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 Board, FDIC, and OCC
(the agencies) propose under the emergency clearance provisions of
OMB’s 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 Owners’ 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