FRY9_20200405_omb

Supporting Statement for the
Financial Statements for Holding Companies
FR Y-9; OMB No. 7100-0128
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 Financial Statements for Holding Companies (FR Y-9; OMB No. 7100-0128). This
information collection comprises the following five reports:
 Consolidated Financial Statements for Holding Companies (FR Y-9C),
 Parent Company Only Financial Statements for Large Holding Companies (FR Y-9LP),
 Parent Company Only Financial Statements for Small Holding Companies (FR Y-9SP),
 Financial Statements for Employee Stock Ownership Plan Holding Companies
(FR Y-9ES), and
 Supplement to the Consolidated Financial Statements for Holding Companies
(FR Y-9CS).
The Board requires bank holding companies (BHCs), most savings and loan holding
companies (SLHCs),1 securities holding companies, and U.S. intermediate holding companies
(IHCs) (collectively HCs) to provide standardized financial statements through one or more of
the FR Y-9 reports. The information collected on the FR Y-9 reports is necessary for the Board
to identify emerging financial risks and monitor the safety and soundness of HC operations.
The Board revised the FR Y-9C to implement various changes to the Board’s capital rule
that the Board has recently finalized. Each of the revisions to the FR Y-9C would take effect the
same quarter as the effective date of the relevant associated revision to the Board’s capital rule.
The Board also revised the instructions for the reporting of operating leases on the FR Y-9C that
would take effect March 31, 2020, as well as FR Y-9C changes for reporting home equity lines
of credit that would take effect March 30, 2020, and March 31, 2021. Finally, the Board revised
the FR Y-9CS to clarify that response to the report is voluntary.
The current estimated total annual burden for the FR Y-9 reports is 124,000 hours, and
would decrease to 119,667 hours. The revisions would result in a decrease of 4,333 hours. The
forms and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/default.aspx.”
Background and Justification
The FR Y-9 reports are the Board’s primary source of financial data on HCs. Federal
Reserve System examiners rely on the FR Y-9 reports to supervise financial institutions between
on-site inspections. The Board uses the collected data to detect emerging financial problems,
1

An SLHC must file one or more of the FR Y-9 family of reports unless it is (1) a grandfathered unitary SLHC with
primarily commercial assets and thrifts that make up less than 5 percent of its consolidated assets or (2) an SLHC
that primarily holds insurance-related assets and does not otherwise submit financial reports with the U.S. Securities
and Exchange Commission pursuant to section 13 or 15(d) of the Securities Exchange Act of 1934.

conduct pre-inspection analysis, monitor and evaluate capital adequacy, evaluate mergers and
acquisitions, and analyze an HC’s overall financial condition to monitor the safety and soundness
of its operations. The information collected by the FR Y-9 reports is not available from other
sources.
Description of Information Collection
The FR Y-9C consists of standardized financial statements similar to the Call Reports
filed by commercial banks.2 The FR Y-9C collects consolidated data from HCs and is filed
quarterly by top-tier HCs with total consolidated assets of $3 billion or more.3
The FR Y-9LP, which collects parent company only financial data, must be submitted by
each HC that files the FR Y-9C, as well as by each of its subsidiary HCs.4 The report consists of
standardized financial statements.
The FR Y-9SP is a parent company only financial statement filed semiannually by HCs
with total consolidated assets of less than $3 billion. In a banking organization with total
consolidated assets of less than $3 billion that has tiered HCs, each HC in the organization must
submit, or have the top-tier HC submit on its behalf, a separate FR Y-9SP. This report collects
basic balance sheet and income data for the parent company, as well as data on its intangible
assets and intercompany transactions.
The FR Y-9ES is filed annually by each employee stock ownership plan (ESOP) that is
also an HC. The report collects financial data on the ESOP’s benefit plan activities. The
FR Y-9ES consists of four schedules: a Statement of Changes in Net Assets Available for
Benefits, a Statement of Net Assets Available for Benefits, Memoranda, and Notes to the
Financial Statements.
The instructions to each of the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES state that
respondent HCs should retain workpapers and other records used in the preparation of the
reports.
The FR Y-9CS is a voluntary, free-form supplemental report that the Board may utilize to
collect critical additional data from HCs deemed to be needed in an expedited manner.5 The
2

The Call Reports (OMB No. 7100-0036) consist of the Consolidated Reports of Condition and Income for a Bank
with Domestic Offices Only and Total Assets Less than $5 Billion (FFIEC 051), Consolidated Reports of Condition
and Income for a Bank with Domestic Offices Only (FFIEC 041), and Consolidated Reports of Condition and
Income for a Bank with Domestic and Foreign Offices (FFIEC 031).
3
Under certain circumstances described in the FR Y-9C’s General Instructions, HCs with assets under $3 billion
may be required to file the FR Y-9C.
4
A top-tier HC may submit a separate FR Y-9LP on behalf of each of its lower-tier HCs.
5
Certain criteria apply to information collections conducted via the Board’s ad hoc clearance process. Such
information collections shall (1) be vetted by the Board’s clearance officer as well as the Division director
responsible for the information collection, (2) display the OMB control number and respondents shall be informed
that the information collection has been approved, (3) be used only in such cases where response is voluntary,
(4) not be used to substantially inform regulatory actions or policy decisions, (5) be conducted only and exactly as
described in the OMB submission, (6) involve only noncontroversial subject matter that will not raise concerns for

2

FR Y-9CS data collections are used to assess and monitor emerging issues related to HCs, and
the report is intended to supplement the other FR Y-9 reports. The data requested by the
FR Y-9CS would depend on the Board’s data needs in any given situation. For example, changes
made by the Financial Accounting Standards Board (FASB) may introduce into U.S. generally
accepted accounting principles (U.S. GAAP) new data items that are not currently collected by
the other FR Y-9 reports. The Board could use the FR Y-9CS report to collect these data until the
items are implemented into the other FR Y-9 reports.6
Respondent Panel
The FR Y-9 reports panel is comprised of HCs. Specifically, the FR Y-9C panel consists
of top-tier HCs with total consolidated assets of $3 billion or more; FR Y-9LP panel consists of
each HC that files the FR Y-9C, as well as by each of its subsidiary HCs; FR Y-9SP panel
consists of HCs with total consolidated assets of less than $3 billion; FR Y-9ES panel consists of
each employee stock ownership plan (ESOP) that is also an HC; and FR Y-9CS panel consists of
any HC the Board selects.
Adopted Revisions to the FR Y-9C
Simplifications Rule
The Board revised the FR Y-9C to implement the Board’s final rule to simplify certain
aspects of the capital rule (simplifications rule), which made a number of changes to the
calculation of common equity tier 1 (CET1) capital, additional tier 1 capital, and tier 2 capital for
non-advanced approaches holding companies that do not apply to advanced approaches
institutions.7, 8 The simplifications rule results in different calculations for these tiers of
regulatory capital for non-advanced approaches holding companies and advanced approaches
HCs. To reflect the effects of the simplifications rule for non-advanced approaches HCs, the
Board revised the FR Y-9C to adjust the existing regulatory capital calculations reported on
Schedule HC-R, Part I. Although the report would include two sets of calculations (for nonadvanced approaches HCs and advanced approaches HCs), a HC would complete only the set
applicable to that holding company.

other Federal agencies, (7) include information collection instruments that are each conducted only one time,
(8) include a detailed justification of the effective and efficient statistical survey methodology (if applicable), and
(9) collect personally identifiable information (PII) only to the extent necessary (if collecting PII, the form must
display current privacy act notice). In addition, for each information collection instrument, respondent burden will
be tracked and submitted to OMB.
6
The FR Y-9CS was most recently used by the Board on June 30, 2008. In that collection, data were requested from
banking organizations implementing an Advanced Measurement Approach to calculate operational risk capital
under the Basel II Risk-Based Capital Framework. The report was used to conduct a voluntary Loss Data Collection
Exercise (LDCE) relating to operational risk.
7
In general, an advanced approaches HC, as defined in the Board’s Regulation Q, has consolidated total assets of
$250 billion or more, has consolidated total on-balance sheet foreign exposure of $10 billion or more, has a
subsidiary depository institution that uses the advanced approaches to calculate its total risk-weighted assets, or
elects to use the advanced approaches to calculate its total risk-weighted assets. See 12 CFR 217.100.
8
84 FR 35234 (July 22, 2019).

