FFIEC101_20200206_omb

Supporting Statement for the
Regulatory Capital Reporting for Institutions Subject to the
Advanced Capital Adequacy Framework
(FFIEC 101; OMB No. 7100-0319)
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) Regulatory Capital Reporting for
Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101; OMB No.
7100-0319). The FFIEC 101 collects data regarding the levels and components of risk-based
capital from firms subject to the Board’s advanced approaches capital framework (advanced
approaches framework), as well as data regarding the supplementary leverage ratio (SLR) from
firms subject to that requirement. The FFIEC 101 must be filed quarterly by certain large or
internationally active state member banks (SMBs), bank holding companies (BHCs), savings and
loan holding companies (SLHCs) that are subject to the advanced approaches framework and
other Board-regulated institutions that adopt the framework on a voluntary basis (collectively,
advanced approaches banking organizations); additionally, certain BHCs, SLHCs, SMBs, and
U.S. intermediate holding companies (IHCs) that are not advanced approaches banking
organizations must report only certain information regarding the SLR. The revisions to the
FFIEC 101 that are the subject of this request have been approved by the FFIEC.
The Board, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller
of the Currency (OCC) (collectively, the agencies) propose to revise the FFIEC 101 by (1)
modifying the respondent panel to account for changes in the scope of the advanced approaches
framework, (2) revising Schedule A to exclude from the SLR calculation certain central bank
deposits of custodial banks, based on recent changes to the agencies’ capital rule, and (3)
revising the instructions for SLR Table 2 consistent with a proposed rule that would implement a
new approach for calculating the exposure amount of derivative contracts under the capital rule
(the standardized approach for counterparty credit risk). Most of the proposed revisions would
take effect in the same quarters as the effective dates of the capital rule changes, i.e., primarily as
of the March 31, 2020, and June 30, 2020, report dates.
The current estimated total annual burden for the FFIEC 101 is 46,060 hours, and would
decrease to 35,276 hours. The proposed revisions would result in a decrease of 10,784 hours.
The draft form and instructions are available on the FFIEC’s public website at
https://www.ffiec.gov/ffiec_report_forms.htm.
Background and Justification
A number of federal laws require the Board to establish capital requirements for entities it
supervises.1 The Board’s current risk-based and leverage capital standards are codified in the
1

Section 171 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires the Board to establish
minimum risk-based and leverage capital requirements on a consolidated basis for the insured depository

Board’s Regulation Q - Capital Adequacy of Bank Holding Companies, Savings and Loan
Holding Companies, and State Member Banks (12 CFR Part 217). The Board’s risk-based capital
standards include an advanced approaches capital framework for large and internationally active
banking organizations. Banking organizations that use this framework report information related
to their risk-based capital requirements using the FFIEC 101.
With respect to the advanced approaches framework, the Board uses the data reported on
the FFIEC 101 to:
 Assess the components of each advanced approaches banking organization’s risk-based
capital requirements,
 Assess each advanced approaches banking organization’s capital relative to inherent risks
and the Board’s minimum capital requirements,
 Assess the components of each advanced approaches banking organization and top-tier
Category III2 BHCs, SHCs, and SMBs, and all Category III IHCs of its SLR. The SLR is
the ratio of tier 1 capital to total leverage exposure, as defined in the regulatory capital
rule,
 Monitor the levels and components of the risk-based capital requirements for advanced
approaches banking organizations through peer, outlier, and risk trend analyses,
 Evaluate the quantitative impact and competitive implications of the implementation of
the framework on risk-based capital levels within advanced approaches banking
organizations and on an overall industry basis,
 Ensure that the advanced approaches framework is implemented in the United States in a
safe and sound manner,
 Provide market participants, depositors, the public, supervisors, and other interested
parties with information about advanced approaches banking organizations’ risk-based
capital, and
 Supplement on-site examination processes and decisions pertaining to the allocation of
supervisory resources.
The information collected by the FFIEC 101 is not available from other sources.
Description of Information Collection
The mandatory FFIEC 101 report collects information from all Board-supervised
advanced approaches banking organizations, as well as information regarding the SLR from
Category III institutions. Advanced approaches banking organizations are required to submit
detailed data on the components of their capital and risk-weighted assets in nineteen schedules
(A through S). Category III institutions must complete only Schedule A, SLR Tables 1 and 2.

