FRY6_FRY7_FRY10_FRY10E_20191126_omb

Supporting Statement for the
Structure Reporting Requirements for Domestic and Foreign Banking Organizations
(FR Y-6, FR Y-7, FR Y-10, and FR Y-10E; OMB No. 7100-0297)
Prudential Standards for Large Bank Holding Companies,
Savings and Loan Holding Companies, and Foreign Banking Organizations
(Docket No. R-1658; RIN 7100-AF45)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Structure Reporting Requirements for Domestic and Foreign Banking Organizations
(OMB No. 7100-0297). This information collection comprises the following four reports:
 Annual Report of Holding Companies (FR Y-6), which collects financial and
organizational information from holding companies (HCs) and foreign banking
organizations (FBOs) that are non-qualifying,
 Annual Report of Foreign Banking Organizations (FR Y-7), which collects financial and
organizational information from qualifying FBOs,
 Report of Changes in Organizational Structure (FR Y-10), which is an event-generated
report that captures changes in organizational structure or the regulated investments and
activities of various entities, and
 Supplement to the Report of Changes in Organizational Structure (FR Y-10E)1, which is
a formless supplement to the FR Y-10 that the Board may use to collect additional
structural information on an emergency basis.
The Board adopted a final rule that establishes risk-based categories for determining
prudential standards for large U.S. banking organizations and foreign banking organizations,
consistent with section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank), as amended by the Economic Growth, Regulatory Relief, and Consumer
Protection Act (EGRRCPA), and with the Home Owners’ Loan Act (HOLA). The final rule
amends certain prudential standards, including standards relating to liquidity, risk management,
stress testing, and single-counterparty credit limits, to reflect the risk profile of banking
organizations under each category; applies prudential standards to certain large savings and loan
holding companies (SLHCs) using the same categories; makes corresponding changes to
reporting forms; and makes additional modifications to the Board’s companyrun stress test and
supervisory stress test rules, consistent with section 401 of EGRRCPA. The final rule is effective
Certain criteria apply to information collections conducted via the Board’s ad hoc clearance process. Such
information collections shall (1) be vetted by the Board’s clearance officer as well as the Division director
responsible for the information collection, (2) display the OMB control number and respondents shall be informed
that the information collection has been approved, (3) be used only in such cases where response is voluntary,
(4) not be used to substantially inform regulatory actions or policy decisions, (5) be conducted only and exactly as
described in the OMB submission, (6) involve only noncontroversial subject matter that will not raise concerns for
other Federal agencies, (7) include information collection instruments that are each conducted only one time, (8)
include a detailed justification of the effective and efficient statistical survey methodology (if applicable), and (9)
collect personally identifiable information (PII) only to the extent necessary (if collecting PII, the form must display
current privacy act notice).
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December 31, 2019. The Board revised item 5 on the FR Y-7, Regulation YY Compliance for
the FBO, to align the reporting form with the applicability thresholds set forth in the final rule
and other regulatory changes that are consistent with the Board’s July 2018 statement concerning
EGRRCPA. The first as-of date for the amended FR Y-7 is the next report after the effective date
of the final rule. There are no changes to the FR Y-6, FR Y-10, or FR Y-10E.
The current estimated total annual burden for the structure reports is 69,127 hours, and
would decrease to 68,743 hours. The proposed revisions would result in a decrease of 384 hours.
The forms and instructions for the FR Y-6, FR Y-7, and FR Y-10 are available on the Board’s
public website at https://www.federalreserve.gov/apps/reportforms/default.aspx. There is no
formal reporting form for the FR Y-10E (the FR designation is for internal purposes only).
Background and Justification
The Board has collected organizational structure reports in some form since the
implementation of the Bank Holding Company Act of 1956 (BHC Act). The information
collected through the FR Y-6, FR Y-7, FR Y-10, and FR Y-10E reports is not available from
other sources.
The Board uses the FR Y-6 to collect financial and structural information from top-tier
HCs to monitor that HC operations are conducted in a safe and sound manner and to assess
compliance with the BHC Act, Change in Bank Control Act, HOLA, and the Board’s
Regulation Y - Bank Holding Companies and Change in Bank Control (12 CFR 225),
Regulation LL - Savings and Loan Holding Companies (12 CFR 238), and Regulation YY Enhanced Prudential Standards (12 CFR 252). Information about the principal owners and
directors of an HC is of supervisory importance because these individuals can have a significant
effect on the policies and condition of banking organizations. Data on outside business interests
of directors and officers aid in identifying chain-banking organizations by indicating when an
individual owns 25 percent or more of each of two or more banking organizations. Information
on the outside business interests of insiders is useful to identify situations that involve a conflict
of interest or preferential treatment in granting credit. In addition, the FR Y-6 serves as a source
of HC structure information for the public. The FR Y-6 data are available to other federal
financial supervisory agencies for use in their supervision of national and state nonmember
banks.
The Board uses the FR Y-7 to collect financial and structural information from FBOs to
assess each FBO’s ability to be a continuing source of strength to its U.S. operations. In addition,
the Board uses the information to assess eligibility of qualifying FBOs and compliance with U.S.
laws and regulations.
The Board uses the information collected on the FR Y-10 to monitor that the activities of
reporting financial institutions are conducted in a safe and sound manner and to assess
compliance with applicable laws and regulations, including the BHC Act, Gramm-Leach-Bliley
Act, Federal Reserve Act (FRA), HOLA, and the Board’s Regulation Y, Regulation K International Banking Operations (12 CFR 211), Regulation LL, and Regulation YY.