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The simplifications rule provides for certain amendments to the capital rule, associated
with the proposed reporting revisions to the FR Y-9C, with an effective date of April 1, 2020. On
October 29, 2019, the Board issued a final rule that permits non-advanced approaches banking
organizations to implement the simplifications rule on January 1, 2020.9 As a result, nonadvanced approaches HCs have the option to implement the simplifications rule on the revised
effective date of January 1, 2020, or wait until the quarter beginning April 1, 2020. The Board
revised Schedule HC-R, Regulatory Capital, to implement the associated changes to the capital
rule effective as of the March 31, 2020, report date, consistent with the simplifications rule’s
optional effective date.
Additionally, the Board adopted a simplified capital calculations methodology on
Schedule HC-R, Part I and Part II, and thereby reduced burden. As previously mentioned, the
FR Y-9C would include two sets of calculations (one that incorporates the effects of the
simplifications rule and another that does not); therefore, a holding company would only
complete the column for the set of calculations applicable to that holding company. For the
March 31, 2020, report date, non-advanced approaches HCs that elect to adopt the
simplifications rule on January 1, 2020, would complete the column for the set of calculations
that incorporates the effects of the simplifications rule. Non-advanced approaches HCs that elect
to wait to adopt the simplifications rules on April 1, 2020, and all advanced approaches holding
companies would complete the column for the set of calculations that does not reflect the effects
of this rule (i.e., that reflects the capital calculation in effect for all holding companies before this
revision). Beginning with the June 30, 2020, report date, all non-advanced approaches holding
companies would complete the column for the set of calculations that incorporates the effects of
the simplifications rule. The advanced approaches holding companies would complete the
column that does not reflect the effects of the simplifications rule.
Currently, the regulatory capital calculations in FR Y-9C Schedule HC-R require that a
holding company’s capital cannot include mortgage servicing assets (MSAs), certain temporary
difference deferred tax assets (DTAs), and significant investments in the common stock of
unconsolidated financial institutions in an amount greater than 10 percent of CET1 capital, on an
individual basis, and that those three data items combined cannot comprise more than 15 percent
of CET1 capital. Under the simplifications rule, the Board increased the threshold for MSAs,
DTAs that could not be realized through net operating loss carrybacks (temporary difference
DTAs),10 and investments in the capital of unconsolidated financial institutions for non-advanced
approaches HCs. The Board revised Schedule HC-R to permit non-advanced approaches HCs to
include as capital MSAs and temporary difference DTAs up to 25 percent of CET1 capital, on an
individual basis. The 15 percent aggregate limit would be removed. In addition, the Board
revised the capital calculation for minority interest included in the various capital categories for
non-advanced approaches HCs and the calculation of the capital conservation buffer.
The simplifications rule also combined the current three categories of investments in
financial institutions (non-significant investments in the capital of unconsolidated financial
9

84 FR 61804 (November 13, 2019).
The Board notes that the Tax Cuts and Jobs Act, Pub. L. No. 115-97, 131 Stat. 2054 (2017), eliminated the
concept of net operating loss carrybacks for U.S. federal income tax purposes, although the concept may still exist in
particular jurisdictions for state or foreign income tax purposes.
10

4

institutions, significant investments in the capital of unconsolidated financial institutions that are
in the form of common stock, and significant investments in the capital of unconsolidated
financial institutions that are not in the form of common stock) into a single category,
investments in the capital of unconsolidated financial institutions, and will apply a limit of 25
percent of CET1 capital on the amount of these investments that can be included in capital. Any
investments in excess of the 25 percent limit would be deducted from capital using the
corresponding deduction approach.11 The Board revised the FR Y-9C to implement this change.
Consistent with the current capital rule, a holding company must risk weight MSAs,
temporary difference DTAs, and investments in the capital of unconsolidated financial
institutions that are not deducted. As a result of the simplifications rule, non-advanced
approaches banking organizations will not be required to differentiate among categories of
investments in the capital of unconsolidated financial institutions. The risk weight for such
equity exposures generally will be 100 percent, provided the exposures qualify for this risk
weight.12 For non-advanced approaches banking organizations, the simplifications rule
eliminates the exclusion of significant investments in the capital of unconsolidated financial
institutions in the form of common stock from being eligible for a 100 percent risk weight.13 The
application of the 100 percent risk weight (1) requires a banking organization to follow an
enumerated process for calculating adjusted carrying value and (2) mandates the inclusion of
equity exposures to determine whether the threshold has been reached. Equity exposures that do
not qualify for a preferential risk weight will generally receive risk weights of either 300 percent
or 400 percent, depending on whether the equity exposures are publicly traded.14 The Board
revised the FR Y-9C to implement this change, as discussed below.
In order to implement these regulatory capital changes, a number of revisions were made
to Schedule HC-R, Part I, for non-advanced approaches HCs. Specifically, the Board created two
columns for existing items 11 through 19 on the FR Y-9C. Column A would be reported by
non-advanced approaches HCs that elect to adopt the simplifications rule on January 1, 2020, in
the March 31, 2020, FR Y-9C report and by all non-advanced approaches HCs beginning in the
June 30, 2020, FR Y-9C report using the definitions under the simplifications rule. Column A
would not include items 11 or 16, and items 13 through 15 would be designated as items 13.a,
column A through item 15.a, column A to reflect the new calculation methodology. Column B
would be reported by advanced approaches HCs and by non-advanced approaches HCs that elect
to wait to adopt the simplifications rule on April 1, 2020, in the March 31, 2020, FR Y-9C report
and only by advanced approaches HCs beginning in the June 30, 2020, FR Y-9C report using the

11

84 FR 35234 (July 22, 2019).
Note that for purposes of calculating the 10 percent nonsignificant equity bucket, the capital rule excludes equity
exposures that are assigned a risk weight of zero percent or 20 percent and community development equity
exposures and the effective portion of hedge pairs, both of which are assigned a 100 percent risk weight. In addition,
the 10 percent non-significant bucket excludes equity exposures to an investment firm that would not meet the
definition of traditional securitization were it not for the application of criterion 8 of the definition of traditional
securitization, and has greater than immaterial leverage.
13
Equity exposures that exceed, in the aggregate, 10 percent of a non-advanced approaches banking organization’s
total capital would then be assigned a risk weight based upon the approaches available in sections 52 and 53 of the
capital rule. 12 CFR 217.52 and .53.
14
See footnote 11.
12

