating
lease right-of-use assets should properly be excluded from reporting on the FFIEC 009, like
other fixed assets, but believes that operating lease liabilities are now reportable as liabilities
under GAAP, and thus should be included in foreign liabilities for purposes of the FFIEC 009.
Unlike financial-statement collections such as the Call Report or the Board’s FR Y-9C, the
FFIEC 009 is designed to collect additional detail for specific types of claims and liabilities and
not to reflect a comprehensive and symmetric balance sheet. Therefore, the agencies propose to
not exclude operating lease liabilities from Schedule L of the FFIEC 009.
Fourth, the commenter noted that Schedule L of the FFIEC 009 requires reporting of
short sales by country of the counterparty to which the foreign office owes delivery until the
settlement date. The commenter believed this treatment to be inconsistent with the corresponding
treatment in the Board’s FR 2510, which provides that the immediate counterparty country and
sector for short sale contracts are those of the issuer of the financial instrument that has been sold
short. The commenter recommended that the reporting of short sales in Schedule L of the
FFIEC 009 should be revised to conform with the treatment provided in the Board’s FR 2510.
The agencies also note that the reporting of short sales in the Board’s FR 2510 is consistent with
the BIS guidelines for reporting CBS data (CBS Guidelines).3 Therefore, the agencies agree with
the commenter and propose to revise the instructions for Schedule L so that reporting of short
sales is based on the immediate counterparty and sector of the issuer rather than that of the
counterparty to the short-sale transaction.
Fifth, the commenter noted a difference in treatment between the FFIEC 009 and U.S.
GAAP for netting trading assets against trading liabilities in the same security (i.e., Committee
on Uniform Security Identification Procedures (CUSIP) netting) and stated that changing the
3

BIS, Monetary and Economic Department, Reporting guidelines for the BIS international banking statistics
(July 2019) available at https://www.bis.org/statistics/bankstatsguide.pdf.

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FFIEC 009 instructions to align with netting under U.S. GAAP would reduce the burden on
banking organizations required to report the FFIEC 009. To address this concern, the commenter
recommended that CUSIP netting for purposes of the FFIEC 009 be aligned with netting
permitted under U.S. GAAP to simplify the currently required operational and reconciliation
processes. The agencies believe that aligning CUSIP netting with U.S. GAAP for country
exposure reporting would potentially distort such reporting in cases in which the office holding
the position, the issuer of the underlying security, and the counterparty to the short position are
not the same. The agencies also note that it is important for data collected in the FFIEC 009 to be
comparable to data gathered for the same purpose by other jurisdictions, so that these data can be
combined by the BIS into meaningful global aggregate statistical data as the CBS. Aligning
CUSIP netting with U.S. GAAP for country exposure reporting by U.S. banking organizations in
the FFIEC 009 would create a key inconsistency between U.S. data and data provided by other
jurisdictions which adhere to International Financial Reporting Standards (IFRS) because IFRS
does not allow for CUSIP netting. Therefore, the agencies propose to retain the current, more
limited use of CUSIP netting described in the FFIEC 009 instructions.
Finally, the commenter suggested that items to be excluded under Schedule C and
Schedule L of the FFIEC 009 should be more specifically identified and that the list of
exclusions should be expanded. The commenter recommended that certain cross-border claims
(i.e., bank-owned or company-owned life insurance, deferred tax assets, physical commodities
held in inventory, initial margin, pension assets, and cash in vault) should be excluded from
Schedule C of the FFIEC 009 and that deferred tax liabilities should be excluded from
Schedule L.
As a general matter, the agencies believe that the decision to include or exclude items as
in Schedule C of the FFIEC 009 should be based on whether the items represent financial claims
(or, for Schedule L, foreign office financial liabilities) in order to provide a proper and
meaningful basis for the agencies to analyze country exposure, and should be consistent with the
CBS Guidelines in order that data collected in the FFIEC 009 and FFIEC 009a would be
comparable with data being provided to CBS by other jurisdictions.
In this context, the agencies agree with the commenter that bank-owned and companyowned life insurance, physical commodities held in inventory, and pension assets should not be
considered financial claims for purposes of the FFIEC 009 and FFIEC 009a. Therefore, the
agencies propose to revise the instructions to exclude these items from reporting in the
FFIEC 009 and FFIEC 009a by adding them to the list of “Exclude” items in section II.A of the
instructions to the FFIEC 009.
The agencies do not agree with the commenter with regard to initial margin because the
agencies believe that initial margin represents a financial claim like others related to derivatives.
The agencies therefore propose that initial margin should continue to be reported as part of
derivative claims in Schedule D.
The agencies believe that cash in vault represents a financial claim and, moreover, that
this claim is subject to transfer risk, an important element of the risks that may be associated with

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cross-border financial claims. As a result, the agencies do not agree with the commenter and
propose that cash in vault should continue to be reported in the FFIEC 009 and FFIEC 009a.
Finally, the agencies do not agree with the commenter that deferred tax assets and
liabilities are not financial claims. In addition, the agencies note that deferred tax assets and
liabilities are specifically identified in the CBS Guidelines as reportable claims (liabilities).
Therefore, the agencies propose to retain the current inclusion of deferred tax assets and
liabilities among reportable items in the FFIEC 009 and FFIEC 009a.
To provide sufficient time for respondents to make any changes to their reporting systems
that may be needed to reflect the agencies’ proposed instructional revisions discussed above, the
agencies will permit respondents to file the FFIEC 009 and FFIEC 009a for the periods ending
September 30, 2019, and December 31, 2019, using either the existing definitions or the revised
definitions for the items discussed above. On September 9, 2019, the agencies published a final
notice in the Federal Register (84 FR 47340).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden of the FFIEC 009 and
FFIEC 009a is 26,516 hours for financial institutions supervised by the Board and would stay the
same with the proposed revisions. The estimated number of respondents is based on the reporting
panel as of December 31, 2018. These reporting requirements represent less than 1 percent of the
Board’s total paperwork burden.
Estimated
number of
respondents4
49
35

FFIEC 009
FFIEC 009a
Total

Annual
frequency
4
4

Estimated
average hours
per response
131
6

Estimated
annual burden
hours
25,676
840
26,516

The estimated total annual cost to the public for this information collection is
$1,527,322.5
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
4

Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets), https://www.sba.gov/document/support--table-size-standards.
5
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $19, 45% Financial Managers at
$71, 15% Lawyers at $69, and 10% Chief Executives at $96). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2018, published March 29, 2019, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Occupational Classification System, https://www.bls.gov/soc/.

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Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 009 and FFIEC 009a is $117,000.

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