institutions, depository institution holding companies, and nonbank financial companies it supervises (12 U.S.C. §
5371(b)(1)-(2)). Further, the International Lending Supervision Act of 1983 (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 agency may deem appropriate and section 38(c) of the Federal Deposit
Insurance Act (12 U.S.C. § 1831o(c)) requires each federal banking agency to adopt a risk-based capital requirement
for insured depository institutions.
2
See page 5 for a description of the tailoring rule standards (categories).

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Advanced Approaches Regulatory Capital and Summary Risk-Weighted Asset
Information. Schedule A collects information about the components of Tier 1 capital, Tier 2
capital, and adjustments to regulatory capital as defined within the rule. Schedule B contains
summary information about risk-weighted assets by risk type, and, in the case of credit risk
exposures, outstanding balances and aggregated information about the drivers and estimates that
underlie the calculation of risk-weighted assets. Tables 1 and 2 of Schedule A collect
information about each advanced approaches banking organization and top-tier Category III
BHCs, SHCs, and SMBs, and all Category III IHCs SLR, the ratio of tier 1 capital to total
leverage exposure. Table 1 reconciles balance sheet assets reported in published financial
statements and total leverage exposure. Table 2 collects components of on-balance sheet and offbalance sheet exposures, for the calculation of total leverage exposure, tier 1 capital, and the
calculation of the SLR.
Schedule B collects general exposure information from advanced approaches banking
organizations. Respondents must report:
 Wholesale exposures, including separate reporting for the following types of exposures:
Corporate; Bank; Sovereign; Income producing real estate; High volatility commercial
real estate; Eligible margin loans, repo-style transactions, and OTC derivatives with cross
product netting; and Eligible margin loans, repo-style transactions, and OTC derivatives
without cross product netting,
 Retail Exposures, including separate reporting for the following types of exposures:
Residential mortgage closed-end first liens, Residential mortgage closed-end junior liens,
Residential mortgage revolving exposures, Qualifying revolving exposures, and Other
retail exposures,
 Securitization exposures,
 Cleared transactions, including separate reporting for the following types of exposures:
Derivative contracts and netting sets to derivatives, Repo-style transactions, and Default
fund contributions,
 Equity exposures, and
 Other assets; including separate reporting for the following types of exposures: Unsettled
transactions, Assets not included in a defined exposure category, Non-material portfolios
of exposures, Credit valuation adjustments, Assets subject to the general risk-based
capital requirements, Excess eligible credit reserves not included in Tier 2 capital,
Advanced market risk equivalent assets; and Operational risk.
Some of the aggregate data items submitted in Schedule B are derived from information
contained in the more detailed confidential supporting schedules described below. The data
contained in Schedule B describe the main summary-level components of respondents’ riskweighted assets.
Wholesale Exposures. Schedules C through J request data on respondents’ wholesale
exposures. Each schedule represents a sub-portfolio of the wholesale exposure category as listed
on Schedule B. For each reported sub-portfolio, the schedule groups exposures into sub-portfolio
segments using supervisor-defined probability of default (PD) ranges. The reported cells within
these schedules then describe the main risk parameters and characteristics of each sub-portfolio
segment.
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Retail Exposures. Schedules K through O request data on respondents’ retail exposure
category. Each schedule represents a sub-portfolio of the retail exposure category as listed on
Schedule B. PD ranges are used to sub-divide each sub-portfolio into segments.3 The reported
cells within these schedules then describe the main risk parameters and characteristics of each
sub-portfolio segment. The retail schedules also incorporate risk characteristics that are believed
to be commonly used drivers within respondents’ risk management and measurement processes,
including the distribution of each sub-portfolio segment by loan-to-value ranges (applies only to
real estate exposures), weighted average credit bureau score, and weighted average account age. 4
Securitization Exposures. Schedule P requests data on respondents’ securitization and
resecuritization exposures that are subject to either the supervisory formula approach, the
simplified supervisory formula approach, a 1250 percent risk weight, or deduction. A respondent
completes Schedule P by providing information on exposure amount, risk-weighted asset
amount, and deduction amount for each securitization and resecuritization based on the treatment
the exposure is subject to under the rule.
Cleared Transactions. Schedule Q requests data on respondents’ cleared transaction
exposures. The schedule divides cleared transactions into subcategories relating to the Clearing
member client bank and to the Clearing member bank. For the Clearing member client bank
category, a respondent completes Schedule Q by providing exposure amount and risk weighted
asset amount information on derivative contracts or netting sets of derivative contracts and repostyle transactions. Schedule Q requests that respondents’ provide exposure amount from default
fund contributions and risk-weighted asset amounts for exposures within the Clearing member
bank category, which include derivative contracts or netting sets of derivative contracts, repostyle transactions, and default fund contributions to non-qualified and qualified central
counterparties.
Equities. Schedule R requests information about respondents’ equity exposures by type of
exposure and by approach to measuring required capital. Schedule R also requests information
on equity exposures subject to specific risk weights and equity exposures to investment funds. A
respondent completes the appropriate section of the schedule based on whether it uses a simple
risk-weight approach, a full internal models approach, or a partially modeled approach to
measuring required capital for equity exposures.
Operational Risk. Schedule S requests data on respondents’ operational risk exposure.
Data items submitted in this schedule include various details about historical operational losses,
on a stand-alone and group-wide basis, for the current reporting period and those historical
operational losses used to model operational risk capital. The schedule also requests data related
to scenarios, distribution assumptions, and loss caps used to model operational risk capital.