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existing definitions. Existing items 13 through 15 would be designated as items 13.b, column B
through item 15.b, column B to reflect continued use of the existing calculation methodology.
With respect to the revisions related to the capital calculation for minority interests, the
Board modified the FR Y-9C instructions to reflect the ability of non-advanced approaches HCs
to use the revised method under the simplifications rule to calculate minority interest in existing
items 4, 22, and 39 (CET1, additional tier 1, and tier 2 minority interest, respectively).
In addition, as a result of certain changes made by the capital simplifications rule, the
Board clarified when a holding company must report the amount of distributions and
discretionary bonus payments in Schedule HC-R, Part I, item 48 (which would be renumbered as
item 52). The Board clarified the instructions for renumbered item 52 to explain that an
institution must report the amount of distributions and discretionary bonus payments made
during the calendar quarter ending on the report date if the amount of its capital conservation
buffer that it reported for the previous calendar quarter-end report date was less than its
applicable required buffer percentage on that previous calendar quarter-end report date. This
change will enhance the Board’s ability to monitor compliance with the limitations on
distributions and discretionary bonus payments. Holding companies must comply with this
instructional clarification beginning with the March 31, 2020, report date.
Community Bank Leverage Ratio
The Board revised the FR Y-9C to implement a simplified alternative measure of capital
adequacy, the community bank leverage ratio (CBLR), for qualifying HCs with less than $10
billion in total consolidated assets. The revisions would align the FR Y-9C with the CBLR final
rule,15 which implemented section 201 of the Economic Growth, Regulatory Relief, and
Consumer Protection Act (EGRRCPA).16 The revisions to the FR Y-9C would become effective
for the March 31, 2020, report date, the first report date in respect of which a HC could elect to
opt into the framework established by the community leverage bank ratio final rule (CBLR
framework).
Under the CBLR final rule, HCs that have less than $10 billion in total consolidated
assets, meet risk-based qualifying criteria, and have a leverage ratio of greater than 9 percent
would be eligible to opt into the CBLR framework. A HC that opts into the CBLR framework,
maintains a leverage ratio of greater than 9 percent, and continues to meet the other qualifying
criteria will be considered to have satisfied the generally applicable risk-based and leverage
capital requirements and any other capital or leverage requirements to which it is subject.17
Under the CBLR final rule, a holding company that opts into the CBLR framework
(CBLR HC) may opt out of the CBLR framework at any time, without restriction, by reverting to
the generally applicable capital requirements in the Board’s capital rule and reporting its
regulatory capital information in the FR Y-9C Schedule HC-R, “Regulatory Capital,” Parts I and
II, at the time of opting out.
15

84 FR 61776 (November 13, 2019).
See Pub. L. No. 115-174, 132 Stat. 1296 (2018).
17
See footnote 15.
16

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As described in the CBLR final rule, a CBLR HC that no longer meets the qualifying
criteria for the CBLR framework will be required within two consecutive calendar quarters
(grace period) either to satisfy once again the qualifying criteria or demonstrate compliance with
the generally applicable capital requirements. During the grace period, the HC would continue to
be treated as a CBLR HC and would be required to report its leverage ratio and related
components in FR Y-9C Schedule HC-R, Part I.18 A CBLR HC that ceases to meet the
qualifying criteria as a result of a business combination (e.g., a merger) will receive no grace
period, and will immediately become subject to the generally applicable capital requirements.
Similarly, a CBLR HC that fails to maintain a leverage ratio greater than 8 percent would not be
permitted to use the grace period and would immediately become subject to the generally
applicable capital requirements.19
The Board incorporated revisions related to the CBLR framework into Schedule HC-R,
Part I. As provided in the CBLR final rule, the numerator of the community bank leverage ratio
will be tier 1 capital, which is currently reported on Schedule HC-R, Part I, item 26. Therefore,
the Board did not propose any changes related to the numerator of the CBLR.
As provided in the planned CBLR final rule, the denominator of the community bank
leverage ratio will be average total consolidated assets. Specifically, average total consolidated
assets would be calculated in accordance with the existing reporting instructions for Schedule
HC-R, Part I, items 36 through 39. The Board did not propose any substantive changes related to
the denominator of the community bank leverage ratio. However, the Board moved existing
items 36 through 39 of Schedule HC-R, Part I, and renumbered them as items 27 through 30 of
Schedule HC-R, Part I, to consolidate all of the CBLR-related capital items earlier in Schedule
HC-R, Part I.
As provided in the CBLR final rule, an HC will calculate its community bank leverage
ratio by dividing tier 1 capital by average total consolidated assets (as adjusted), and the
community bank leverage ratio would be reported as a percentage, rounded to four decimal
places. Since this calculation is essentially identical to the existing calculation of the tier 1
leverage ratio in Schedule HC-R, Part I, item 44, the Board did not propose a separate item for
the community bank leverage ratio in Schedule HC-R, Part I. Instead, the Board revised the
FR Y-9C to move the tier 1 leverage ratio from item 44 of Part I and renumber it as item 31, and
rename the item to the Leverage Ratio, as this ratio would apply to all HCs (as the community
bank leverage ratio for qualifying HCs or the tier 1 Leverage Ratio for all other HCs).
As provided in the CBLR final rule, a CBLR bank will need to satisfy certain qualifying
criteria in order to be eligible to opt into the CBLR framework. The new items identified below
would collect information necessary to ensure that a HC continuously meets the qualifying
18

For example, if the CBLR HC no longer meets one of the qualifying criteria as of February 15, and still does not
meet the criteria as of the end of that quarter, the grace period for such an HC will begin as of the end of the quarter
ending March 31. The banking organization may continue to use the CBLR framework as of June 30, but will need
to comply fully with the generally applicable rule (including the associated reporting requirements) as of
September 30, unless the HC once again meets all qualifying criteria of the CBLR framework, including a leverage
ratio of greater than 9 percent, by that date.
19
84 FR 61776 (November 13, 2019).

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criteria for using the CBLR framework. The Board added a “yes/no” checkbox (item 31.a.) on
Schedule HC-R, Part I, after item 31, “Leverage ratio,” where each HC would report whether or
not it has a CBLR framework election in effect as of the quarter-end report date.
Qualifying Criteria for Using the CBLR Framework
A HC would need to satisfy certain qualifying criteria to be eligible to opt into the CBLR
framework. The items below would collect the information necessary to ensure that an HC
continuously meets the qualifying criteria for using the CBLR framework. Specifically, a
qualifying HC must not be an advanced approaches (AA) HC and must meet the following
criteria:
 A leverage ratio of greater than 9 percent,
 Total consolidated assets of less than $10 billion,
 Total trading assets and trading liabilities of 5 percent or less of total consolidated assets,
and
 Total off-balance sheet exposures (excluding derivatives other than sold credit derivatives
and unconditionally cancelable commitments) of 25 percent or less of total consolidated
assets.20





Accordingly, the Board will collect the items described below from CBLR HCs only:
In item 32 of Schedule HC-R, Part I, a CBLR HC will report total assets, as reported in
Schedule HC, item 12.
In item 33, a CBLR HC will report the sum of trading assets from Schedule HC, item 5,
and trading liabilities from Schedule HC, item 15, in Column A. The HC will also report
that sum divided by total assets from Schedule HC, item 12, and expressed as a
percentage in Column B. As provided in the CBLR final rule, trading assets and trading
liabilities will be added together, not netted, for purposes of this calculation. Also as
discussed in the CBLR final rule, a HC will not meet the definition of a qualifying
community banking organization for purposes of the CBLR framework if the percentage
reported in Column B is greater than 5 percent.
In items 34.a through 34.d, a CBLR HC will report information related to commitments,
other off-balance sheet exposures, and sold credit derivatives.
o In item 34.a, a CBLR HC will report the unused portion of conditionally
cancellable commitments. This amount will be the amount of all unused
commitments less the amount of unconditionally cancellable commitments, as
discussed in the CBLR final rule and defined in the agencies’ capital rule.21 This
item will be calculated consistent with the sum of Schedule HC-R, Part II, items
18.a and 18.b, Column A.
o In item 34.b, a CBLR HC will report total securities lent and borrowed, which
will be the sum of Schedule HC-L, items 6.a and 6.b.
o In item 34.c, a CBLR HC will report the sum of certain other off-balance sheet
exposures and sold credit derivatives. Specifically, a CBLR HC will report the

20

As provided in the CBLR final rule, the Board would reserve the authority to disallow the use of the CBLR
framework by an HC based on the risk profile of the HC. This authority derives from the general reservation of
authority included in the Board’s Regulation Q, in which the CBLR framework is be codified. See 12 CFR 217.1(d).
21
See definition of “unconditionally cancellable” in 12 CFR 217.2.

