FRY14_20200612_omb_emergency

Supporting Statement for the
Capital Assessments and Stress Testing Reports
(FR Y-14A/Q/M; OMB No. 7100-0341)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has temporarily revised the Capital
Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No. 7100-0341) pursuant to its
authority to temporarily approve a collection of information without providing opportunity for
public comment.1 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)2 (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, 2021.3 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 has temporarily revised the FR Y-14A/Q/M reports to implement changes to
allow eligible firms to incorporate the effects of recently adopted changes to the Board’s capital
rule meant to simplify the capital rule (simplifications rule)4 and tailor the Board’s regulations to
more closely match this risk profile of domestic and foreign banks (tailoring rules).5 In addition,
the Board has also temporarily revised the FR Y-14A/Q/M reports to reflect amendments to the
current expected credit losses (CECL) transitions provisions (interim CECL final rule)6 and the
supplementary leverage ratio (SLR) (interim SLR final rule),7 made by the Board in response to
the coronavirus disease 2019 (COVID-19) pandemic. There are no temporary revisions to the
FR Y-14Q or FR Y-14M. The temporary revisions were effective for the December 31, 2019,
FR Y-14A as-of date, which was due April 6, 2020.
The estimated total annual burden for the FR Y-14A/Q/M reports is 803,476 hours. The
temporary revisions did not result in a change to the estimated burden hours. The draft forms and
instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/review.aspx.

1

5 CFR Part 1320, Appendix A (1)(a)(3)(i)(A).
Covered SLHCs are those that are not substantially engaged in insurance or commercial activities. See 12 CFR
217.2.
3
See 84 FR 59032 (November 1, 2019).
4
See 84 FR 35234 (July 22, 2019).
5
See 84 FR 59230 and 84 FR 59032 (November 1, 2019).
6
See 85 FR 17723 (March 31, 2020).
7
See https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200401a1.pdf (April 1, 2020).
2

Background and Justification
Section 165(i)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act)8 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).9 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.10 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.11 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.12
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.13 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-14A/Q/M series of reports collects 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.
8

Pub. L. No. 111-203, 124 Stat. 1376 (2010).
See 12 U.S.C. § 5365(i)(1).
10
See 12 U.S.C. § 5365(i)(2).
11
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.
12
See 12 CFR 252 subparts B, E, F, and O.
13
See 12 CFR 225.8.
9

2

Description of Information Collection
These collections of information are applicable to top-tier 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.14
 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, and 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 pre-provision net revenue (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.

14

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.

3

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 the holding companies with $100 billion or more in total
consolidated assets,15 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.
Temporary Revisions to the FR Y-14A/Q/M
The delegation of authority to the Board from OMB that permits the Board to approve
collections of information under the Paperwork Reduction Act includes the authority to
temporarily approve a collection of information without seeking public comment. To exercise
this authority, the Board must determine that a new collection of information or a change to an
existing collection must be instituted quickly and that public participation in the approval process
would substantially interfere with the Board’s ability to perform its statutory obligation.
Following the temporary approval of an information collection, the Board must conduct a normal
delegated review of the collection within six months, including publishing in the Federal
Register a notice seeking public comment.
As a result of the simplified threshold deduction framework and new AOCI opt-out
election discussed below, the simplifications and tailoring rules could have a material impact on
projected capital levels for certain non-advanced approaches institutions. In addition, the Board
issued the interim CECL final rule and interim SLR final rule in response to the COVID-19
pandemic. In order to allow non-advanced approaches institutions to be able to incorporate the
effects of the simplifications and tailoring rules, as well as for all firms to incorporate the effects
of the interim final rules in response to COVID-19, effective beginning with FR Y-14A reports
reflecting the December 31, 2019, as-of date, which were required to be submitted to the Board
by April 6, 2020, the Board was unable to satisfy the normal Paperwork Reduction Act clearance
process. The Board determined that it must revise the FR Y-14A quickly and that public
participation in the approval process would have defeated the purpose of the collection of
information, as delaying the revisions would have resulted in the collection of inaccurate
15

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, 2021, as-of date.