3

Unlike the wholesale credit exposure reporting schedules, the PD ranges for retail exposures differ from subportfolio to sub-portfolio.
4
For qualifying revolving exposures and other (non-mortgage) retail exposures, the exposure at default of accounts
under two years old is reported instead of weighted average age for each sub-portfolio exposure segment.

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Respondent Panel
The FFIEC 101 panel consists of SMBs, BHCs, SLHCs, and other Board-regulated
institutions that are subject to the advanced approaches framework pursuant to subpart E of the
Board’s Regulation Q (12 CFR Part 217, Subpart E), as well as, with regard to Schedule A, SLR
Tables 1 and 2, Category III SMBs, BHCs, SLHCs, and IHCs.
Proposed Revisions to the FFIEC 101
Tailoring Rules
On November 1, 2019, the agencies published a final rule to revise the criteria for
determining the applicability of regulatory capital and liquidity requirements for large U.S.
banking organizations and the U.S. intermediate holding companies of certain foreign banking
organizations (tailoring final rule).5
Under the tailoring final rule, the most stringent set of standards (Category I) applies to
U.S. global systemically important banks (GSIBs). The second set of standards (Category II)
applies to banking organizations that are very large or have significant international activity, but
are not GSIBs. Like Category I, this category generally includes standards that that reflect
agreements reached by the Basel Committee on Banking Supervision. All banking organizations
subject to Category I and Category II standards are advanced approaches institutions. The third
set of standards (Category III) applies to banking organizations with $250 billion or more in total
consolidated assets that do not meet the criteria for Category I or II. This set of standards also
applies to banking organizations with total consolidated assets of $100 billion or more, but less
than $250 billion, that meet or exceed other specified risk-based indicators. The fourth set of
standards (Category IV) applies to banking organizations with total consolidated assets of $100
billion or more that do not meet the thresholds for one of the other categories.
Under the tailoring final rule, depository institution subsidiaries generally are subject to
the same category of standards that apply at the holding company level.6
Based on the capital and liquidity requirements that would apply to institutions subject to
Category I, II, III, or IV capital standards in the tailoring final rule, the agencies propose to
amend the FFIEC 101 to clarify the reporting requirements for those institutions that would be
subject to the tailoring final rule. Specifically, the agencies propose changes to FFIEC 101
Schedule A, Advanced Approaches Regulatory Capital, for institutions subject to Category III
capital standards.7
5

Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements, 84 FR 59230
(November 1, 2019); Prudential Standards for Large Bank Holding Companies, Savings and Loan Holding
Companies, and Foreign Banking Organizations, 84 FR 59032 (November 1, 2019).
6
However, standardized liquidity requirements apply only to depository institution subsidiaries with $10 billion or
more in total consolidated assets under Categories I through III, and such requirements do not apply to depository
institution subsidiaries under Category IV.
7
The agencies do not believe reporting form or instructional clarifications are needed to reflect capital requirements
that would apply to institutions subject to Category I, II, or IV capital standards under the tailoring final rule.

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To implement this change, the agencies propose to revise the instructions to state that
top-tier Category III BHCs, SLHCs, SMBs, and IHCs must complete FFIEC 101 Schedule A,
SLR Tables 1 and 2, only.8
Supplementary Leverage Ratio for Certain Central Bank Deposits of Custodial Banks
Rule
On November 19, 2019, the agencies announced that they had finalized the proposed
revisions to the SLR for certain central bank deposits of banking organizations predominantly
engaged in custodial activities.9 The final rule, which implements section 402 of the Economic
Growth, Regulatory Relief, and Consumer Protection Act,10 takes effect April 1, 2020. Section
402 directs the agencies to amend the capital rule11 to exclude from the SLR certain central bank
deposits of custodial banks. Section 402 defines a custodial bank as any depository institution
holding company predominantly engaged in custody, safekeeping, and asset servicing activities,
including any insured depository institution subsidiary of such a holding company.
In order to reflect the regulatory changes of the final rule that implements section 402, the
agencies propose to revise the total leverage exposure calculation that would be reported on the
FFIEC 101, Schedule A. Currently, there are two calculations for the total leverage exposure in
Schedule A, one is contained in SLR Table 1 and the other is in SLR Table 2. The agencies
propose to add a new data item to both tables in FFIEC 101 Schedule A for the qualifying central
bank deduction. The new reporting item would be placed between existing data items 1.7 and 1.8
in SLR Table 1, with the instructions for the total leverage exposure expected to include the new
reporting item in the total calculation. Similarly, for SLR Table 2, the new reporting item would
be placed between data items 2.2 and 2.3 and the total leverage exposure would be modified to
include the new reporting item in the total calculation.
Standardized Approach for Counterparty Credit Risk on Derivative Contracts Rule
On January 24, 2020, the agencies published a final rule to implement a new approach for
calculating the exposure amount of derivative contracts under the capital rule: the standardized
approach for counterparty credit risk (SA-CCR) (SA-CCR final rule).12
Under the final rule, an advanced approaches banking organization may use SA-CCR or
the internal models methodology to calculate its advanced approaches total risk-weighted assets,
and must use SA-CCR, instead of the current exposure methodology (CEM), to calculate its
8

Any Category III banking organization that is a consolidated subsidiary of a top-tier Category III bank holding
company, savings and loan holding company, or insured depository institution would not complete or file any part of
the FFIEC 101. Those subsidiary banking organizations would report SLR data on Schedule RC-R of the
Call Reports.
9
See the custodial bank SLR final rule attached to OCC News Release 2019-135 (https://www.occ.gov/newsissuances/news-releases/2019/nr-ia-2019-135.html), Board Press Release
(https://www.federalreserve.gov/newsevents/pressreleases/bcreg20191119a.htm), and FDIC Press Release 109 2019
(https://www.fdic.gov/news/news/press/2019/pr19109.html), all of which are dated November 19, 2019.
10
Pub.L. 115-174.
11
See 12 CFR Part 3 (OCC); 12 CFR Part 217 (Board); 12 CFR Part 324 (FDIC).
12
85 FR 4362 (January 24, 2020).