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



sum of self-liquidating, trade-related contingent items that arise from the
movement of goods; transaction-related contingent items (performance bonds, bid
bonds, warranties, and performance standby letters of credit); sold credit
protection in the form of guarantees and credit derivatives; credit-enhancing
representations and warranties; financial standby letters of credit; forward
agreements that are not derivative contracts; and off-balance sheet securitizations.
A CBLR HC will not include derivatives that are not sold credit derivatives, such
as foreign exchange swaps and interest rate swaps, in item 34.c.
o In item 34.d, a CBLR HC will report the sum of items 34.a through 34.c in
Column A. The HC will also report that sum divided by total assets from
Schedule HC, item 12, and expressed as a percentage in Column B. As discussed
in the CBLR final rule, a HC will not be eligible to opt into the CBLR framework
if this percentage is greater than 25 percent.
In item 35, a CBLR HC will report the total of unconditionally cancellable commitments,
which will be calculated consistent with the instructions for existing Schedule HC-R,
Part II, item 19. This item is not used specifically to calculate a HC’s eligibility for the
CBLR framework. However, the Board is collecting this information in order to monitor
balance sheet exposures that are not reflected in the CBLR framework and to identify any
CBLR HCs with elevated concentrations in unconditionally cancellable commitments.
In item 36, a CBLR HC will report the amount of investments in the capital instruments
of an unconsolidated financial institution that would qualify as tier 2 capital. Since the
CBLR framework does not have a total capital requirement, a CBLR HC is neither
required to calculate tier 2 capital nor make any deductions that would be taken from tier
2 capital. Therefore, if a CBLR HC has investments in the capital instruments of an
unconsolidated financial institution that would qualify as tier 2 capital of the CBLR HC
under the generally applicable capital requirements (tier 2 qualifying instruments), and
the CBLR HC’s total investments in the capital of unconsolidated financial institutions
exceed 25 percent of its CET1 capital, the CBLR bank is not required to deduct the tier 2
qualifying instruments. A CBLR HC is required to make a deduction from CET1 capital
or T1 capital only if the sum of its investments in the capital of an unconsolidated
financial institution is in a form that would qualify as CET1 capital or T1 capital
instruments of the CBLR HC and the sum exceeds the 25 percent CET1 threshold. The
Board considers it important to continue collecting information on the amount of
investments in these capital instruments in order to identify any instances where such
activity potentially creates an unsafe or unsound practice or condition.

Because a CBLR HC will not be subject to the generally applicable capital requirements,
a CBLR HC will not need to complete any of the items in Schedule HC-R, Part I, after proposed
item 36, nor will the holding company need to complete Schedule HC-R, Part II, Risk-Weighted
Assets.
In connection with moving the leverage ratio calculations and inserting items for the
CBLR qualifying criteria in Schedule HC-R, Part I, existing items 27 through 35 of Schedule
HC-R, Part I, will be renumbered as items 37 through 45. Existing items 40 through 43 will be
renumbered as items 46 through 49, while existing items 46 through 48 will be renumbered as

9

items 50 through 52. For advanced approaches HCs, existing item 45 for total leverage exposure
and the supplementary leverage ratio, will be renumbered as item 53.
A CBLR HC will indicate that it has elected to apply the CBLR framework by
completing Schedule HC-R, Part I, items 32 through 36. HCs not subject to the CBLR
framework would be required to report all data items in Schedule HC-R, Part I, except for items
32 through 36.
Standardized Approach for Counterparty Credit Risk on Derivatives
The Board revised the FR Y-9C instructions to implement changes to the capital rule
regarding how to calculate the exposure amount of derivative contracts (the standardized
approach for counterparty credit risk, or SA-CCR) that were implemented by final rule (the
SA-CCR final rule).22
The SA-CCR final rule amends the capital rule by replacing the current exposure
methodology (CEM) with SA-CCR for advanced approaches HCs. The final rule requires
holding companies subject to Category I and II standards (Category I and II holding companies)
under the Board’s tailoring final rule23 to use SA-CCR to calculate their standardized total riskweighted assets and permits non-advanced approaches banking organizations the option of using
SA-CCR in place of CEM to calculate the exposure amount of their noncleared and cleared
derivative contracts.
Category I and II banking organizations would have to choose either SA-CCR or the
internal models methodology (IMM) to calculate the exposure amount of their noncleared and
cleared derivative contracts in connection with calculating their risk-based capital under the
advanced approaches. The SA-CCR final rule provides for the eventual elimination of the current
methods for Category I and II banking organizations to determine the risk-weighted asset amount
for their default fund contributions to a central counterparty (CCP) or a qualifying central
counterparty (QCCP) and implements a new and simpler method that would be based on the
banking organization’s prorata share of the CCP’s and QCCP’s default fund. However, the final
rule allows banking organizations that elect to use SA-CCR to continue to use method 1 and
method 2 under CEM to calculate the risk-weighted asset amount for default fund contributions
until January 1, 2022.
Under the SA-CCR final rule, a non-advanced approaches HC will be able to use either
CEM or SA-CCR to calculate the exposure amount of any noncleared and cleared derivative
contracts and to determine the risk-weighted asset amount of any default fund contributions
under the standardized approach. A HC that meets the criteria for a banking organization subject
to Category III standards24 will also use SA-CCR for calculating its supplementary leverage ratio
if it chooses to use SA-CCR to calculate its derivative and default fund exposures.
22

84 FR 4362 (January 24, 2020).
84 FR 59230 (November 1, 2019).
24
The Board’s final tailoring rule, approved on October 10, 2019, describes a Category III banking organization
generally as a banking organization with $250 billion or more in total consolidated assets that is not a global
23

10

Accordingly, the Board revised the instructions for HC-R Part II, consistent with the
SA-CCR final rule. Generally, the revisions to the reporting of derivatives elements in Schedule
HC-R, Part II, are driven by differences in the methodology for determining the exposure amount
of a derivative contract under SA-CCR relative to CEM. The General Instructions for Schedule
HC-R, Part II, and the instructions for Schedule HC-R, Part II, items 20, 21, and Memorandum
items 1 through 3 were revised. These revisions will be effective for the June 30, 2020, report
date, the same quarter as the effective date of the SA-CCR final rule, with a mandatory
compliance date of January 1, 2022. The Board also clarified the FR Y-9C instructions for
HC-R, Part II, items 20 and 21 to explain that derivatives cleared through a central counterparty
or a qualified central counterparty should be reported in HC-R, Part II, items 20 as an over-thecounter derivative.
High Volatility Commercial Real Estate (HVCRE)
The Board revised the FR Y-9C instructions to implement changes to the HVCRE
exposure definition in section 2 of the capital rule25 to conform to the statutory definition of an
HVCRE Acquisition, Development, or Construction (ADC) loan (HVCRE final rule).26 The
revisions align the capital rule with section 214 of the EGRRCPA to exclude from the definition
of HVCRE exposure credit facilities that finance the acquisition, development, or construction of
one- to four-family residential properties.27
The HVCRE final rule also clarifies the definition of HVCRE exposure in the capital rule
by adding a new paragraph that provides that the exclusion for one- to four-family residential
properties would not include credit facilities that solely finance land development activities, such
as the laying of sewers, water pipes, and similar improvements to land, without any construction
of one- to four-family residential structures. In order for a loan to be eligible for this exclusion,
the credit facility would be required to include financing for construction of one- to four-family
residential structures.

systemically important bank (GSIB) nor has significant international activity, or a banking organization with total
consolidated assets of $100 billion or more, but less than $250 billion, that meets or exceeds other specified riskbased indicators. See “Prudential Standards for Large Bank Holding Companies, Savings and Loan Holding
Companies, and Foreign Banking Organizations,” 84 FR 59032 (November 1, 2019).
25
12 CFR Part 217.2.
26
84 FR 68019 (December 13, 2019).
27
Section 214 became effective upon enactment of the EGRRCPA. Accordingly, on July 6, 2018, the Board, along
with the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC),
issued a statement advising institutions that, when determining which loans should be subject to a heightened risk
weight, they may choose to continue to apply the current regulatory definition of HVCRE exposure, or they may
choose to apply the heightened risk weight only to those loans they reasonably believe meet the definition of
“HVCRE ADC loan” set forth in section 214 of the EGRRCPA. See Board, FDIC, and OCC, Interagency statement
regarding the impact of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA).
https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20180706a1.pdf. The Board temporarily
implemented this revision to the FR Y-9C through an emergency PRA clearance that permitted, but did not require,
a HC to use the definition of HVCRE ADC loan in place of the existing definition of HVCRE loan.

