FRY14_20200610_omb

Supporting Statement for the
Capital Assessments and Stress Testing Reports
(FR Y-14A/Q/M; OMB No. 7100-0341)
Regulations Q, Y, and YY: Regulatory Capital, Capital Plan, and Stress Test Rules
(Docket No. R-1603; RIN 7100-AF02)
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 Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No.
7100-0341). These collections of information are currently applicable to top-tier U.S. bank
holding companies (BHCs) and U.S. intermediate holding companies of foreign banking
organizations (IHCs) with $100 billion or more in total consolidated assets. Covered savings and
loan holding companies (SLHCs)1 (collectively with BHCs, IHCs, and SLHCs, holding
companies) with $100 billion or more in total consolidated assets will also become respondents
to the FR Y-14Q and FR Y-14M effective June 30, 2020, and will become respondents to the
FR Y-14A effective December 31, 2021.2 The FR Y-14A, FR Y-14Q, and FR Y-14M reports are
used to support the Board’s Comprehensive Capital Analysis and Review (CCAR) and DoddFrank Act Stress Test (DFAST) exercises and supervisory stress test models, and also are used in
connection with the supervision and regulation of these financial institutions.
The Board adopted changes to the FR Y-14 related to a final rule (SCB rule) that
simplifies the Board’s capital framework while preserving strong capital requirements for large
firms.3 In connection with the SCB rule, the Board modified the FR Y-14A report to collect
information regarding a firm’s capital conservation buffer requirements (including the stress
capital buffer requirement) and any applicable distribution limitations under the regulatory
capital rule. Finally, to align with the SCB rule, the Board revised the FR Y-14A instructions to
require a firm to submit an updated FR Y-14A, Schedule C (Regulatory Capital Instruments),
within 15 days after notice of distributions in excess of planned distributions as required under
the capital plan rule. The revisions are effective with the December 31, 2020, as-of date, except
for the revisions to FR Y-14A, Schedule C, which are effective when the final rule goes into
effect, May 18, 2020.
The current estimated total annual burden for the FR Y-14 is 802,756 hours, and would
increase to 803,476 hours. The adopted revisions would result in an increase 720 hours. The draft
forms and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/review.aspx.

1

Covered SLHCs are those that are not substantially engaged in insurance or commercial activities. See 12 CFR
217.2.
2
See 84 FR 59032 (November 1, 2019).
3
85 FR 15576 (March 18, 2020).

Background and Justification
Section 165(i)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act)4 requires the Board to conduct an annual stress test of certain companies to
evaluate whether the company has sufficient capital, on a total consolidated basis, to absorb
losses as a result of adverse economic conditions (supervisory stress test).5 Further, section
165(i)(2) of the Dodd-Frank Act requires the Board to issue regulations requiring such
companies to conduct company-run stress tests.6 On May 24, 2018, the Economic Growth,
Regulatory Relief, and Consumer Protection Act (EGRRCPA) amended sections 165(i)(1) and
(2) of the Dodd-Frank Act, among other changes.7 The Board’s rules implementing sections
165(i)(1) and (i)(2) of the Dodd-Frank Act establish stress testing requirements for certain BHCs,
state member banks, savings and loan holding companies, foreign banking organizations, and
nonbank financial companies supervised by the Board.8
Additionally, the Board’s capital plan rule requires certain firms to submit capital plans to
the Board annually and requires such firms to request prior approval from the Board under
certain circumstances before making a capital distribution.9 In connection with submissions of
capital plans to the Board, firms are required, pursuant to 12 CFR 225.8(e)(3), to provide
information including, but not limited to, the firm’s financial condition, structure, assets, risk
exposure, policies and procedures, liquidity, and risk management.
The FR Y-14A/Q/M reports complement other Board supervisory efforts aimed at
enhancing the continued viability of large firms, including continuous monitoring of firms’
planning and management of liquidity and funding resources, as well as regular assessments of
credit, market and operational risks, and associated risk management practices.
The FR Y-14 series of reports collect stress test and capital plan data from the largest
holding companies, which are those with $100 billion or more in total consolidated assets. The
data collected through the FR Y-14A/Q/M reports provide the Board with the information
needed to help ensure that large holding companies have strong, firm‐wide risk measurement and
management processes supporting their internal assessments of capital adequacy and that their
capital resources are sufficient given their business focus, activities, and resulting risk exposures.
Information gathered in this data collection is also used in the supervision and regulation of these
financial institutions.
4