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standardized total risk-weighted assets. A non-advanced approaches banking organization may
use the CEM or SA-CCR to calculate its standardized total risk-weighted assets. The final rule
also implements SA-CCR in other aspects of the capital rule. Notably, the final rule requires an
advanced approaches banking organization to use SA-CCR to determine the exposure amount of
derivative contracts included in the banking organization’s total leverage exposure, the
denominator of the SLR. In addition, the final rule incorporates SA-CCR into the cleared
transactions framework and makes other amendments, generally with respect to cleared
transactions.
An advanced approaches institution must report the exposure amount of its derivatives in
SLR Table 2 of FFIEC 101 Schedule A. The Board proposes to revise the instructions for SLR
Table 2 consistent with the SA-CCR final rule. In particular, the instructions would state that
institutions that are required to use SA-CCR for the purpose of the SLR would apply the
SA-CCR-based exposure amount without consideration of the various collateral items currently
listed in the instructions for SLR Table 2. Institutions that continue to use the CEM would
continue to complete SLR Table 2 in the same manner as currently.
Time Schedule for Information Collection
The FFIEC 101 is collected quarterly as of the end of the last calendar day of March,
June, September, and December. Respondents must begin reporting on the FFIEC 101,
Schedule A, except for a few specific line items, beginning with the calendar quarter
immediately following the quarter in which the respondent becomes an advanced approaches or
Category III banking institution (Schedule A, SLR Tables 1 and 2 only for Category III banking
institutions), or elects to use the advanced approaches rule (an opt-in institution), and must begin
reporting data on the remaining schedules (except for Category III banking institutions) of the
FFIEC 101 at the end of the first quarter in which they have begun their parallel run period.
The report due dates are 60 days following the end of a quarter while a respondent is in
its parallel run period. After completing its parallel run period, the report due dates are the same
as the report due dates currently required of respondents when filing their respective Call Report
or FR Y-9C13. SMBs must submit the FFIEC 101 to the appropriate Federal Reserve Bank within
thirty calendar days following the as-of date; a five-day extension may be given to banks with
more than one foreign office. BHCs, SLHCs, and IHCs must submit the FFIEC 101 to the
appropriate Federal Reserve Bank within forty calendar days after the March 31, June 30, and
September 30 as of dates unless that day falls on a weekend or holiday (received on the first
business day after the Saturday, Sunday, or holiday) and within forty-five calendars days after
the December 31 as of date.
In general, a reporting entity should maintain in its files a signed and attested record of its
completed FFIEC 101 report, including any amended reports, and the related work papers and
supporting documentation for five years after the report date, unless there are applicable state
requirements that mandate a longer retention time.
13

Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB
Number 7100-0036) and the Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB Number
7100-0128).