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The Board uses the FR Y-10E when there is an immediate need for critical organizational
information to facilitate collection of the information at the earliest practicable date. The Board
uses these supplemental requests to meet time-sensitive legislative requirements, answer
Congressional inquiries, or respond to critical market events that otherwise could not be
addressed in a sufficiently timely manner.
Description of Information Collection
The FR Y-6 is filed by all top-tier HCs. The report collects an organizational chart and
annual verification of domestic branches within the organization and includes information on the
identity, percentage ownership, and business interests of principal shareholders, directors, and
executive officers. The FR Y-6 can be filed via a paper or electronic (Portable Document
Format) submission to the appropriate Federal Reserve Bank.
The FR Y-7 is an annual report by FBOs that have a U.S. banking presence. The report
collects financial statements, organizational information, shares and shareholder information, and
data on the eligibility to be a qualified FBO as defined by the Board’s Regulation K. The FR Y-7
can be filed via a paper submission mailed to the appropriate Federal Reserve Bank.
The FR Y-10 is an event-generated information collection that captures changes in
organizational structure or the regulated investments and activities of various entities. The
FR Y-10 can be filed electronically or via a paper, email, or fax submission to the appropriate
Federal Reserve Bank.
The FR Y-10E is a formless supplement to the FR Y-10 that the Board uses to collect
additional structural information as needed on an emergency basis. Submission methods vary
depending on the nature and time-sensitivity of the data requests.
Respondent Panel
The FR Y-6 panel comprises bank holding companies, SLHCs, employee share
ownership plans/trusts, securities holding companies, intermediate holding companies (IHCs),
and FBOs that are non-qualifying. In 2012 and 2016, the Board expanded the FR Y-6 reporting
panel to include SLHCs and IHCs respectively. The FR Y-7 panel comprises all qualifying FBOs
that engage in banking in the U.S., either directly or indirectly. The FR Y-10 and FR Y-10E
panel comprises top-tier HCs; FBOs; state member banks that are not controlled by a HC; Edge
and agreement corporations that are not controlled by a member bank, a domestic HC, or an
FBO; and nationally chartered banks that are not controlled by a HC (with regard to their foreign
investments only).
Adopted Revisions
The Board adopted a final rule that establishes risk-based categories for determining
prudential standards for large U.S. banking organizations and foreign banking organizations,
consistent with section 165 of the Dodd-Frank, as amended by the EGRRCPA, and with the
HOLA. The final rule amends certain prudential standards, including standards relating to

