FRQ_20191211_omb

Supporting Statement for the
Recordkeeping and Disclosure Requirements Associated with Regulation Q
(FR Q; OMB No. 7100-0313)
Regulatory Capital Rule: Simplifications to the Capital Rule Pursuant to the
Economic Growth and Regulatory Paperwork Reduction Act of 1996
(Docket No. R-1576) (RIN 7100-AE74)
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 Recordkeeping and Disclosure Requirements Associated with Regulation Q (FR Q;
OMB No. 7100-0313). In September and October of 2013, the Office of the Comptroller of the
Currency (OCC), Board, and Federal Deposit Insurance Corporation (FDIC) (collectively, the
agencies) published final rules1 that revised their risk-based and leverage capital requirements for
banking organizations. For the Board, Regulation Q - Capital Adequacy of Bank Holding
Companies, Savings and Loan Holding Companies, and State Member Banks (12 CFR 217) was
revised and created recordkeeping and disclosure requirements.
The agencies adopted a final rule to simplify certain aspects of the capital rule. Under the
final rule, non-advanced approaches banking organizations will be subject to simpler regulatory
capital requirements for mortgage servicing assets, certain deferred tax assets arising from
temporary differences, and investments in the capital of unconsolidated financial institutions than
those currently applied. The final rule also simplifies, for non-advanced approaches banking
organizations, the calculation for the amount of capital issued by a consolidated subsidiary of a
banking organization and held by third parties (sometimes referred to as a minority interest) that
is includable in regulatory capital. In addition, the final rule makes technical amendments to, and
clarifies certain aspects of, the agencies’ capital rule for both non-advanced approaches banking
organizations and advanced approaches banking organizations. Section 217.63 of the final rule
breaks out the disclosures in Table 8 to include (1) after-tax gain-on-sale on a securitization that
has been deducted from common equity tier 1 capital and (2) credit-enhancing interest-only strip
that is assigned a 1,250 percent risk weight. The final rule is effective on October 1, 2019.
The current estimated total annual burden for the FR Q is 79,271 hours, and would
remain the same with the adopted revisions.
Background and Justification
Section 1831o(c) of the Federal Deposit Insurance Act requires each federal banking
agency to adopt a risk-based capital requirement, which is based on the prompt corrective action
framework in that section. The International Lending Supervision Act of 1983 (ILSA) (12 U.S.C.
§ 3907(a)(1)) mandates that each federal banking agency require banks to achieve and maintain
adequate capital by establishing minimum levels of capital or by other methods that the
applicable federal banking agency may deem appropriate. Section 908 of the ILSA (12 U.S.C.
1

See 78 FR 55340 (September 10, 2013) and 78 FR 62018 (October 11, 2013).

§ 3907(b)(3)(C)), also directs the Chairman of the Federal Reserve System and the Secretary of
the Treasury to encourage governments, central banks, and regulatory authorities of other major
banking countries to work toward maintaining and, where appropriate, strengthening the capital
bases of banking institutions involved in international lending.
On December 7, 2007, the OCC, Board, FDIC, and Office of Thrift Supervision (OTS)
issued the joint final rule (December 2007 final rule) titled Risk-Based Capital Standards:
Advanced Capital Adequacy Framework implementing a risk-based regulatory capital
framework for institutions in the United States (72 FR 69288). The rule was based on the June
2004 Basel Committee on Banking Supervision’s document, “International Convergence of
Capital Measurement and Capital Standards: A Revised Framework” (New Accord).
The December 2007 final rule implemented the New Accord in the United States and
builds on improvements to risk assessment approaches that a number of large banks have
adopted over the last two decades. In particular, the rule required banks to assign risk parameters
to exposures and provides specific risk-based capital formulas that are used to transform these
risk parameters into risk-based capital requirements. The collection of information contained in
the rule was necessary to ensure that the new risk-based regulatory capital framework is
implemented in the United States in a safe and sound manner.
On October 11, 2013, the OCC and Board adopted a final rule that revised their riskbased and leverage capital requirements for banking organizations. The final rule consolidated
three separate notices of proposed rulemaking that the OCC, Board, and FDIC published with
selected changes.2 The final rule implemented a revised definition of regulatory capital, a new
common equity tier 1 minimum capital requirement, a higher minimum tier 1 capital
requirement, and, for banking organizations subject to the advanced approaches risk-based
capital rules, a supplementary leverage ratio that incorporated a broader set of exposures in the
denominator. The final rule incorporated these new requirements into the agencies’ prompt
corrective action framework. In addition, the final rule established limits on a banking
organization’s capital distributions and certain discretionary bonus payments if the banking
organization does not hold a specified amount of common equity tier 1 capital in addition to the
amount necessary to meet its minimum risk-based capital requirements. Further, the final rule
amended the methodologies for determining risk-weighted assets for all banking organizations,
and introduced disclosure requirements that would apply to top-tier banking organizations
domiciled in the United States with $50 billion or more in total assets. The final rule also adopted
changes to the agencies’ regulatory capital requirements that meet the requirements of section
171 and section 939A of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act).3
The final rule also codified the agencies’ regulatory capital rules, which had previously
resided in various appendices to their respective regulations, into a harmonized integrated
regulatory framework. In addition, the Board amended the advanced approaches and market risk
rules to apply to top-tier savings and loan holding companies domiciled in the United States,