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Public Availability of Data
For report dates before a reporting institution has completed its parallel run period,
Schedule A will be available to the public, except for items 78 (total eligible credit reserves
calculated under the advanced approaches rules), 79 (amount of eligible credit reserves
includable in tier 2 capital), 86 (expected credit loss that exceeds eligible credit reserves);
87 (advanced approaches risk-weighted assets), 88 (common equity tier 1 capital ratio calculated
using the advanced approaches), 89 (additional tier 1 capital ratio calculated using the advanced
approaches), and 90 (total capital ratio using the advanced approaches). Information reported in
all other schedules of the FFIEC 101 are confidential. For report dates after a reporting
institution has completed its parallel run period, all items reported in Schedules A and B (except
for Schedule B, items 31.a and 31.b, column D) and items 1 and 2 of Schedule S are available to
the public. All other items reported in the FFIEC 101 are confidential. Note that for both before
and after an institution has completed its parallel run period, all items reported on Schedule A,
SLR Tables 1 and 2, are available to the public.
Individual respondent data, excluding confidential information, are available on the
National Information Center public website.
Legal Status
The Board is authorized to collect the information on the FFIEC 101 report from SMBs
pursuant to section 9(6) of the Federal Reserve Act (12 U.S.C. § 324), from BHCs pursuant to
section 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. § 1844(c)(1)(a)),
from SLHCs pursuant to section 10 of the Home Owners’ Loan Act (12 U.S.C. § 1467a(b)(2)),
and from IHCs pursuant to section 5(c) of the BHC Act (12 U.S.C. § 1844(c)(1)(A)), as well as
pursuant to sections 102(a)(1) and 165 of the Dodd-Frank Wall Street and Consumer Protection
Act (Dodd-Frank Act) (12 U.S.C. §§ 5311(a)(1) and 5365),14 and sections 8(a) and 13(a) of the
International Banking Act of 1978 (12 U.S.C. §§ 3106(a) and 3108(a)). The quarterly FFIEC 101
report is mandatory for reporting institutions.
For report dates before a reporting institution has completed its parallel run period,
Schedule A, except for items 78, 79, and 86-90, is released to the public. Items 78, 79, and 86-90
on Schedule A and all of the information reported in Schedules B through S are withheld as
confidential. For report dates after an institution has completed its parallel run period, all of the
data items in Schedules A and B, except for Schedule B, items 31.a and 31.b, column D, and data
items 1 and 2 of Schedule S are released to the public. Data items 31.a and 31.b, column D of
Section 165(b)(2) of Title I of the Dodd-Frank Act (12 U.S.C. § 5365(b)(2)), refers to “foreign-based bank
holding company.” Section 102(a)(1) of the Dodd-Frank Act (12 U.S.C. § 5311(a)(1)), defines “bank holding
company” for purposes of Title I of the Dodd-Frank Act to include foreign banking organizations that are treated as
bank holding companies under section 8(a) of the International Banking Act of 1978 (12 U.S.C. § 3106(a)). The
Board has required, pursuant to section 165(b)(1)(B)(iv) of the Dodd-Frank Act (12 U.S.C. § 5365(b)(1)(B)(iv)),
certain of the foreign banking organizations that are subject to section 165 of the Dodd-Frank Act to form U.S.
intermediate holding companies. Accordingly, the parent foreign-based organization of a U.S. IHC is treated as a
BHC for purposes of the BHC Act and section 165 of the Dodd-Frank Act. Because section 5(c) of the BHC Act
authorizes the Board to require reports from subsidiaries of BHCs, section 5(c) provides additional authority to
require U.S. IHCs to report the information contained in the FFIEC 101 report.
14