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liquidity, risk management, stress testing, and single-counterparty credit limits, to reflect the risk
profile of banking organizations under each category; applies prudential standards to certain
large savings and loan holding companies using the same categories; makes corresponding
changes to reporting forms; and makes additional modifications to the Board’s companyrun
stress test and supervisory stress test rules, consistent with section 401 of EGRRCPA. The final
rule is effective December 31, 2019.
The Board revised item 5 on the FR Y-7, Regulation YY Compliance for the FBO, to
align the reporting form with the applicability thresholds set forth in the final rule and other
regulatory changes that are consistent with the Board’s July 2018 statement concerning
EGRRCPA.2 Specifically, item 5(a) was amended to apply only to foreign savings and loan
holding companies with more than $250 billion in total consolidated assets, and assess
compliance with the capital stress testing requirements under section 238.162 of the Board’s
Regulation LL, as revised under the final rule. Items 5(b) and 5(c) continue to assess compliance
with the risk committee requirements in sections 252.132(a) and 252.144(a) of the Board’s
Regulation YY, respectively, but the descriptions for each item would be updated to conform to
the asset size thresholds under the final rule. For item 5(b), the description eliminated language
referring to foreign banking organizations that are publicly traded, as that distinction was
eliminated under the final rule. Similarly, the Board revised items 5(d) and 5(e) to align the
descriptions of the requirements with the asset size thresholds under the final rule. These items
continue to assess compliance with the capital stress testing requirements in sections 252.146(b)
and 252.158(b) of the Board’s Regulation YY. The first as-of date for the amended FR Y-7 is the
next report after the effective date of the final rule.
There are no changes to the FR Y-6, FR Y-10, or FR Y-10E.
Time Schedule for Information Collection
Covered financial institutions submit the FR Y-6 annually, no later than 90 calendar days
after the end of the respondent’s fiscal year. Qualifying FBOs submit the FR Y-7 annually as of
the end of the FBO’s fiscal year, and the data are due no later than four months after the report
date. The FR Y-10 is event-generated, and covered financial institutions submit the data within
30 calendar days of a reportable transaction or event. The FR Y-10E is event-generated, and the
Board collects the data from covered financial institutions on an as-needed basis.
Public Availability of Data
Limited structural data from the information collection are published on the National
Information Center’s public website at https://www.ffiec.gov/nic/. Unless granted confidential
treatment, additional respondent data are available to the public upon request through the
appropriate Reserve Bank.

2

See Board statement regarding the impact of the Economic Growth, Regulatory Relief, and Consumer Protection
Act, July 6, 2018, available at https://www.federalreserve.gov/newsevents/pressreleases/bcreg20180706b.htm.