11

Operating Lease Liabilities
In February 2016, the FASB issued ASU No. 2016-02, “Leases,” which added Topic 842,
Leases, to the Accounting Standards Codification (ASC). Once ASU 2016-02 is effective for a
holding company, the ASU’s accounting requirements, as amended by certain subsequent ASUs,
supersede ASC Topic 840, Leases.
The most significant change that ASC Topic 842 makes to the previous lease accounting
requirements is to lessee accounting. Under the lease accounting standards in ASC Topic 840,
lessees recognize lease assets and lease liabilities on the balance sheet for capital leases, but do
not recognize operating leases on the balance sheet. The lessee accounting model under Topic
842 retains the distinction between operating leases and capital leases, which the new standard
labels finance leases. However, the new standard requires lessees to record a right-of-use (ROU)
asset and a lease liability on the balance sheet for operating leases. (For finance leases, a lessee’s
lease asset also is designated an ROU asset.) In general, the new standard permits a lessee to
make an accounting policy election to exempt leases with a term of one year or less at their
commencement date from on-balance sheet recognition.
The Board revised the FR Y-9C instructions to implement changes for operating leases to
be reported as other liabilities instead of other borrowings for regulatory reporting purposes. The
change would better align the reporting of the single noninterest expense item for operating
leases in the income statement (which is the presentation required by ASC Topic 842) with their
balance sheet classification.
For HCs that are public business entities, as defined under U.S. GAAP, ASU 2016-02 is
effective for fiscal years beginning after December 15, 2018, including interim reporting periods
within those fiscal years. For HCs that are not public business entities, at present, the new
standard is effective for fiscal years beginning after December 15, 2019, and interim reporting
periods within fiscal years beginning after December 15, 2020. Early application of the new
standard is permitted for all HCs.
The FR Y-9C reports Supplemental Instructions for March 201928 stated that a lessee
should report lease liabilities for operating leases and finance leases, including lease liabilities
recorded upon adoption of the ASU, in Schedule HC-M, item 14, “Other borrowings,” which is
consistent with the current FR Y-9C instructions for reporting a lessee’s obligations under capital
leases under ASC Topic 840. In response to this instructional guidance, the Board received
questions from HCs concerning the reporting of a bank lessee’s lease liabilities for operating
leases. These HCs indicated that reporting operating lease liabilities as other liabilities instead of
other borrowings would better align the reporting of the single noninterest expense item for
operating leases in the income statement (which is the presentation required by ASC Topic 842)
with their balance sheet classification and would be consistent with how these HCs report
operating lease liabilities internally.

28

See https://www.federalreserve.gov/reportforms/supplemental/SI_FRY9_201903.pdf.

12

The Board agrees with the views expressed by these HCs and revised the FR Y-9C to
require that operating lease liabilities be reported on the FR Y-9C balance sheet in Schedule HC,
item 20, “Other liabilities.” In Schedule HC-G, Other Liabilities, operating lease liabilities would
be reported in item 4, “Other” effective March 31, 2020.
Reporting Home Equity Lines of Credit That Convert From Revolving to
Non-Revolving Status
Holding companies report the amount outstanding under revolving, open-end lines of
credit secured by 1-4 family residential properties (commonly known as home equity lines of
credit or HELOCs) in item 1.c.(1) of Schedule HC-C, Loans and Lease Financing Receivables.
The amounts of closed-end loans secured by 1-4 family residential properties are reported in
Schedule HC-C, item 1.c.(2)(a) or (b), depending on whether the loan is a first or a junior lien.29
A HELOC is a line of credit secured by a lien on a 1-4 family residential property that
generally provides a draw period followed by a repayment period. During the draw period, a
borrower has revolving access to unused amounts under a specified line of credit. During the
repayment period, the borrower can no longer draw on the line of credit, and the outstanding
principal is either due immediately in a balloon payment or repaid over the remaining loan term
through monthly payments. The FR Y-9C instructions do not address the reporting treatment for
a home equity line of credit when it reaches its end-of-draw period and converts from revolving
to nonrevolving status. This leads to inconsistency in how these credits are reported in Schedule
HC-C, items 1.c.(1), 1.c.(2)(a), and 1.c.(2)(b), and in other holding company items that use the
definitions of these three loan categories.
To address this absence of instructional guidance and promote consistency in reporting,
the Board proposed to clarify the instructions for reporting loans secured by 1-4 family
residential properties by specifying that after a revolving open-end line of credit has converted to
non-revolving closed-end status, the loan should be reported as closed-end in Schedule HC-C,
item 1.c.(2)(a) or (b), as appropriate.
The Board considers that it is important to collect accurate data on loans secured by 1-4
family residential properties in the FR Y-9C reports. Consistent classification of HELOCs based
on the status of the draw period is particularly important for the Board’s safety and soundness
monitoring. Due to the structure of HELOCs discussed above, borrowers generally are not
required to make principal repayments during the draw period, which may create a financial
shock for borrowers when they must make a balloon payment or begin regular monthly
repayments after the draw period. Some HCs report HELOCs past the draw period as revolving,
and this practice increases the amounts outstanding, charge-offs, recoveries, past dues, and
nonaccruals reported in the open-end category relative to the amounts reported by HCs that treat
HELOCs past the draw period as closed-end, which makes the data less useful for analysis and

29

Holding companies report additional information on open-end and closed-end loans secured by 1-4 family
residential properties in certain other FR Y-9C schedules in accordance with the loan category definitions in
Schedule HC-C, items 1.c.(1), 1.c.(2)(a), and 1.c.(2)(b).

13

safety and soundness monitoring. In addition, in Accounting Standards Update No. 2019-04,30
the FASB amended ASC Subtopic 326-20 on credit losses to require that, when presenting credit
quality disclosures in notes to financial statements prepared in accordance with U.S. GAAP, an
entity must separately disclose line-of-credit arrangements that are converted to term loans from
line-of-credit arrangements that remain in revolving status. The Board has determined that there
would be little or no impact to the regulatory capital calculations or other regulatory reporting
requirements as a result of this clarification.
In light of prior comments regarding the time needed for any systems changes, the Board
proposed that compliance with the clarified instructions would not have been required until the
March 31, 2021, report date. The Board’s December 2019 notice further proposed that
institutions not currently reporting in accordance with the clarified instructions would be
permitted, but not required, to report in accordance with the clarified instructions before that
date.
Board revised the FR Y-9C instructions to create a new memorandum item, Schedule
HC-C, Part I, Memorandum 15, for HCs to report HELOCs that have converted to non-revolving
closed-end status that are included in Schedule HC-C, Part I, item 1.c.1. This new line item will
would not be required until the March 31, 2021, report date. The Board also clarified instructions
for Schedule HC-C, items 1.c.(1), 1.c.(2)(a), and 1.c.(2)(b).
Adopted Revisions to the FR Y-9CS
The Board revised the FR Y-9CS to clarify that response to the report is voluntary.
Time Schedule for Information Collection
The FR Y-9C and FR Y-9LP are filed quarterly as of the last calendar day of March,
June, September, and December. The filing deadline for the FR Y-9C is 40 calendar days after
the March 31, June 30, and September 30 as-of dates and 45 calendar days after the
December 31 as-of date. The filing deadline for the FR Y-9LP is 45 calendar days after the
quarter-end as-of date. The FR Y-9SP is filed semiannually as of the last calendar day of June
and December, and the filing deadline is 45 calendar days after the as-of date. The annual
FR Y-9ES is collected as of December 31, and the filing deadline is July 31 of the following
year, unless an extension to file by October 15 is granted. Respondents will be notified of the
filing deadline for the FR Y-9CS if it is utilized by the Board.
Public Availability of Data
Data from the FR Y-9 reports that are not granted confidential treatment are publicly
available on the Federal Financial Institutions Examination Council website:
https://www.ffiec.gov/NPW.