2
3

See 77 FR 52792, 77 FR 52888, and 77 FR 52978 (August 30, 2012).
See Public Law 111-203, 124 Stat. 1376, 1435-38 (2010).

2

except for certain savings and loan holding companies that are substantially engaged in insurance
underwriting or commercial activities.
Description of Information Collection
The recordkeeping requirements are found in sections 217.3(d), 217.22(h)(2)(iii)(A),
217.35(b)(3)(i)(A), 217.37(c)(4)(i)(E), 217.41(b)(3), 217.41(c)(2)(i), 217.41(c)(2)(ii),
217.121(b), 217.122, 217.123, 217.124, 217.132(b)(2)(iii)(A), 217.132(b)(3), 217.132(d)(1),
217.132(d)(1)(iii), 217.132(d)(2)(iv), 217.132(d)(3)(vi), 217.132(d)(3)(viii), 217.132(d)(3)(ix),
217.132(d)(3)(x), 217.132(d)(3)(xi), 217.141(b)(3), 217.141(c)(1), 217.141(c)(2)(i)-(ii), and
217.153. The disclosure requirements are found in sections 217.42(e)(2), 217.62, 217.63,
217.142, 217.172, and 217.173 Tables 4, 5, 9, 12, and 13. No other federal law mandates these
recordkeeping and disclosure requirements.
Minimum Capital Ratios
Recordkeeping Requirements
Section 217.3(d) provides for termination and close-out netting across multiple types of
transactions or agreements if the bank obtains a written legal opinion verifying the validity and
enforceability of the agreement under certain circumstances and maintains sufficient written
documentation of this legal review.
Section 217.22(h)(2)(iii)(A) allows the use of a conservative estimate of the amount of a
bank’s investment in the capital of unconsolidated financial institutions held through the index
security with prior approval by the appropriate agency.
Standardized Approach
Recordkeeping Requirements
Section 217.35(b)(3)(i)(A) requires, for a cleared transaction with a qualified central
counterparty (QCCP), that a client bank apply a risk weight of 2 percent, provided that the
collateral posted by the bank to the QCCP is subject to certain arrangements and the client bank
has conducted a sufficient legal review (and maintains sufficient written documentation of the
legal review) to conclude with a well-founded basis that the arrangements, in the event of a legal
challenge, would be found to be legal, valid, binding, and enforceable under the law of the
relevant jurisdictions.
Section 217.37(c)(4)(i)(E) requires that a bank have policies and procedures describing
how it determines the period of significant financial stress used to calculate its own internal
estimates for haircuts and be able to provide empirical support for the period used.
Section 217.41(b)(3) allows for synthetic securitizations a bank’s recognition, for riskbased capital purposes, of a credit risk mitigant to hedge underlying exposures if certain