Pub. L. No. 111-203, 124 Stat. 1376 (2010).
See 12 U.S.C. § 5365(i)(1).
6
See 12 U.S.C. § 5365(i)(2).
7
EGRRCPA requires “periodic” supervisory stress tests for bank holding companies with $100 billion or more, but
less than $250 billion, in total consolidated assets and amended section 165(i)(1) to require annual supervisory stress
tests for bank holding companies with $250 billion or more in total consolidated assets. EGRRCPA amended section
165(i)(2) to require bank holding companies with $250 billion or more in total consolidated assets, and financial
companies with more than $250 billion in total consolidated assets, to conduct “periodic” stress tests. Finally,
EGRRCPA amended both sections 165(i)(1) and (2) to no longer require the Board to include an “adverse” scenario
in company-run or supervisory stress tests, reducing the number of required stress test scenarios from three to two.
8
See 12 CFR 252, subparts B, E, F, and O.
9
See 12 CFR 225.8.
5

2

Description of Information Collection
These collections of information are applicable to holding companies with total
consolidated assets of $100 billion or more. This family of information collections is composed
of the following three mandatory reports:
 The annual FR Y-14A, which collects quantitative projections of balance sheet, income,
losses, and capital across a range of macroeconomic scenarios, and qualitative
information on methodologies used to develop internal projections of capital across
scenarios.10
 The quarterly FR Y-14Q, which collects granular data on various asset classes, including
loans, securities, trading assets, and pre-provision net revenue (PPNR) for the reporting
period.
 The monthly FR Y-14M, which is comprised of three retail portfolio- and loan-level
schedules, and one detailed address matching schedule to supplement two of the
portfolio- and loan-level schedules.
FR Y-14A (annual collection)
The annual collection of quantitative projected regulatory capital ratios across various
macroeconomic scenarios is comprised of five primary schedules (Summary, Scenario,
Regulatory Capital Instruments, Operational Risk, Business Plan Changes), each with multiple
supporting tables.
The FR Y-14A schedules collect current financial information and projections under the
Board’s supervisory scenarios. The information includes balances for balance sheet and off‐
balance‐sheet positions, income statement and PPNR, and estimates of losses across various
portfolios.
Firms are also required to submit qualitative information supporting their projections,
including descriptions of the methodologies used to develop the internal projections of capital
across scenarios and other analyses that support their comprehensive capital plans.
FR Y-14Q (quarterly collection)
The FR Y-14Q schedules (Retail, Securities, Regulatory Capital Instruments, Regulatory
Capital, Operational Risk, Trading, PPNR, Wholesale Risk, Fair Value Option/Held for Sale,
Supplemental, Counterparty, and Balances) collect firm‐specific data on positions and exposures
that are used as inputs to supervisory stress test models to monitor actual versus forecast
information on a quarterly basis and to conduct ongoing supervision.

10

In certain circumstances, a BHC or IHC may be required to re-submit its capital plan. See 12 CFR 225.8(e)(4).
Firms that must re-submit their capital plan generally also must provide a revised FR Y-14A in connection with their
resubmission.

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FR Y-14M (monthly collection)
The FR Y-14M report includes two portfolio- and loan-level schedules for First Lien data
and Home Equity data, and an account- and portfolio-level schedule for Domestic Credit Card
data. To match senior and junior lien residential mortgages on the same collateral, the Address
Matching schedule gathers additional information on the residential mortgage loans reported in
the First Lien and Home Equity schedules.
Respondent Panel
The respondent panel consists of holding companies with $100 billion or more in total
consolidated assets,11 as based on (1) the average of the firm’s total consolidated assets in the
four most recent quarters as reported quarterly on the firm’s Consolidated Financial Statements
for Holding Companies (FR Y-9C; OMB No. 7100-0128) or (2) the average of the firm’s total
consolidated assets in the most recent consecutive quarters as reported quarterly on the firm’s
FR Y-9Cs, if the firm has not filed an FR Y-9C for each of the most recent four quarters.
Reporting is required as of the first day of the quarter immediately following the quarter in which
the respondent meets this asset threshold, unless otherwise directed by the Board.
Revisions to the FR Y-14A
The SCB rule integrated the Board’s regulatory capital rule with the CCAR, as
implemented through the Board’s capital plan rule. The final rule made amendments to the
capital rule, capital plan rule, stress test rules, and Stress Testing Policy Statement. Under the
SCB rule, the Board will use the results of its supervisory stress test to establish the size of a
firm’s stress capital buffer requirement, which replaces the static 2.5 percent of risk-weighted
assets component of a firm’s capital conservation buffer requirement. Through the integration of
the capital rule and CCAR, the SCB rule removed redundant elements of the current capital and
stress testing frameworks that currently operate in parallel rather than together, including the
CCAR quantitative objection and the assumption that a firm makes all capital actions under
stress.
In connection with the SCB rule, the Board modified the FR Y-14A to collect
information regarding a firm’s capital conservation buffer requirements (including the stress
capital buffer requirement) and any applicable distribution limitations under the regulatory
capital rule. Specifically, the Board revised the FR Y-14A, Schedule A.1.d (Capital) report to
collect the following items under firm baseline conditions: (1) the firm’s capital conservation
buffer requirement and, as applicable, leverage buffer requirement for each quarter of the
planning horizon, (2) the firm’s capital conservation buffer and, as applicable, leverage buffer as
of the preceding quarter-end for each quarter of the planning horizon, which is the difference
between the firm’s relevant capital ratio and the relevant minimum requirement, and
(3) information needed to calculate the firm’s maximum payout amount, including the firm’s
planned total capital distributions, eligible retained income, and maximum payout ratio for each
11