Accounting Standards Update No. 2019-04, “Codification Improvements to Topic 326, Financial Instruments—
Credit Losses, Topic 815, Derivatives and Hedging, and Topic 825, Financial Instruments,” issued in April 2019.
30

14

Legal Status
The Board has the authority to impose the reporting and recordkeeping requirements
associated with the FR Y-9 family of reports on BHCs pursuant to section 5 of the Bank Holding
Company Act of 1956 (BHC Act) (12 U.S.C. § 1844); on SLHCs pursuant to section 10(b)(2)
and (3) of the Home Owners’ Loan Act (12 U.S.C. § 1467a(b)(2) and (3)), as amended by
sections 369(8) and 604(h)(2) of the Dodd-Frank Wall Street and Consumer Protection Act
(Dodd-Frank Act); on U.S. IHCs pursuant to section 5 of the BHC Act (12 U.S.C § 1844), as
well as pursuant to sections 102(a)(1) and 165 of the Dodd-Frank Act (12 U.S.C. §§ 511(a)(1)
and 5365);31 and on securities holding companies pursuant to section 618 of the Dodd-Frank Act
(12 U.S.C. § 1850a(c)(1)(A)). Except for the FR Y-9CS report, which is expected to be collected
on a voluntary basis, the obligation to submit the remaining reports in the FR Y-9 series of
reports and to comply with the recordkeeping requirements set forth in the respective instructions
to each of the other reports, is mandatory.
With respect to the FR Y-9C report, Schedule HI’s data item 7(g) “FDIC deposit
insurance assessments,” Schedule HC-P’s data item 7(a) “Representation and warranty reserves
for 1-4 family residential mortgage loans sold to U.S. government agencies and government
sponsored agencies,” and Schedule HC-P’s data item 7(b) “Representation and warranty reserves
for 1-4 family residential mortgage loans sold to other parties” are considered confidential
commercial and financial information. Such treatment is appropriate under exemption 4 of the
Freedom of Information Act (FOIA) (5 U.S.C. § 552(b)(4)) because these data items reflect
commercial and financial information that is both customarily and actually treated as private by
the submitter, and which the Board has previously assured submitters will be treated as
confidential. It also appears that disclosing these data items may reveal confidential examination
and supervisory information, and in such instances, this information would also be withheld
pursuant to exemption 8 of the FOIA (5 U.S.C. § 552(b)(8)), which protects information related
to the supervision or examination of a regulated financial institution.
In addition, for both the FR Y-9C report and the FR Y-9SP report, Schedule HC’s
memorandum item 2.b., the name and email address of the external auditing firm’s engagement
partner, is considered confidential commercial information and protected by exemption 4 of the
FOIA (5 U.S.C. § 552(b)(4)) if the identity of the engagement partner is treated as private
information by HCs. The Board has assured respondents that this information will be treated as
confidential since the collection of this data item was proposed in 2004.

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 foreign banking organizations 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 FR Y-9 series of reports.
31

15

Aside from the data items described above, the remaining data items collected on the
FR Y-9C report and the FR Y-9SP report are generally not accorded confidential treatment. The
data items collected on FR Y-9LP, FR Y-9ES, and FR Y-9CS32 reports, are also generally not
accorded confidential treatment. As provided in the Board’s Rules Regarding Availability of
Information (12 CFR part 261), however, a respondent may request confidential treatment for
any data items the respondent believes should be withheld pursuant to a FOIA exemption. The
Board will review any such request to determine if confidential treatment is appropriate, and will
inform the respondent if the request for confidential treatment has been denied.
To the extent the instructions to the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES
reports each respectively direct the financial institution to retain the workpapers and related
materials used in preparation of each report, such material would only be obtained by the Board
as part of the examination or supervision of the financial institution. Accordingly, such
information is considered confidential pursuant to exemption 8 of the FOIA (5 U.S.C. §
552(b)(8)). In addition, the financial institution’s workpapers and related materials may also be
protected by exemption 4 of the FOIA, to the extent such financial information is treated as
confidential by the respondent (5 U.S.C. § 552(b)(4)).
Consultation Outside the Agency
The Board consulted with the Federal Deposit Insurance Corporation and Office of the
Comptroller of the Currency in regard to these revisions.
Public Comments
On December 27, 2019, the Board published an initial notice in the Federal Register
(84 FR 71414) requesting public comment for 60 days on the proposal to extend, with revision,
of the FR Y-9 series reports. The comment period for this notice expired on February 25, 2020.
The Board received one comment from a bankers’ association. The Board also considered
comments on a proposal to make similar revisions to the Call Reports33 in order to promote
consistency between the Call Reports and the FR Y-9 reports.
The Board did not receive any comments on the FR Y-9C report related to the CBLR
changes. However, the Board considered comments received on the Call Report proposal, and
adopted changes on the FR Y-9C to maintain consistency with the Call Report. Several
comments were received on the Call Report proposal related to the CBLR proposed changes.
One commenter supported the proposed line item additions to Schedule RC-R, Part I, to support
changes to the leverage ratio, but another commenter recommended removing proposed items 35
through 38.c34 of Part I because the data to be reported are not qualifying criteria under the
CBLR framework. Two commenters did not favor the proposal to move existing items 36
through 39 of Schedule RC-R, Part I, which are used to measure total assets for the leverage
32

The FR Y-9CS is a supplemental report that may be utilized by the Board to collect additional information that is
needed in an expedited manner from HCs. The information collected on this supplemental report is subject to
change as needed. Generally, the FR Y-9CS report is treated as public. However, where appropriate, data items on
the FR Y-9CS report may be withheld under exemptions 4 and/or 8 of the Freedom of Information Act (5 U.S.C. §
552(b)(4) and (8)).
33
84 FR 4780 (January 27, 2020).
34
These items 37 through 38.c are not applicable to the FR Y-9C report.

16

ratio, and existing item 44, “Tier 1 leverage ratio,” from their present locations in Part I of the
schedule to an earlier position in Part I where all of the CBLR-related items would have been
reported, with these five items renumbered as items 27 through 31. One of the commenters stated
that, although this proposed change in the presentation of Part I of Schedule RC-R would not
affect the results of individual items in Part I, the proposed new presentation could be confusing
to end users of the schedule. The second commenter expressed concern about inserting the data
items for the CBLR framework within existing Schedule RC-R, Part I, rather than in a separate
version of the schedule, as had been originally proposed in April 2019, because the insertion of
these data items would be confusing and could lead to reporting errors. Thus, this commenter
suggested a break-up of the proposed revised structure of Part I of Schedule RC-R into three
separate parts, with existing Part II of Schedule RC-R becoming the fourth part of the schedule.
In addition, this commenter noted that an institution that is eligible to opt into the CBLR
framework may opt into and out of the framework at any time, and that there is a grace period for
an institution that no longer meets the qualifying criteria for the CBLR framework.
The Board has considered these comments on the Call Report and will retain proposed
FR Y-9C items 35 through 36 for reporting by CBLR holding companies in Schedule HC-R,
Part I, as proposed for the reasons cited in the December 2019 notice. While these items are not
used specifically to calculate a holding company’s eligibility for the CBLR framework, the
Board considers collecting information on unconditionally cancellable commitments or
investments in the tier 2 capital instruments important for identifying instances where such
activity potentially creates an unsafe or unsound practice or condition.
The Board will also retain the proposed movement of the data items related to the
leverage ratio to a position immediately after the calculation of tier 1 capital (designated items 27
through 31 of Schedule HC-R, Part I, as it would be revised) as well as the placement of the
proposed data items to be completed only by CBLR holding companies, including those within
the grace period (designated items 32 through 36 of Schedule HC-R, Part I, as it would be
revised). Because all holding companies are subject to a leverage ratio requirement, all
institutions must calculate and report the ratio’s numerator, which is tier 1 capital, and its
denominator, which is based on average total assets. As a consequence, items 1 through 31 of
Part I would be applicable to and completed by all institutions. Moving the leverage ratio data
items as proposed would allow CBLR holding companies to avoid completing the remainder of
Schedule HC-R after item 36 of Part I. The Board considers this option less confusing for CBLR
holding companies than having to complete the leverage ratio items in their current location,
which is after numerous items that will not be applicable to CBLR holding companies.
Furthermore, the Board will modify the formatting of Schedule HC-R, Part I, to better
distinguish the data items that should be completed only by CBLR holding companies and those
that should be completed only by those institutions applying the generally applicable capital
requirements. This will be accomplished by improving the captioning before Schedule HC-R,
Part I, item 32, which is the first data item to completed only by CBLR holding companies, and
between items 36, which is the final data item only for CBLR holding companies banks, and
item 37, which is the first data item applicable only to other institutions subject to the generally
applicable capital requirements. The portion of Schedule HC-R, Part I, applicable only to CBLR
holding companies also will be marked by bordering. These modifications to the formatting of
17