3

conditions are met, including the bank’s having obtained a well-reasoned opinion from legal
counsel that confirms the enforceability of the credit risk mitigant in all relevant jurisdictions.
Section 217.41(c)(2)(i) requires that a bank support a demonstration of its comprehensive
understanding of a securitization exposure by conducting and documenting an analysis of the
risk characteristics of each securitization exposure prior to its acquisition, taking into account a
number of specified considerations.
Section 217.41(c)(2)(ii) requires on an on-going basis (no less frequently than quarterly),
a bank must evaluate, review, and update as appropriate the analysis required under this section
for each securitization exposure.
Disclosure Requirements
Section 217.42(e)(2) addresses risk-weighted assets for securitization exposures and
requires that a bank publicly disclose that is has provided implicit support to the securitization
and the risk-based capital impact to the bank of providing such implicit support.
Section 217.62 sets forth disclosure requirements related to a bank’s capital requirements.
Section 217.62(a) specifies a quarterly frequency for the disclosure of information in the
applicable tables set out in section 63 and, if a significant change occurs, such that the most
recent reported amounts are no longer reflective of the bank’s capital adequacy and risk profile,
it also requires the bank to disclose as soon as practicable thereafter, a brief discussion of the
change and its likely impact. This section allows for annual disclosure of qualitative information
that typically does not change each quarter, provided that any significant changes are disclosed
in the interim. Section 217.62(b) requires that a bank have a formal disclosure policy approved
by the board of directors that addresses its approach for determining the disclosures it makes.
The policy is required to address the associated internal controls and disclosure controls and
procedures. Section 217.62(c) requires a bank with total consolidated assets of $50 billion or
more that is not an advanced approaches bank, if it concludes that specific commercial or
financial information required to be disclosed under section 217.62 is exempt from disclosure by
the agency under the Freedom of Information Act (5 U.S.C. 552), to disclose more general
information about the subject matter of the requirement and the reason the specific items of
information have not been disclosed.
Section 217.63 sets forth disclosure requirements for banks with total consolidated assets
of $50 billion or more that are not advanced approaches banks. Section 217.63(a) requires a
covered institution to make the disclosures in Tables 1 through 10. The covered institution must
make these disclosures publicly available for each of the last three years (that is, twelve quarters)
or such shorter period beginning on January 1, 2015. Section 217.63(b) requires quarterly
disclosure of a bank’s common equity tier 1 capital, additional tier 1 capital, tier 2 capital, tier 1
and total capital ratios, including the regulatory capital elements and all the regulatory
adjustments and deductions needed to calculate the numerator of such ratios; total risk-weighted
assets, including the different regulatory adjustments and deductions needed to calculate total
risk-weighted assets; regulatory capital ratios during any transition periods, including a
description of all the regulatory capital elements and all regulatory adjustments and deductions

4

needed to calculate the numerator and denominator of each capital ratio during any transition
period; and a reconciliation of regulatory capital elements as they relate to its balance sheet in
any audited consolidated financial statements.
Tables 1 through 10 in section 217.63 set forth qualitative and quantitative disclosure
requirements for scope of application, capital structure, capital adequacy, capital conservation
buffer, credit risk, counterparty credit risk-related exposures, credit risk mitigation,
securitizations, equities not subject to Subpart F (Risk-Weighted Assets - Market Risk) of the
rule, and interest rate risk for non-trading activities.
Advanced Approach
Recordkeeping Requirements
Sections 217.121 and 122 requires that a covered institution adopt a written
implementation plan that addresses how it will comply with the advanced capital adequacy
framework’s qualification requirements, including incorporation of a comprehensive and sound
planning and governance process to oversee the implementation efforts. The institution must also
develop processes for assessing capital adequacy in relation to an organization’s risk profile. It
must establish and maintain internal risk rating and segmentation systems for wholesale and
retail risk exposures, including comprehensive risk parameter quantification processes and
processes for annual reviews and analyses of reference data to determine their relevance. It must
document its process for identifying, measuring, monitoring, controlling, and internally reporting
operational risk; verify the accurate and timely reporting of risk-based capital requirements; and
monitor, validate, and refine its advanced systems.
Section 217.123 requires an institution to notify its Federal supervisor of changes to
advance systems and requires submission of a plan for returning to compliance with qualification
requirements.
Section 217.124 requires an institution to notify its primary Federal supervisor when it
makes a material change to its advanced systems and to develop an implementation plan after
any mergers.
Section 217.132(b)(2)(iii)(A) addresses counterparty credit risk of repo-style transactions,
eligible margin loans, and over-the-counter (OTC) derivative contracts and allows an institution,
with the prior written approval of the agency, to calculate haircuts (Hs and Hfx) using its own
internal estimates of the volatilities of market prices and foreign exchange rates. To receive
Board approval to use its own internal estimates, an institution must satisfy the minimum
quantitative standards outlined in this section.
Section 217.132(b)(3) provides that with the prior written approval of the agency, an
institution may estimate exposure at default (EAD) for a netting set using a value-at-risk (VaR)
model that meets certain requirements.

