FFIEC101_20200402_omb_emergency

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 revise 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) under the
emergency clearance provisions of OMB’s regulations. 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 Federal Deposit Insurance Corporation (FDIC) and the Office of the Comptroller
of the Currency (OCC) have also submitted a similar request for OMB review to request this
information from banks under their supervision.
The Board, FDIC, and OCC (the agencies) propose to revise the FFIEC 101 effective for
the March 31, 2020, report date. The agencies are providing a summary of two interim final rules
(IFRs) that impact the FFIEC 101. The current estimated total annual burden for the FFIEC 101
is 35,276 hours, and would not change with the proposed revision. The forms 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
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
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
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.

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 III 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.
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 off-

2

balance 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.
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.2 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
2

Unlike the wholesale credit exposure reporting schedules, the PD ranges for retail exposures differ from subportfolio to sub-portfolio.

3

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. 3
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.
Proposed Revisions
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
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
3

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.

4

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.
In late March, the agencies issued two IFRs to make changes to their regulatory capital
and liquidity rules to facilitate banking organizations’ use of the Board’s emergency facilities
and to support prudent lending. The IFRs, listed below, are applicable to the FFIEC 101. The
IFRs were issued with immediate effective date. As stated in the Federal Register notice, the
agencies believe that, in light of current market uncertainty, the public interest is best served by
implementing the IFR as soon as possible. The agencies request emergency clearance from OMB
to permit the revisions for the March 31, 2020, FFIEC 101.
Money Market Mutual Fund Liquidity Facility (MMLF) – Interim Final Rule
To enhance the liquidity and functioning of money markets, the Federal Reserve Bank of
Boston launched the Money Market Mutual Fund Liquidity Facility (MMLF) on March 18,
2020. On March 23, 2020, the agencies published an interim final rule,4 which permits banking
organizations to exclude from regulatory capital requirements exposures related to the MMLF.
The interim final rule modifies the agencies’ capital rule to allow banking organizations
to neutralize the effects of purchasing assets through the MMLF on their risk-based and leverage
capital ratios. This treatment extends to the community bank leverage ratio. Specifically, a
banking organization may exclude from its total leverage exposure, average total consolidated
assets, standardized total risk-weighted assets, and advanced approaches total risk-weighted
assets, as applicable, any exposure acquired pursuant to a non-recourse loan from the MMLF.
The interim final rule only applies to activities with the MMLF. The facility is scheduled to
terminate on September 30, 2020, unless the facility is extended by the Federal Reserve Board.
Reporting Revisions
Starting with the March 31, 2020 reporting period, advanced approaches banking
organizations should not include assets purchased from the MMLF in “total risk-weighted assets
(RWAs)” reported in the FFIEC 101, Schedule A, item 60. A banking organization, even if it is
not a custodial banking organization, should include assets purchased from the MMLF in the
FFIEC 101, Schedule A, SLR Table 1, item 1.7.c, “Adjustments for deductions of qualifying
central bank deposits for custodial banking organizations.” Also for banking organizations
subject to the supplementary leverage ratio requirement, assets purchased from the MMLF
would receive similar treatment as under the “leverage ratio” and should be reported in the
4

FR 16232 (March 23, 2020).

5

FFIEC 101, Schedule A, SLR Table 2, item 2.2.b, “Deductions of qualifying central bank
deposits from total on-balance sheet exposures for custodial banking organizations,” even if a
banking organization is not a custodial banking organization.
Current Expected Credit Losses Revised Transition - Interim Final Rule
The interim final rule,5 published on March 31, 2020, delays the estimated impact on
regulatory capital stemming from the implementation of Accounting Standards Update No.
2016-13, Financial Instruments - Credit Losses, Topic 326, Measurement of Credit Losses on
Financial Instruments (CECL). The interim final rule provides banking organizations that
implement CECL before the end of 2020 the option to delay for two years an estimate of
CECL’s effect on regulatory capital, relative to the incurred loss methodology’s effect on
regulatory capital, followed by a three-year transition period. The agencies are providing this
relief to allow such banking organizations to better focus on supporting lending to creditworthy
households and businesses in light of market disruptions as a result of COVID-19, while also
maintaining the quality of regulatory capital.
Reporting Revisions
The interim final rule on Current Expected Credit Losses Regulatory Capital Transition
would revise the following items on the FFIEC 101, Schedule A: Item 2 (Retained earnings),
Item 21 (Temporary difference deferred tax assets (DTAs)), Item 50 (Eligible credit reserves in
Tier 2 capital), and Supplementary Leverage Ratio Table 1, Item 1.8 (Total Leverage Exposure).
Institutions that elect the 2020 CECL transition approach would calculate the following
amounts, as applicable.
AACL refers to the Adjusted Allowances for Credit Losses, as defined in 12 CFR 3.2
(OCC); 12 CFR 217.2 (Board); or 12 CFR 324.2 (FDIC):
CECL Transitional Amount means the decrease in the amount of an institution’s retained
earnings as of the beginning of the fiscal year in which the institution adopts CECL from the
amount of the institution’s retained earnings as of the closing of the fiscal year-end immediately
prior to the institution’s adoption of CECL.
DTA Transitional Amount means the increase in the amount of an institution’s DTAs
arising from temporary differences as of the beginning of the fiscal year in which the institution
adopts CECL from the amount of the institution’s DTAs arising from temporary differences as of
the closing of the fiscal year-end immediately prior to the institution’s adoption of CECL.
AACL Transitional Amount means the difference in the amount of an institution’s AACL
as of the beginning of the fiscal year in which the institution adopts CECL and the amount of the
institution’s ALLL as of the closing of the fiscal year-end immediately prior to the institution’s
adoption of CECL.