Part I should functionally achieve an outcome similar to the comment suggesting that Part I be
split into Parts 1, 2, and 3 with existing Part II then renumbered as Part 4.
In addition, the Board acknowledges that, under the CBLR final rule, a holding company
that is eligible to opt into the CBLR framework may choose to opt into or out of this framework
at any time and for any reason. Accordingly, the Board agrees with the commenter’s
recommendation that an institution should report its status as of the report date regarding the use
of the CBLR framework. Therefore, the Board will add a “yes/no” item 31.a to Schedule HC-R,
Part I, after item 31, “Leverage ratio,” in which each holding company would report whether it
has a CBLR framework election in effect as of the quarter-end report date. An institution would
answer “yes” if it qualifies for the CBLR framework (even if it is within the grace period) and
has elected to adopt the framework as of that report date. Otherwise, the institution would answer
“no.” Captioning after the “yes/no” response to item 31.a would indicate which of the subsequent
data items in Schedule HC-R should be completed based on the response to item 31.a. This
“yes/no” response should assist a holding company in understanding which specific data items it
should complete in the rest of Schedule HC-R. The response also should assist users of Schedule
HC-R in understanding the regulatory capital regime an institution is following as of the report
date. The Board is not adopting a commenter’s recommendation to add additional data items
relating to use of the CBLR, for example by differentiating between holding companies that
currently meet the CBLR qualifying criteria and those that are within the grace period, as the
Board does not need this additional level of detail in the FR Y-9C report.
The Board considers such modifications to the format and structure of Part I of Schedule
HC-R will limit the burden on reporting institutions and lessen possible confusion, including for
users of Schedule HC-R and for those qualifying community institutions that elect to adopt the
CBLR framework.
The Board received a comment from a bankers’ association requesting additional
clarification to the FR Y-9C instructions that conform to changes on the Call Report related to
certain derivatives reporting issues. The Call Report commenters sought clarification as to
whether, for purposes of reporting derivatives referred to as settled-to-market contracts in
Memorandum item 3, the remaining maturity of such derivatives should be the remaining
maturity used to determine the conversion factor for the calculation of the potential future
exposures (PFE) of these contracts or the contractual remaining maturity of these contracts. The
derivatives information reported in Memorandum items 1 through 3 of Schedule HC-R, Part II, is
collected to assist the Board in understanding, and assessing the reasonableness of, the credit
equivalent amounts of the over-the-counter derivatives and the centrally cleared derivatives
reported in Schedule HC-R, Part II, items 20 and 21, column B. Accordingly, when reporting
settled-to-market centrally cleared derivative contracts in Memorandum item 3, the remaining
maturity used to determine the applicable conversion factor should be the basis for reporting.
The Board revised the instructions for Schedule HC-R, Part II, Memorandum item 3, to clarify
the reporting of settled-to-market centrally cleared derivative contracts.
The commenter on the Call Report proposal also expressed concerns related to the
reporting of notional amounts in Schedule HC-R by institutions that use SA-CCR. The
commenter recommended that the notional amounts by institutions that use SA-CCR should be
18

based on the contractual notional amount, i.e., the notional amount as defined in U.S. generally
accepted accounting principles (U.S. GAAP), consistent with current practice in Schedule HC-R.
Institutions report the notional amounts of over-the-counter and centrally cleared derivative
contracts by remaining maturity in Schedule HC-R, Part II, Memorandum items 2 and 3. After
considering this comment, the Board will clarify the instructions for Schedule HC-R, Part II,
Memorandum items 2 and 3, to indicate that all institutions, including those that use SA-CCR to
calculate exposure amounts, should report contractual notional amounts. The Board also clarified
the reporting instructions to Schedule HC-L that all notional amounts should be based on U.S.
GAAP contractual notional amounts.
The commenter recommended that the Board revise the FR Y-9C instructions on
reporting of notional amounts in Schedule HC-L, Derivatives and Off-Balance Sheet Items, and
Schedule HC-R, Part II, Risk-Weighted Assets, for derivatives that have matured, but have
associated unsettled receivables or payables that are reported as assets or liabilities, respectively,
on the balance sheet as of the quarter-end report date. In seeking clarification of the reporting
requirements for such situations, the commenter recommended not reporting the notional
amounts for derivatives that have matured. The Board agrees and has clarified the FR Y-9C,
Schedule HC-L and Schedule HC-R, instructions to exclude reporting of the notional amounts of
derivatives that have matured. The Board considered another comment received on the Call
Report regarding clarification on whether the client facing leg of a derivative cleared through a
central counterparty or a qualified central counterparty should be reported as an OTC or centrally
cleared derivative. The Board has clarified the FR Y-9C instructions for HC-R, Part II, items 20
and 21 to clarify that such derivatives should be reported in HC-R, Part II, item 20, as an overthe-counter derivative.
Two Call Report commenters addressed the reporting of the fair value of collateral held
against over-the-counter (OTC) derivative exposures by type of collateral and type of derivative
counterparty in Schedule RC-L, item 16.b, and questioned whether this information is
meaningful. One commenter requested clarification of the purpose for collecting this information
while the other recommended no longer collecting this information. The data items for reporting
the fair value of collateral are applicable to institutions with total assets of $10 billion or more. In
general, the Board uses this information collected on the FR Y-9C in its oversight and
supervision of holding companies engaging in OTC derivative activities. The breakdown of the
fair value of collateral posted for OTC derivative exposures in Schedule HC-L, item 15.b
provides the Board with important insights into the extent to which collateral is used as part of
the credit risk management practices associated with derivative credit exposures to different
types of counterparties and changes over time in the nature and extent of the collateral
protection.
The Board received a comment from a bankers’ association requesting that the Board
ensure consistency across regulatory reports by modifying the proposed reporting of HELOCs in
line with comments on proposed Call Report changes. In connection with the Call Report
proposal, three commenters opposed the proposal to require that HELOCs that have converted to
non-revolving closed-end status should be reported as closed-end loans. Commenters cited the
numerous data items in multiple Call Report schedules that would be affected by this proposed
instructional clarification and the reconfiguration of systems that would need to be undertaken as
well as a definitional conflict between the Call Report instructions as proposed for clarification
19