5

Section 217.132(d)(1) allows the use of the internal models methodology to determine
EAD for counterparty credit risk for derivative contracts with prior written approval.
Section 217.132(d)(1)(iii) allows the use of the internal models methodology for
derivative contracts, eligible margin loans, and repo-style transactions subject to a qualifying
cross-product netting agreement with prior written approval.
Section 217.132(d)(2)(iv) provides that for risk-weighted assets using the internal models
methodology (IMM), an institution uses an internal model to estimate the expected exposure
(EE) for a netting set and then calculates EAD based on that EE. An institution must calculate
two EEs and two EADs (one stressed and one unstressed) for each netting as outlined in this
section.
Section 217.132(d)(3)(vi) requires that an institution, in order to obtain agency approval
to calculate the distributions of exposures upon which the EAD calculation is based, must
demonstrate to the satisfaction of the agency that it has been using for at least one year an
internal model that broadly meets the minimum standards, with which the institution must
maintain compliance. The institution must have procedures to identify, monitor, and control
wrong-way risk throughout the life of an exposure. The procedures must include stress testing
and scenario analysis.
Section 217.132(d)(3)(viii) requires that when estimating model parameters based on a
stress period, the institution must use at least three years of historical data that include a period of
stress to the credit default spreads of the institution’s counterparties. The institution must review
the data set and update the data as necessary, particularly for any material changes in its
counterparties. The institution must demonstrate at least quarterly that the stress period coincides
with increased credit default swap (CDS) or other credit spreads of the institution’s
counterparties. The institution must have procedures to evaluate the effectiveness of its stress
calibration that include a process for using benchmark portfolios that are vulnerable to the same
risk factors as the institution’s portfolio. The agency may require the institution to modify its
stress calibration to better reflect actual historic losses of the portfolio.
Section 217.132(d)(3)(ix) requires that an institution subject its internal model to an
initial validation and annual model review process. The model review should consider whether
the inputs and risk factors, as well as the model outputs, are appropriate. As part of the model
review process, the institution must have a backtesting program for its model that includes a
process by which unacceptable model performance will be determined and remedied.
Section 217.132(d)(3)(x) requires that an institution must have policies for the
measurement, management, and control of collateral and margin amounts.
Section 217.132(d)(3)(xi) requires that an institution have a comprehensive stress testing
program that captures all credit exposures to counterparties, and incorporates stress testing of
principal market risk factors and creditworthiness of counterparties.