5

85 FR 17723 (March 31, 2020).

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Eligible Credit Reserves Transitional Amount (for advanced approaches institutions
filing FFIEC 101 only) means the increase in the amount of an institution’s eligible credit
reserves as of the beginning of the fiscal year in which the institution adopts CECL from the
amount of the institution’s eligible credit reserves as of the closing of the fiscal year-end
immediately prior to the institution’s adoption of CECL.
Modified CECL Transitional Amount means A) during the first two years of the
transition period, the difference between AACL as reported in the most recent Call Report (or
FR Y-9C), and the AACL as of the beginning of the fiscal year in which the institution adopts
CECL, multiplied by 0.25, plus the CECL transitional amount, and B) during the last three years
of the transition period, the difference between AACL as reported in the Call Report at the end of
the second year of the transition period and the AACL as of the beginning of the fiscal year in
which the institution adopts CECL, multiplied by 0.25, plus the CECL transitional amount.
Modified AACL Transitional Amount means A) during the first two years of the
transition period, the difference between AACL as reported in the most recent Call Report (or
FR Y-9C), and the AACL as of the beginning of the fiscal year in which the institution adopts
CECL, multiplied by 0.25, plus the AACL transitional amount, and B) during the last three years
of the transition period, the difference between AACL as reported in the Call Report at the end of
the second year of the transition period and the AACL as of the beginning of the fiscal year in
which the institution adopts CECL, multiplied by 0.25, plus the AACL transitional amount.
Adjustments to the FFIEC 101
Schedule A
Item 2 – Retained Earnings: An institution that has elected to apply the 2020 CECL
Transition provision would add the Modified CECL Transitional Amount, as defined in section
301 of the regulatory capital rules, when calculating this item, adjusted as follows: 100% in
Years 1 and 2 of the transition period; 75% in Year 3 of the transition period; 50% in Year 4 of
the transition period; and 25% in Year 5 of the transition period.
Item 21 - DTAs arising from temporary differences: An institution that has elected to
apply the 2020 CECL transition would subtract the DTA Transitional Amount, as defined in
section 301 of the regulatory capital rules, from the amount of DTAs from temporary differences
used in the calculation of this item, adjusted as follows: 100% in Years 1 and 2 of the transition
period; 75% in Year 3 of the transition period; 50% in Year 4 of the transition period; and 25%
in Year 5 of the transition period.
Item 50 – Eligible credit reserves includable in Tier 2 capital. An institution that has
elected to apply the 2020 CECL transition would subtract Eligible Credit Reserves Transitional
Amount, as defined in section 301 of the regulatory capital rules, when calculating this item,
adjusted as follows: 100% in Years 1 and 2 of the transition period; 75% in Year 3 of the
transition period; 50% in Year 4 of the transition period; and 25% in Year 5 of the transition
period.

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Supplementary Leverage Ratio Table 1
Item 1.8 – Total leverage exposure: An institution that has elected to apply the 2020
CECL Transition would add the Modified CECL Transitional Amount, as defined in section 301
of the regulatory capital rules, when calculating this item, adjusted as follows: 100% in Years 1
and 2 of the transition period; 75% in Year 3 of the transition period; 50% in Year 4 of the
transition period; and 25% in Year 5 of the transition period.
Time Schedule for Information Collection and Publication
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-9C6. 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.
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
6

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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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),7 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
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
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.
7

9

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.8 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
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. The agencies will
follow this request for emergency processing with a request under normal clearance procedures,
during which comments will be solicited for the typical 60-day and 30-day periods. All
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).
8

10

comments received on paperwork burden, whether during the 60-day or 30-day comment
periods, will be considered in finalizing the collection.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FFIEC 101 is
35,276, and would remain unchanged with the proposed revisions. These reporting requirements
represent less than 1 percent of the Board’s total paperwork burden.
Estimated
number of
respondents9
4
9

FFIEC 101
SMBs
BHCs and SLHCs
BHCs and SLHCs
(SLR Tables 1 and 2 only)
IHCs

4
6

Estimated
Annual
average hours
frequency
per response
4
674
4
677
4
4

Total

3
3

Estimated
annual burden
hours
10,784
24,372
48
72
35,276

The estimated total annual cost to the public for the FFIEC 101 is $2,031,898.10
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.

9

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.
10
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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