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Schedule B, and all of the data items in Schedules C through S, except for Schedule S, data items
1 and 2, continue to be withheld as confidential after the institution’s parallel run period is
completed.
Data items 78, 79, and 86-90 of Schedule A collect information on total eligible credit
reserves, risk weighted assets, tier one capital ratios and other data calculated using advanced
approaches. Schedule B contains summary information about risk-weighted assets and
aggregated information that underlie the calculation of risk-weight assets using advanced
approaches. Data items 1 and 2 of Schedule S reflect high-level information on an institution’s
total risk-based capital requirement for operational risk. During the parallel run period,
supervisors may request a banking organization amend its internal models, risk measurement,
and management infrastructure to implement calculations using advanced approaches. Public
disclosure of the above referenced data items before the parallel run period is completed could
lead investors, competitors, and the public to misjudge the financial health of the institutions,
when in fact there has been no change to their underlying fundamentals and, therefore, could
result in substantial competitive harm. Thus, data items 78, 79, and 86-90 of Schedule A, all of
Schedule B (except for data items 31.a and 31.b, column D), and data items 1 and 2 of Schedule
S only will be released to the public by the FFIEC for the reporting periods after the institution’s
parallel run period is completed.15 Before completion of the parallel run period, such information
may be withheld as confidential pursuant to exemption 4 of the Freedom of Information Act
(FOIA), which exempts from disclosure “trade secrets and commercial or financial information
obtained from a person and privileged or confidential” (5 U.S.C. § 552(b)(4)).
Data items 31.a and 31.b, column D of Schedule B, data items 3-24 of Schedule S, and all
of the data items in Schedules C through R. The data items found in these schedules contain
more detailed information than are included in the public schedules, including sensitive
information breaking down individual banking organization exposures to borrowers by
probability of default, exposures at default, and detailed information on the data used to model
operational risk capital. Disclosure of this information could result in substantial competitive
harm to the reporting institution, particularly because other financial institutions, which are not
required to publicly report such data, would competitively benefit from the public disclosure of
such detailed information by each reporting institution. Accordingly, these items are withheld as
confidential pursuant to exemption 4 of the FOIA after the parallel run period.
If a reporting institution believes that disclosing the data items designated for public
disclosure on the FFIEC 101 report is reasonably likely to result in substantial harm to its
competitive position, then consistent with exemption 4 of the FOIA, the respondent may request
confidential treatment for such information, which will be evaluated on a case-by-case basis.
Finally, the Board uses data from the FFIEC 101 to supplement on-site examination
processes. Therefore, this information can be kept confidential under exemption 8 of FOIA
(5 U.S.C. § 552(b)(8)), which specifically exempts from disclosure information “contained in or
Before determining an institution’s risk-based capital requirements, the institution must conduct a parallel run of
no less than four consecutive calendar quarters during which it complies with the qualification requirements in
12 CFR 217.122 to the Board’s satisfaction (12 CFR 217.121).
15

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related to examination, operating, or condition reports prepared by, on behalf of, or for the use of
an agency responsible for the regulation or supervision of financial institutions.”
Consultation Outside the Agency
The Board, FDIC, and OCC coordinated in developing these revisions.
Public Comments
On October 4, 2019, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (84 FR 53227) requesting public comment for 60 days on the
extension, with revision, of the FFIEC 101. The comment period for this notice expired on
December 3, 2019. The agencies received four comments in response to this notice.
Two commenters recommended that Category III institutions should not be required to
file the FFIEC 101. Such institutions are not required to calculate risk-weighted assets according
to the advanced approaches rule, but are subject to the SLR. Thus, the only portions of the
FFIEC 101 report applicable to Category III institutions are SLR Tables 1 and 2. However, one
commenter noted that depository institution subsidiaries of Category III institutions, which are
themselves considered Category III institutions, are not required to complete these two tables in
the FFIEC 101 and instead report specified SLR data only in Call Report Schedule RC-R, Part I.
In support of their recommendation to eliminate SLR data from the FFIEC 101, these
commenters asserted that holding companies that report detailed SLR information in the
FFIEC 101 report duplicate information in the Board’s FR Y-15.16 However, the instructions for
the FR Y-15 state that “[i]f the banking organization files the Regulatory Capital Reporting for
Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101) for the same
reporting period, then”12 data items in Schedule A of the FR Y-15 “will be populated
automatically” from the corresponding data items reported in FFIEC 101 SLR Table 2.
Furthermore, the FR Y-15 does not collect data comparable to the data reported in FFIEC 101
SLR Table 1, “Summary comparison of accounting assets and total leverage exposure.”
Both commenters also noted that Table 13 of the Pillar 3 disclosures requires certain
institutions to disclose the same SLR information as is reported in FFIEC 101 SLR Tables 1 and
2. These commenters also cited these Pillar 3 disclosures as a reason for eliminating the SLR
Tables from the FFIEC 101. However, the agencies’ capital rule provides that the management
of an institution required to make the Pillar 3 public disclosures may provide all of the required
disclosures in one place on its public website “or may provide the disclosures in more than one
public financial report or other regulatory reports,” provided the institution “publicly provides a
summary table specifically indicating the location(s) of all such disclosures.” Thus, an institution
could satisfy the Table 13 disclosure requirement through the use of FFIEC 101 SLR Tables 1
and 2, the location of which would be provided in the institution’s summary table.
Although the agencies recognize the existence of overlaps between the SLR information
in the FR Y-15, Table 13 of the Pillar 3 disclosures, and SLR Tables 1 and 2 of the FFIEC 101,
16

Banking Organization Systemic Risk Report (FR Y-15; OMB No. 7100-0352).