4

information, and would have interfered with the Board’s ability to perform its statutory duties
pursuant to section 165 of the Dodd-Frank Act.
Capital Simplifications
In order to allow eligible firms to report projected capital levels consistent with the
capital rule then in effect, the Board temporarily revised the FR Y-14A instructions for the
December 31, 2019, as-of date, to allow non-advanced approaches institutions to report certain
capital items in a manner that aligns with the simplifications rule. Specifically, the Board
temporarily revised the instructions for several items on FR Y-14A, Schedule A.1.d, and
Schedule A.1.c.1 (Standardized risk-weighted assets), to allow eligible firms to report data
beginning with the second projected quarter that incorporates the effects of capital
simplifications. The instructions for the following FR Y-14A, Schedule A.1.d, items were
temporarily revised:
 Item 35, Non-significant investments in the capital of unconsolidated financial
institutions in the form of common stock that exceed the 10 percent threshold for nonsignificant investments,
 Item 37, Significant investments in the capital of unconsolidated financial institutions in
the form of common stock, net of associated DTLs, that exceed 10 percent common
equity tier 1 capital deduction threshold,
 Item 38, MSAs, net of associated DTLs, that exceed the 10 percent common equity tier 1
capital deduction threshold,
 Item 39, DTAs arising from temporary differences that could not be realized through net
operating loss carrybacks, net of related valuation allowances and net of DTLs, that
exceed the 10 percent common equity tier 1 capital deduction threshold,
 Item 40, Amount of significant investments in the capital of unconsolidated financial
institutions in the form of common stock; MSAs, net of associated DTLs; and DTAs
arising from temporary differences that could not be realized through net operating loss
carrybacks, net of related valuation allowances and net of DTLs; that exceeds the 15
percent common equity tier 1 capital deduction threshold,
 Item 66, Amount of non-significant investments that exceed the 10 percent deduction
threshold for non-significant investments,
 Item 67, Gross significant investments in the capital of unconsolidated financial
institutions in the form of common stock,
 Item 70, 10 percent common equity tier 1 deduction threshold,
 Item 75, 10 percent common equity tier 1 deduction threshold,
 Item 78, 10 percent common equity tier 1 deduction threshold, and
 Item 84, Amount to be deducted from common equity tier 1 due to 15 percent deduction
threshold, prior to transition provision (greater of item 83 minus item 81 or zero).
The Board also temporarily revised the instructions for FR Y-14A, Schedule A.1.c.1, to
require non-advanced approaches institutions to incorporate the effects of capital simplifications
on applicable risk-weighted asset items (items 1-41), beginning in the second projected quarter.

5

Tailoring
Prior to the tailoring rules, non-advanced approaches firms could elect to recognize
elements of accumulated other comprehensive income (AOCI) in regulatory capital. The result
of this election is reported in item 18 (AOCI opt-out election). Per the guidance provided in
SR Letter 20-2 (Frequently Asked Questions on the Tailoring Rules), Category III and IV firms
are required to make a new election to determine whether to recognize elements of AOCI in
regulatory capital, beginning January 1, 2020. This election must be made during the first
reporting period after the banking organization meets the definition of a Category III or IV firm.
The Board temporarily revised the instructions for item 18 to adhere to the guidance provided in
SR Letter 20-2.
Previously, the instructions to FR Y-14A Schedule A.1.d, item 18 did not contemplate a
situation in which a holding company would make an AOCI opt-out election on a FR Y-9C
report with an as-of date other than (1) March 31, 2015, or (2) for a holding company that comes
into existence after that date, the first FR Y-9C report filed by the holding company. Therefore,
eligible firms would not have had the ability to reflect this new election in projected quarters for
the December 31, 2019, FR Y-14A submission.
Because the ability to make an AOCI opt-out election could have a material impact on
projected capital levels for certain firms, the Board temporarily revised FR Y-14A Schedule
A.1.d, item 18 to reflect that Category III and IV firms that were previously advanced
approaches institutions must make a new AOCI opt-out election during the first reporting period
after the firm meets the definition of a Category III Board-regulated institution or Category IV
Board-regulated institution. This temporary revision pertmitted firms to reflect this new election
in projected quarters for the December 31, 2019, FR Y-14A submission.
Current Expected Credit Losses (CECL)
The Board temporarily revised the instructions to FR Y-14A report to accurately reflect
the CECL transition provision as modified by the interim CECL final rule. Specifically, the
Board temporarily revised the FR Y-14A general instructions, as well as the instructions to the
following FR Y-14A schedules or line items:
 Schedule A.1.d, Capital,
 Schedule A.1.d, Line item 20, Retained earnings,
 Schedule A.1.d, Line item 39, DTAs arising from temporary differences that could not be
realized through net operating loss carrybacks, net of related valuation allowances and
net of DTLs, that exceed the 10 percent common equity tier 1 capital deduction threshold,
 Schedule A.1.d, Line item 54, Allowance for loan and lease losses includable in tier 2
capital,
 Schedule A.1.d, Line item 77, DTAs arising from temporary differences that could not be
realized through net operating loss carrybacks, net of related valuation allowances and
net of DTLs, and
 Collection of Supplemental CECL Information, Line item 2, Institutions applying the
CECL transition provision.

