The FFIEC 101 collects data regarding the levels and components of risk-based capital from firms subject to the Boardâs 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 Board, FDIC, and OCC (the agencies) propose under the emergency clearance provisions of OMBâs regulations to revise the FFIEC 101 effective beginning with the March 31, 2020, report date. The agencies are providing a summary of two interim final rules (IFRs) that impact the FFIEC 101 for the first quarter on a best effort basis in response to disruptions related to COVID-19. The current estimated total annual burden for the FFIEC 101 is 35,276 hours, and would not change with the proposed revision.
The agencies have determined that (1) the collection of information within the scope of this request is needed prior to the expiration of time periods established under 5 CFR 1320.10, (2) this collection of information is essential to the mission of the agencies, and (3) the agencies cannot reasonably comply with the normal clearance procedures because an unanticipated event has occurred and the use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of information.
Recent events have suddenly and significantly impacted financial markets. The spread of the coronavirus disease 2019 has disrupted economic activity in many countries. In addition, financial markets have experienced significant volatility. The magnitude and persistence of the overall effects on the economy remain highly uncertain. In light of these developments, banking organizations may realize a sudden, unanticipated drop in capital ratios and liquidity. This could create a strong incentive for these banking organizations to limit their lending and other financial intermediation activities in order to avoid facing abrupt regulatory capital and liquidity limitations.
US Code:
12 USC 1844(c)(1)(a)
Name of Law: Bank Holding Company Act of 1956
US Code:
12 USC 1467a(b)(2)
Name of Law: Home Ownersâ Loan Act
US Code:
12 USC 1844(c)(1)(A)
Name of Law: Bank Holding Company Act of 1956
US Code:
12 USC 5311(a)(1)
Name of Law: Dodd-Frank Wall Street and Consumer Protection Act
US Code:
12 USC 5365
Name of Law: Dodd-Frank Wall Street and Consumer Protection Act
US Code:
12 USC 324
Name of Law: Federal Reserve Act
US Code:
12 USC 3106(a)
Name of Law: International Banking Act of 1978
US Code:
12 USC 3108(a)
Name of Law: International Banking Act of 1978
PL: Pub.L. 116 - 136 134 Stat. 281 Name of Law: Coronavirus Aid, Relief, and Economic Security Act
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Form FFIEC 101 SMBs
FFIEC101_20200402_18_question_omb_emergency.pdf
SMBs