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Legal Status
The following statutes authorize the Board to require the collections of information:
FR Y-6: Section 5(c) of the BHC Act (12 U.S.C. § 1844(c)); sections 8(a) and 13(a) of
the International Banking Act of 1978 (IBA) (12 U.S.C. §§ 3106(a) and 3108(a)); sections
11(a)(1), 25, and 25A of the FRA (12 U.S.C. §§ 248(a)(1), 602, and 611a); sections 113, 165,
312, 618, and 809 of the Dodd-Frank Act (12 U.S.C. §§ 5361, 5365, 5412, 1850a(c)(1), and
5468(b)(1)); and section 252.153(b)(2) of Regulation YY (12 CFR 252.153(b)(2)).
FR Y-7: Sections 8(a) and 13(a) of the IBA (12 U.S.C. §§ 3106(a) and 3108(a)) and
sections 113, 165, 312, 618, and 809 of the Dodd-Frank Act (12 U.S.C. §§ 5361, 5365, 5412,
1850a(c)(1), and 5468(b)(1)).
FR Y-10 and FR Y-10E: Sections 4(k) and 5(c)(1)(A) of the BHC Act (12 U.S.C. §§
1843(k) and 1844(c)(1)(A)); section 8(a) of the IBA (12 U.S.C. 3106(a)); sections 11(a)(1),
25(7), and 25A of the FRA (12 U.S.C. §§ 248(a)(1), 321, 601, 602, 611a , 615, and 625);
sections 113, 165, 312, 618, and 809 of the Dodd-Frank Act (12 U.S.C. §§ 5361, 5365, 5412,
1850a(c)(1), and 5468(b)(1)); and section 10(c)(2)(H) of the HOLA (12 U.S.C. §
1467a(c)(2)(H)).
The obligation to respond is mandatory.
The data collected in the FR Y-6, FR Y-7, FR Y-10, and FR Y-10E are generally not
considered confidential. With regard to information that a banking organization may deem
confidential, the institution may request confidential treatment of such information under one or
more of the exemptions in the Freedom of Information Act (FOIA) (5 U.S.C. § 552). The most
likely case for confidential treatment will be based on FOIA exemption 4, which permits an
agency to exempt from disclosure “trade secrets and commercial or financial information
obtained from a person and privileged and confidential” (5 U.S.C. § 552(b)(4)). To the extent an
institution can establish the potential for substantial competitive harm, such information would
be protected from disclosure under the standards set forth in National Parks and Conservation
Association v. Morton, 498 F.2d 765 (D.C. Cir. 1974). In particular, the disclosure of the
responses to the certification questions on the FR Y-7 may interfere with home country
regulators’ administration, execution, and disclosure of their stress test regime and its results, and
may cause substantial competitive harm to the FBO providing the information, and thus this
information may be protected from disclosure under FOIA exemption 4. Exemption 6 of FOIA
might apply with regard to the respondents’ submission of non-public personal information of
owners, shareholders, directors, officers and employees of respondents. Exemption 6 covers
“personnel and medical files and similar files the disclosure of which would constitute a clearly
unwarranted invasion of personal privacy” (5 U.S.C. § 552(b)(6)). All requests for confidential
treatment would need to be reviewed on a case-by-case basis and in response to a specific
request for disclosure.

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Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On November 29, 2018, the Board published a notice of proposed rulemaking for U.S.
banking orginations in the Federal Register (83 FR 61408) for public comment. The comment
period for this notice expired on January 22, 2019. On May 15, 2019, the Board published a
notice of proposed rulemaking for foreign banking orginations in the Federal Register
(84 FR 21988) for public comment. The comment period for this notice expired on June 21,
2019. The Board did not receive any specific comments related to the Paperwork Reduction Act
(PRA) analysis. On November 1, 2019, the Board published a final rule in the Federal Register
(84 FR 59032). The final rule is effective on December 31, 2019.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the structure reports is
69,127 hours, and would decrease to 68,743 hours with the adopted revision. The Board
estimates that revisions to the FR Y-7 would not impact the respondent count, but the estimated
average hours per response would decrease from 6 hours to 4.5 hours. These reporting
requirements represent less than 1 percent of the Board’s total paperwork burden.
Estimated
number of
respondents3
Current
FR Y-6
FR Y-7
FR Y-10
FR Y-10E

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

4,044
256
4,232
4,232

1
1
4.094
1

5.5
6
2.5
0.5

22,242
1,536
43,233
2,116
69,127

4,044
256
4,232
4,232

1
1
4.09
1

5.5
4.5
2.5
0.5

Proposed Total

22,242
1,152
43,233
2,116
68,743

Change

( 384)

Current Total
Proposed
FR Y-6
FR Y-7
FR Y-10
FR Y-10E

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Of these respondents, 3,060 for the FR Y-6; 39 for the FR Y-7; 3,101 for the FR Y-10; and 3,101 for the FR Y-10E
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.
4
In 2018, there were 17,293 FR Y-10’s processed for the 4,232 reporting institutions. This yields an approximate
annual frequency of 4.09.

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The current estimated total annual cost to the public for the structure reports is
$3,981,715 and would decrease to $3,959,597 with the adopted revisions.5
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing these
reports is $2,362,900 per year.

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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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