6

In addition, the Board delayed the due date for the December 31, 2019, FR Y-14A,
Collection of Supplemental CECL Information from April 6, 2020, to May 11, 2020, to
correspond with the submission date for the March 31, 2020, FR Y-9C report.
Supplementary Leverage Ratio (SLR)
The Board temporarily revised the FR Y-14A report to give each banking organization
that was required to submit the FR Y-14A on April 6, 2020 the option to calculate the
supplementary leverage ratio in its stress test results in accordance with the interim SLR final
rule. This revision does not require changes to the current FR Y-14A form and instructions. This
revision would be effective for the FR Y-14A report as of December 31, 2020, after which the
exclusion in the interim final rule will no longer be effective.
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

December 31st

April 5th of the following year.

A specified date in the
first quarter that would
be communicated by
the Board.16

April 5th


Regulatory Capital
Instruments


December 31st

16

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.

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).

7



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

Incremental submission:
Within 15 days after making
any capital distribution in
excess of those included in a
firm’s capital plan (see 12 CFR
225.8(k)).
Submission Date
Data as-of date
to Board
FR Y-14Q (Quarterly Filings)

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 and
Counterparty

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
For all other quarters,
(Regular/unstressed
the as-of date would be submission): 52 calendar days
the last day of the
after the notification date
quarter, except for
(notifying respondents of the as-of
firms that are required
date) or March 15, whichever
to re-submit their
comes earlier. Unless the Board
capital plan.
requires the data to be provided
over a different weekly period,
For these firms, the as- firms may provide these data as-of
of date for the quarter
the most recent date that
preceding the quarter in corresponds to their weekly
which they are required internal risk reporting cycle, as
to re-submit a capital
long as it falls before the as-of
plan would be
date.
communicated to the
firms during the
Fourth quarter – Counterparty
subsequent quarter
(CCAR/stressed submission):
April 5th. In addition, for firms that
8

Schedules

All schedules

are required to re-submit a capital
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
date that the re-submitted capital
plan is due, including any
extensions.
Submission Date
Data as-of date
to Board
FR Y-14M (Monthly Filings)
The last business day
By the 30th calendar day of the
of each calendar
following month.
month.

Public Availability 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-14A/Q/M 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.17 The Board has authority to require SLHCs to file the
FR Y-14A/Q/M 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-14A/Q/M 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).18 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
17

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-14A/Q/M reports.
18

9

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.”19 The obligation to file the
three FR Y-14A/Q/M reports is mandatory.
The information reported in the FR Y-14A/Q/M 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)).20
Consultation outside the Agency
There has been no consultation outside the Federal Reserve System with regard to the
FR Y-14A/Q/M revisions.
Estimate of Respondent Burden
As shown in the table below, the total annual burden for the FR Y-14A/Q/M is 803,476
hours and would not change as a result of these temporary revisions. These reporting
requirements represent approximately 8.2 percent of the Board’s total paperwork burden.

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-14A/Q/M reports. See 79 FR 17240, 17304 (March 27, 2014).
20
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).
19

10

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

Estimated
number of
respondents21
36
36
34
0
36
0
13

Estimated
Annual
average hours
frequency
per response
1
1,085
4
1,920
12
1,072
1
7,200
1
480
1
4,800
1
2,560

Estimated
annual burden
hours
39,060
276,480
437,376
0
17,280
0
33,280
803,476

The estimated total annual cost to the public for this collection of information is
$46,400,739.22
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 is $79,200 for one-time costs and
$2,677,200 for ongoing costs.

21

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.
22
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/.

11