Covered SLHCs with $100 billion or more in consolidated assets are not required to file the FR Y-14Q and
FR Y-14M until the reports with the June 30, 2020, as-of date, and are not required to file the FR Y-14A until the
report with the December 31, 2020, as-of date.

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quarter of the planning horizon. Finally, to align with the SCB rule, the Board revised the
FR Y-14A instructions to require a firm to submit an updated FR Y-14A, Schedule C
(Regulatory Capital Instruments), within 15 days after notice of distributions in excess of
planned distributions as required under the capital plan rule. The revisions are effective with the
December 31, 2020, as-of date, except for the revisions to FR Y-14A, Schedule C, which are
effective when the final rule goes into effect, May 18, 2020.
Time Schedule for Information Collection
The following tables outline, by schedule and reporting frequency (annually, quarterly, or
monthly), the as-of dates for the data and their associated due date for the current submissions to
the Board.
Schedules and
Sub-schedules

Submission Date
to Board

Data as-of-date
FR Y-14A (Annual Filings)

Summary,
Macro Scenario
Operational Risk, and
Business Plan Changes
CCAR Market Shock
exercise
Summary schedule
 Trading Risk
 Counterparty
Regulatory Capital
Instruments

December 31st

April 5th of the following year.

A specified date in the
first quarter that would
be communicated by
the Board.12

April 5th

December 31st






12

Original submission: Data are
due April 5th of the following
year.
Adjusted submission: The
Board will notify companies at
least 14 calendar days in
advance of the date on which it
expects companies to submit
any adjusted capital actions.
Incremental submission:
Within 15 days after making
any capital distributions in
excess of those included in a
firm’s capital plan (see 12 CFR
225.8(k)).

See 12 CFR 252.14(b)(2). In February 2017, the Board finalized modifications to the capital plan rule extending
the range of dates from which the Board may select the as-of date for the global market shock to October 1 of the
calendar year preceding the year of the stress test cycle to March 1 of the calendar year of the stress test cycle.
82 FR 9308 (February 3, 2017).

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Schedules

Submission Date
to Board

Data as-of date
FR Y-14Q (Quarterly Filings)

Securities
PPNR
Retail
Wholesale Risk
Operational
Supplemental
Retail FVO/HFS
Regulatory Capital
Regulatory Capital
Instruments
Balances

Each calendar quarterend.

Due to the CCAR
Market Shock exercise,
the as-of date for the
fourth quarter would be
communicated in the
subsequent quarter.

Trading Schedule
Counterparty Schedule

Data are due seven calendar days
after the FR Y-9C reporting
schedule (52 calendar days after
the calendar quarter-end for
December and 47 calendar days
after the calendar quarter-end for
March, June, and September).

Data are due seven calendar days
after the FR Y-9C reporting
schedule for data as of the quarter
end for March, June, and
September.

Fourth quarter – Trading and
Counterparty
(Regular/unstressed
submission): 52 calendar days
after the notification date
For all other quarters,
(notifying respondents of the as-of
the as-of date would be date) or March 15, whichever
the last day of the
comes earlier. Unless the Board
quarter, except for
requires the data to be provided
firms that are required
over a different weekly period,
to re-submit their
firms may provide these data as-of
capital plan.
the most recent date that
corresponds to their weekly
For these firms, the as- internal risk reporting cycle, as
of date for the quarter
long as it falls before the as-of
preceding the quarter in date.
which they are required
to re-submit a capital
Fourth quarter – Counterparty
plan would be
(CCAR/stressed submission):
communicated to the
April 5th. In addition, for firms that
firms during the
are required to re-submit a capital
subsequent quarter
plan, the due date for the quarter
preceding the quarter in which the
firms are required to re-submit a
capital plan would be the later of
(1) the normal due date or (2) the

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Schedules

All schedules

Data as-of date

Submission Date
to Board
date that the re-submitted capital
plan is due, including any
extensions.

FR Y-14M (Monthly Filings)
The last business day
By the 30th calendar day of the
of each calendar
following month.
month.