6

Section 217.141 addresses operational criteria for recognizing the transfer of risk.
Section 217.141(b)(3) requires a well-reasoned legal opinion confirming the enforceability of the
credit risk mitigant in all relevant jurisdictions. Section 217.141(c)(1) and 217.141(c)(2)(i)
require an advanced approaches institution to demonstrate its comprehensive understanding of a
securitization exposure for each securitization exposure by conducting an analysis of the risk
characteristics of a securitization exposure prior to acquiring the exposure and document such
analysis within three business days after acquiring the exposure. Section 217.141(c)(2)(ii)
requires that, on an ongoing basis (no less frequently than quarterly), a bank must evaluate,
review, and update as appropriate the analysis required under this section for each securitization
exposure.
Section 217.153 provides that an institution must receive prior written approval from its
primary Federal supervisor before it can use internal models approach (IMA).
Disclosure Requirements
Section 217.142 which outlines the capital treatment for securitization exposures,
requires that an institution disclose publicly that it has provided implicit support to the
securitization and the regulatory capital impact to the bank of providing such implicit support.
Section 217.172 specifies that each consolidated institution must publicly disclose its
total and tier 1 risk-based capital ratios and their components.
Section 217.173 requires an institution that is an advanced approaches institution to make
the qualitative and quantitative disclosures described in Tables 1 through 12. The institution
must make these disclosures publicly available for each of the last three years (that is, twelve
quarters) or such shorter period beginning on January 1, 2014. Table 4 to section 217.173
addresses disclosures related to capital conservation and countercyclical capital buffers, Table 5
to section 217.173 addresses general disclosures related to credit risk, Table 9 to section 217.173
addresses disclosures related to securitizations, Table 12 to section 217.173 addresses disclosures
related to interest rate risk for non-trading activities, and Table 13 to section 217.173 addresses
disclosures related to supplementary leverage ratios.
Risk-based Capital Surcharge for GSIBs
Recordkeeping Requirements
A bank holding company (BHC) is a global systemically important BHC (GSIB) if its
method 1 score equals or exceeds 130 basis points. A BHC must calculate its method 1 and
method 2 scores on an annual basis by December 31 of each year.
Section 217.402 requires an advanced approaches BHC to annually calculate its method 1
score, which is the sum of its systemic indicator scores for the twelve systemic indicators set
forth in Table 1 of the final rule. The systemic indicator score in basis points for a given systemic
indicator is equal to the ratio of the amount of that systemic indicator, as reported on the bank
holding company’s most recent Banking Organization Systemic Risk Report (FR Y-15; OMB

7

No. 7100-0352); to the aggregate global indicator amount for that systemic indicator published
by the Board in the fourth quarter of that year; multiplied by 10,000; and multiplied by the
indicator weight corresponding to the systemic indicator as set forth in Table 1 of the final rule.
Section 217.403 requires a BHC to annually calculate its GSIB surcharge, which is the
greater of its method 1 and method 2 scores. The method 2 score is equal to the sum of the global
systemically important BHC’s systemic indicator scores for the nine systemic indicators set forth
in Table 1 of the final rule and the global systemically important BHC’s short-term wholesale
funding score. The systemic indicator score is equal to the amount of the systemic indicator, as
reported on the global systemically important BHC’s most recent FR Y-15, multiplied by the
coefficient corresponding to the systemic indicator set forth in Table 1 of the final rule.
Adopted Revisions to the FR Q
The agencies adopted a final rule to simplify certain aspects of the capital rule. The final
rule is responsive to the agencies’ March 2017 report to Congress pursuant to the Economic
Growth and Regulatory Paperwork Reduction Act of 1996, in which the agencies committed to
meaningfully reduce regulatory burden, especially on community banking organizations. The
key elements of the final rule apply solely to banking organizations that are not subject to the
advanced approaches capital rule (non-advanced approaches banking organizations). Under the
final rule, non-advanced approaches banking organizations will be subject to simpler regulatory
capital requirements for mortgage servicing assets, certain deferred tax assets arising from
temporary differences, and investments in the capital of unconsolidated financial institutions than
those currently applied. The final rule also simplifies, for non-advanced approaches banking
organizations, the calculation for the amount of capital issued by a consolidated subsidiary of a
banking organization and held by third parties (sometimes referred to as a minority interest) that
is includable in regulatory capital. In addition, the final rule makes technical amendments to, and
clarifies certain aspects of, the agencies’ capital rule for both non-advanced approaches banking
organizations and advanced approaches banking organizations. The final rule is effective on
October 1, 2019, except for the amendments to 12 CFR 217.21, 217.22, and 217.300(b) and (d),
which are effective January 1, 2020.
Section 217.63 of the final rule breaks out the disclosures in Table 8 to include (1) aftertax gain-on-sale on a securitization that has been deducted from common equity tier 1 capital and
(2) credit-enhancing interest-only strip that is assigned a 1,250 percent risk weight.
Time Schedule for Information Collection
This information collection contains recordkeeping and disclosure requirements, as
mentioned above. The recordkeeping and disclosure requirements are required annually and
quarterly.
Legal Status
Section 38(o) of the Federal Deposit Insurance Act (12 U.S.C. § 1831o(c)), section 908
of the ILSA (12 U.S.C. § 3907(a)(1)), section 9(6) of the Federal Reserve Act (12 U.S.C. § 324),