and the instructions for the Board’s FR Y-14M report filed by holding companies with total
consolidated assets of $100 billion or more.35 In addition, one commenter stated that the
proposed Call Report instructional clarification may lead to inconsistencies between the
reporting of HELOCs in open-end and closed-end status in the Call Report and disclosures of
HELOCs made in filings with the Securities and Exchange Commission under the federal
securities laws. Another commenter cited differences in the risk profiles of loans underwritten as
HELOCs and those underwritten as closed-end loans at origination and indicated that the
proposed instructional clarification could distort performance trends for loans secured by 1-4
family residential properties as HELOCs migrate between the open-end and closed-end loan
categories in the Call Report. Two of the commenters opposing the proposed instructional
clarification instead recommended the creation of a memorandum item in the Call Report loan
schedule (Schedule RC-C, Part I) to identify for supervisory purposes the amount of HELOCs
that have converted to non-revolving closed-end status. The other commenter suggested
segregating closed-end HELOCs using a separate loan category code, which may also imply
separate reporting and disclosure of such HELOCs.
One Call Report commenter also requested that the agencies clarify the reporting
treatment for “drawdowns of a HELOC Flex product that contain ‘lock-out’ features,” which was
described as the borrower’s exercise of an option to convert a draw on the line of credit to “a
fixed rate interest structure with defined payments and term.”
After considering the comments received on the FR Y-9C proposal and the Call Report
comments, the Board will not implement the proposed clarification to the instructions for
Schedule HC-C, Part I, items 1.c.(1), 1.c.(2)(a), and 1.c.(2)(b) that would have resulted in
revolving, open-end lines of credit secured by 1-4 family residential properties that have
converted to non-revolving closed-end status being reported as closed-end loans. In light of the
guidance in the instructions for the Board’s FR Y-14M report that directs reporting entities to
continue to report HELOCs that are no longer revolving credits in the Home Equity schedule, the
Board will adopt this treatment for FR Y-9C purposes. However, recognizing the existing
diversity in practice in which some institutions report HELOCs that have converted from
revolving to non-revolving status as closed-end loans in the FR Y-9C while other institutions
continue to report such HELOCs as open-end loans, the Board will instruct institutions to report
all HELOCs that convert to closed-end status on or after January 1, 2021, as open-end loans in
Schedule HC-C, Part I, item 1.c.(1). A holding company that currently reports HELOCs that
have converted to non-revolving closed-end status as open-end loans in Schedule HC-C, Part I,
item 1.c.(1), should not change its reporting practice for these loans and should continue to report
these loans in item 1.c.(1) regardless of their conversion date. A holding company that currently
reports HELOCs that convert to non-revolving closed-end status as closed-end loans in Schedule
HC-C, Part I, item 1.c.(2)(a) or 1.c.(2)(b), as appropriate, may continue to report HELOCs that
convert on or before December 31, 2020, as closed-end loans in FR Y-9C for report dates after
that date. Alternatively, the institution may choose to begin reporting some or all of these closedend HELOCs as open-end loans in item 1.c.(1) as of the March 31, 2020, or any subsequent
report date, provided this reporting treatment is consistently applied. With respect to HELOC
Flex products, the proposed reporting treatment described above would mean that amounts
drawn on a HELOC during its draw period that a borrower converts to a closed-end amount
35

Capital Assessments and Stress Testing Report (FR Y-14M; OMB No. 7100-0341).

20

before the end of this period also should be reported as open-end loans in Schedule HC-C, Part I,
item 1.c.(1), subject to the transition guidance above.
The Board also agrees with the commenter’s suggestion to create a memorandum item in
Schedule HC-C, Part I, in which institutions would report the amount of HELOCs that have
converted to non-revolving closed-end status that are included in item 1.c.(1), “Revolving, openend loans secured by 1-4 family residential properties and extended under lines of credit.” This
new Memorandum item 15 in Schedule HC-C, Part I, would enable the Board to monitor the
proportion of an institution’s home equity credits in revolving and non-revolving status and
changes therein and assess whether changes in this proportion in relation to changes in past due
and nonaccrual home equity credits and charge-offs and recoveries of such credits warrant
supervisory follow-up. To provide time needed for any systems changes, the Board will
implement this new memorandum item as of the March 31, 2021.
Aside from the changes discussed above, the Board extended, with revision, the FR Y-9C
as originally proposed. On April 1, 2020, the Board published a final notice in the Federal
Register (85 FR 18230).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-9 is 124,000
hours, and would decrease to 119,667 hours with the adopted revisions, resulting in a decrease of
4,333 hours. FR Y-9C non-advanced approaches HCs (non-AA HCs) estimated average hours
per response of 40.61 is calculated by a weighted average approach.36 The average estimated
hours per response for advanced approaches FR Y-9C filers and for the FR Y-9LP, FR Y-SP,
FR Y-9ES, and FR Y-9CS filers would remain unchanged. These reporting requirements
represent 1.34 percent of the total Federal Reserve System paperwork burden.

36

The number of qualifying non-AA HCs for the CBLR framework (FR Y-9C CBLR) is 176 respondents. Of the
qualifying HCs, the Board estimates an initial adoption rate of 60 percent, or 106 respondents. The estimated hours
per response for FR Y-9C CBLR respondents is 31.11 hours, a decrease of 11.34 hours. The FR Y-9C (CBLR)
estimated number of respondents was multiplied by estimated average hours per response (106*4*31.11=13,191)
and FR Y-9C (Non-CBLR) estimated number of respondents multiplied by estimated average hours per response
(238*4*44.84=42,690). Both of these figures for CBLR and Non-CBLR were added together creating the weighted
summation (13,191+42,690=55,881), which was then divided by the total number of non-AA HCs in the current
burden table, resulting in an estimated average hours per response of 40.61 (55,881/4/344=40.61), reflecting a
decrease for all non-AA HCs of (43.76-40.61) 3.15 hours. The number of respondents is calculated using March 31,
2019, data or the most recent data available for the series.

21

FR Y-9
Current
Reporting
FR Y-9C (non AA HCs) with less than
$5 billion in total assets
FR Y-9C (non AA HCs) with $5
billion or more in total assets
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Recordkeeping
FR Y-9C
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Current Total
Proposed
FR Y-9C (non AA HCs CBLR) with
less than $5 billion in total assets
FR Y-9C (non AA HCs CBLR) with
$5 billion or more in total assets
FR Y-9C (non AA HCs non CBLR)
with less than $5 billion in total assets
FR Y-9C (non AA HCs non CBLR)
with $5 billion or more in total assets
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-CS
Recordkeeping
FR Y-9C
FR Y-9LP
FR Y-9SP
FR Y-9ES

Estimated
number of
respondents37

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

155

4

40.48

25,098

189

4

46.45

35,116

19
434
3,960
83
236

4
4
2
1
4

48.59
5.27
5.40
0.50
0.50

3,693
9,149
42,768
42
472

363
434
3,960
83
236

4
4
2
1
4

1.00
1.00
0.50
0.50
0.50

1,452
1,736
3,960
42
472
124,000

71

4

29.14

8,276

35

4

35.11

4,915

84

4

40.98

13,769

154

4

46.95

28,921

19
434
3,960
83
236

4
4
2
1
4

48.59
5.27
5.40
0.50
0.50

3,693
9,149
42,768
42
472

363
434
3,960
83

4
4
2
1

1.00
1.00
0.50
0.50

1,452
1,736
3,960
42

37

Of these respondents, 4 FR Y-9C FR Y 9C (non AA HCs non CBLR) with less than $5 billion in total assets
filers; 177 FR Y-9LP filers; 3,153 FR Y-9SP filers; and 83 FR Y-9ES filers 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.

22

236
Proposed Total

472
119,667

Change

(4,333)

FR Y-9CS

4

0.50

The current estimated total annual cost to the public for the FR Y-9 is $7,142,400 and
would decrease to $6,892,819 with the adopted revisions.38
Sensitive Questions
These collections of information contain 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 these
information collections will be $2,050,800.

38

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 Standard Occupational Classification System, https://www.bls.gov/soc/.

23