Public Availablity of Data
No data received through this information collection is made is made available to the
public.
Legal Status
The Board has the authority to require BHCs to file the FR Y-14 reports pursuant to
section 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. § 1844(c)), and
pursuant to section 165(i) of the Dodd-Frank Act (12 U.S.C. § 5365(i)), as amended by section
401(a) and (e) of the EGRRCPA.13 The Board has authority to require SLHCs to file the
FR Y-14 reports pursuant to section 10(b) of the Home Owners’ Loan Act (12 U.S.C. §
1467a(b)), as amended by section 369(8) and 604(h)(2) of the Dodd-Frank Act. Lastly, the Board
has authority to require IHCs to file the FR Y-14 reports 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. §§ 5311(a)(1) and 5365).14 In addition, section 401(g) of EGRRCPA (12 U.S.C. §
5365 note) provides that the Board has the authority to establish enhanced prudential standards
for foreign banking organizations with total consolidated assets of $100 billion or more, and
clarifies that nothing in section 401 “shall be construed to affect the legal effect of the final rule
of the Board... entitled ‘Enhanced Prudential Standard for [BHCs] and Foreign Banking
Organizations’ (79 FR 17240 (March 27, 2014)), as applied to foreign banking organizations
with total consolidated assets equal to or greater than $100 million.”15 The obligation to file the
13

Pub. L. No. 115-174, Title IV § 401(a) and (e), 132 Stat. 1296, 1356-59 (2018).
Section 165(b)(2) 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-14 reports.
15
The Board’s final rule referenced in section 401(g) of EGRRCPA specifically stated that the Board would require
IHCs to file the FR Y-14 reports. See 79 FR 17240, 17304 (March 27, 2014).
14

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three FR Y-14 reports is mandatory.
The information reported in the FR Y-14 reports is collected as part of the Board’s
supervisory process, and therefore, such information is afforded confidential treatment pursuant
to exemption 8 of the Freedom of Information Act (FOIA) (5 U.S.C. § 552(b)(8)). In addition,
confidential commercial or financial information, which a submitter actually and customarily
treats as private, and which has been provided pursuant to an express assurance of confidentiality
by the Board, is considered exempt from disclosure under exemption 4 of the FOIA (5 U.S.C. §
552(b)(4)).16
Consultation Outside the Agency
There has been no consultation outside the agency.
Public Comments
On April 25, 2018, the Board published a notice of proposed rulemaking in the Federal
Register (83 FR 18160) for public comment. The comment period for this notice expired on
June 25, 2018. The Board did not receive any comments related to the Paperwork Reduction Act
analysis. On March 18, 2020, the Board published a final rule in the Federal Register
(85 FR 15576).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-14 is
802,756 hours, and would increase to 803,476 hours with the adopted revisions. The Board
estimates that revisions to the FR Y-14A would increase the estimated average hours per
response for FR Y-14A filers by 20 hours. These reporting requirements represent approximately
8.2 percent of the Board’s total paperwork burden.

Please note that the Board publishes a summary of the results of the Board’s CCAR testing pursuant to 12 CFR
225.8(f)(2)(v), and publishes a summary of the results of the Board’s DFAST stress testing pursuant to 12 CFR
252.46(b) and 12 CFR 238.134, which includes aggregate data. In addition, under the Board’s regulations, covered
companies must also publicly disclose a summary of the results of the Board’s DFAST stress testing. See 12 CFR
252.58; 12 CFR 238.146. The public disclosure requirement contained in 12 CFR 252.58 for covered BHCs and
covered IHCs is separately accounted for by the Board in the Paperwork Reduction Act clearance for FR YY (OMB
No. 7100-0350) and the public disclosure requirement for covered SLHCs is separately accounted for in by the
Board in the Paperwork Reduction Act clearance for FR LL (OMB No. 7100-NEW).
16

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Estimated
number of
respondents17

FR Y-14

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

Current
FR Y-14A
FR Y-14Q
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Current Total

36
36
34
0
36
0
13

1
4
12
1
1
1
1

1,065
1,920
1,072
7,200
480
4,800
2,560

38,340
276,480
437,376
0
17,280
0
33,280
802,756

Proposed
FR Y-14A
FR Y-14Q
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Proposed Total

36
36
34
0
36
0
13

1
4
12
1
1
1
1

1,085
1,920
1,072
7,200
480
4,800
2,560

39,060
276,480
437,376
0
17,280
0
33,280
803,476

Change

720

The estimated total annual cost to the public for this collection of information is
$46,359,159 and would increase to $46,400,739 with the adopted revisions.18
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
17

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.
The estimated number of respondents for the FR Y-14M is lower than for the FR Y-14Q and FR Y-14A because, in
recent years, certain respondents to the FR Y-14A and FR Y-14Q have not met the materiality thresholds to report
the FR Y-14M due to their lack of mortgage and credit activities. The Board expects this situation to continue for the
foreseeable future.
18
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 $20, 45% Financial Managers at
$71, 15% Lawyers at $70, and 10% Chief Executives at $93). 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 2019, published March 31, 2020, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

9

Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System is $2,598,000 for ongoing costs.

10