8

and section 5(c) of the Bank Holding Company Act of 1956 (12 U.S.C. § 1844(c)) authorize the
Board to require the information collection. The obligation to respond to this information
collection is mandatory.
If a respondent considers the information to be trade secrets and/or privileged such
information could be withheld from the public under the authority of the Freedom of Information
Act (5 U.S.C. § 552(b)(4)). Additionally, to the extent that such information may be contained in
an examination report such information maybe also be withheld from the public (5 U.S.C. § 552
(b)(8)).
Consultation Outside the Agency
The Board worked with the OCC and FDIC to amend the regulation that is requiring this
revision.
Public Comments
On October 27, 2017, the agencies published a joint notice of proposed rulemaking in the
Federal Register (82 FR 49984) requesting public comment for 60 days on the extension, with
revision, of the FR Q. The comment period for this notice expired on December 26, 2017. The
agencies received no comments on the Paperwork Reduction Act (PRA). On July 22, 2019, the
agencies published a final rule in the Federal Register (84 FR 35234). On November 13, 2019,
the agencies published a notice in the Federal Register (84 FR 61804) to revise the effective date
of the final rule. The final rule is effective on October 1, 2019, except for the amendments to 12
CFR 217.21, 217.22, and 217.300(b) and (d), which are effective January 1, 2020.
Estimate of Respondent Burden
As shown in the table below, the current estimated total annual burden for the FR Q is
79,727 hours, and would remain the same with the adopted revisions. These recordkeeping and
disclosure requirements represent less than 1 percent of the Board’s total paperwork burden.

9

FR Q
Initial Setup
Standardized Approach
Recordkeeping
Sections 217.35(b)(3)(i)(A),
217.37(c)(4)(i)(E),
217.41(b)(3), and
217.41(c)(2)(i)
Disclosure
Sections 217.42(e)(2), 217.62,
and 217.63

Estimated
number of
respondents4

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

1

1

122

122

1

1

226.25

226

1

1

460

460

1

1

328

328
1,136

Ongoing
Minimum Capital Ratios
Recordkeeping
Sections 217.3(d) and
217.22(h)(2)(iii)(A)

1,431

1

16

22,896

Standardized Approach
Recordkeeping
Sections 217.35(b)(3)(i)(A),
217.37(c)(4)(i)(E), and
217.41(c)(2)(ii)

1,431

1

20

28,620

Advanced Approach
Recordkeeping
Sections 217.132(b)(2)(iii)(A),
217.132(d)(2)(iv),
217.132(d)(3)(vi),
217.132(d)(3)(viii),
217.132(d)(3)(ix),
217.132(d)(3)(x),
217.132(d)(3)(xi),
217.141(b)(3), 217.141(c)(1),
217.141(c)(2)(i)-(ii), and
217.153
Disclosure
Section 217.173 Tables 2, 3, 4,
5, 9, and 12
Initial Setup Total

4

Of these respondents, 628 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.

10

Disclosure
Sections 217.42(e)(2), 217.62,
and 217.63
Advanced Approach
Recordkeeping
Sections 217.121(b), 217.122,
217.123, 217.124,
217.132(b)(2)(iii)(A),
217.132(b)(3), 217.132(d)(1),
217.132(d)(1)(iii),
217.132(d)(2)(iv),
217.132(d)(3)(ix), and
217.132(d)(3)(xi)
Sections 217.132(d)(3)(viii)
and 217.141(c)(2)(i)-(ii)
Disclosure
Sections 217.142 and 217.172
Section 217.173 Tables 2, 3, 4,
5, 9, and 12
Section 217.173 Table 13
Risk-based Capital Surcharge
for GSIBs
Recordkeeping
Sections 217.402 and 217.403
Ongoing Total

25

4

131.25

13,125

17

1

540.77

9,193

17

4

17

1

17
25

4
4

21

1

20
5.78
41
5

0.5

Total

1,360
98
2,788
500

11
78,591
79,727

The estimated total annual cost to the public for this information collection is
$4,592,275.5
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.

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/.

11

Estimate of Cost to the Federal Reserve System
The cost to the Federal Reserve System is negligible.

12