10

the latter serves, or can serve, as the source for some or all of the SLR information in the other
two. Therefore, the agencies do not agree with the comments that SLR Tables 1 and 2 in the
FFIEC 101 duplicate other available information and will retain these tables.
In addition, one commenter suggested that if the requirement to complete SLR Tables 1
and 2 is retained for top-tier Category III banking organizations, as proposed, “a change to Line
2.20 Tier 1 capital for Category III firms to account for Tier 1 capital calculation differences
would be appropriate.” On the FFIEC 101 reporting form, the caption for Item 2.20 currently
says, “Tier 1 capital (from Schedule A, item 45).” The agencies note that the existing instructions
for Item 2.20 already state that an institution “that does not complete Schedule A, except for the
SLR disclosures, must use the corresponding item as reported on the institution’s Schedule RC-R
of the Call Reports or Schedule HC-R of the FR Y-9C, as applicable.” Thus, the Item 2.20
instructions already address the commenter’s suggestion. However, the agencies will modify the
caption for Item 2.20 to clarify the source for the amount of Tier 1 capital to be reported in this
item.
The agencies did not receive comments specifically addressing their proposals to revise
the instructions for FFIEC 101 Schedule A, SLR Table 2, consistent with the SA-CCR final rule.
However, for purposes of reporting notional amounts of derivatives in the FFIEC 101,
one commenter recommended that the agencies determine whether the notional amount as
defined in U.S. GAAP17 or under the SA-CCR final rule should be used when an institution must
report the notional amount of derivative contracts in Schedule A, SLR Table 2. The agencies
believe that the SA-CCR notional amount should be reported in Schedule A, SLR Table 2 only
for those derivative contracts for which an institution uses SA-CCR to calculate their exposure
amounts when the institution determines its standardized total risk-weighted assets. For
derivative contracts for which an institution uses CEM to calculate exposure amounts, the
notional amounts to be reported should be based on the definition in U.S. GAAP. The agencies
will revise the instructions for Schedule A, SLR Table 2 in this manner.
On January 27, 2020, the agencies, under the auspices of the FFIEC, published a final
notice in the Federal Register (85 FR 4780).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FFIEC 101 is
46,060 hours, and would decrease to 35,276 hours with the proposed revisions, mostly due to the
decrease in the number of advanced approaches banking organizations resulting from the final
tailoring rule. These reporting requirements represent less than 1 percent of the Board’s total
paperwork burden.

17

See Accounting Standards Codification Section 815-10-20.

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Estimated
Estimated
Annual
number of
average hours
frequency
respondents18
per response

FFIEC 101
Current
SMBs
BHCs and SLHCs
IHCs

4
13
6

4
4
4

674
677
3

10,784
35,204
72
46,060

4
9

4
4

674
677

10,784
24,372

4
6

4
4

3
3

48
72
35,276

Current Total
Proposed
SMBs
BHCs and SLHCs
BHCs and SLHCs
(SLR Tables 1 and 2 only)
IHCs
Proposed Total

Estimated
annual burden
hours

Change

(10,784)

The current estimated total annual cost to the public for the FFIEC 101 is $2,653,056 and
would decrease to $2,031,898 with the proposed revisions.19
Sensitive Questions
This collection of information contains 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 this
information collection is $157,700 per year.

18

Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $600 million in total assets), https://www.sba.gov/document/support--table-size-standards.
19
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/.

12