FRY9_20200723_omb_emergency

Supporting Statement for the
Financial Statements for Holding Companies
(FR Y-9 Reports; 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 temporarily revised the
Financial Statements for Holding Companies (FR Y-9; OMB No. 7100-0128) pursuant to its
authority to approve temporarily a collection of information without providing opportunity for
public comment.1 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), any 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.2 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.
In response to recent economic disruptions and volatility in U.S. financial markets caused
by the spread of Coronavirus Disease 2019 (COVID-19), the Board temporarily revised the
FR Y-9C effective beginning with the June 30, 2020, as-of date. This supporting statement
describes temporary revisions to the FR Y-9C that were adopted in connection with three interim
final rules (IFRs) related to COVID-19 and the Coronavirus Aid, Relief, and Economic Security
Act (CARES Act). These temporary revisions to the FR Y-9C are consistent with recently
approved revisions to the Federal Financial Institutions Examination Council (FFIEC)
Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and
FFIEC 051; OMB No. 7100-0036). No revisions were made to the FR Y-9LP, FR Y-9SP,
FR Y-9ES, or FR Y-9CS.
The current estimated total annual burden for the FR Y-9 is 119,667 hours, and would
increase to 119,725. The temporary revisions resulted in an increase of 58 hours. The FR Y-9
forms and instructions are available on the Board’s public website at
http://www.federalreserve.gov/apps/reportforms/default.aspx.

1

5 CFR Part 1320, Appendix A (1)(a)(3)(i)(A).
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) a 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.
2

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,
conduct pre-inspection analysis, monitor and evaluate capital adequacy, evaluate mergers and
acquisitions, and analyze a HC’s overall financial condition to monitor the safety and soundness
of its operations. The information collected by the FR Y-9 report 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. 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. The
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 a given situation. For example, changes
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.
3

2

made by the Financial Accounting Standards Board may introduce into U.S. generally accepted
accounting principles 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.5
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; the FR Y-9LP panel consists
of each HC that files the FR Y-9C, as well as each of its subsidiary HCs; the FR Y-9SP panel
consists of HCs with total consolidated assets of less than $3 billion; the FR Y-9ES panel
consists of each employee stock ownership plan (ESOP) that is also an HC; and the FR Y-9CS
panel consists of any HC the Board selects.
Adopted Revisions
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.
Recent events have suddenly and significantly impacted financial markets. The spread of
COVID-19 has disrupted economic activity in many countries. In addition, U.S. financial
markets have experienced significant volatility. The magnitude and persistence of the overall
effects on the economy remain highly uncertain. In light of these developments, HCs may realize
a sudden, unanticipated drop in capital ratios and liquidity. This could create a strong incentive
for these HCs to limit their lending and other financial intermediation activities in order to avoid
facing abrupt regulatory capital and liquidity limitations. Also, small businesses are facing severe
liquidity constraints and a collapse in revenue streams resulting from COVID-19 situation.
Lastly, financial disruptions arising in connection with the COVID-19 situation have caused
many depositors to have a more urgent need for access to their funds by remote means,
particularly in light of the closure of many depository institution branches and other in person
facilities.
In April and May 2020, the Board, Federal Deposit Insurance Corporation (FDIC), and
Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued IFRs relating
5

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 relating to operational risk.

3

to the Community Bank Leverage Ratio6 and the Paycheck Protection Program Liquidity Facility
(PPPLF)7 to make changes to their regulatory capital and liquidity rules and to facilitate banking
organizations’ use of the Board’s emergency facility and support prudent lending by banking
organizations. Various provisions of the CARES Act led to the agencies issuing these IFRs. The
Paycheck Protection Program (PPP)8 implemented by the U.S. Small Business Administration
(SBA) and the PPPLF established by the Board were put in place to provide financing to small
businesses and liquidity to small business lenders to help stabilize the financial system in a time
of significant economic strain. The Board also issued an IFR to amend its Regulation D9 to allow
depository institution customers more convenient access to their funds. The IFRs were issued
with an immediate effective date. Finally, section 4013 of the CARES Act provided temporary
relief from the requirement to classify COVID-19 related loan modifications as Troubled Debt
Restructurings.
As described below, the Board has temporarily revised the FR Y-9C to account for the
three IFRs described above, as well as section 4013 of the CARES Act. The Board determined
that these revisions had to be instituted quickly and that public participation in the approval
process would have substantially interfered with the Board’s ability to perform its statutory
obligations.
Community Bank Leverage Ratio - Interim Final Rules
Section 4012 of the CARES Act required the appropriate Federal banking agencies to
reduce the community bank leverage ratio (CBLR) to 8 percent for a temporary period ending on
the earlier of the termination date of the national emergency concerning the coronavirus disease
COVID-19 outbreak declared by the President on March 13, 2020, under the National
Emergencies Act10 (National Emergency) or December 31, 2020, which the agencies did through
an interim final rule.11 To provide further clarity around the possible end date of the statutory
relief and provide a qualifying community banking organization that is planning to elect to use
the community bank leverage ratio framework sufficient time to meet the leverage ratio
requirement, the agencies also issued an interim final rule extending relief for the 8 percent
community bank leverage ratio through 2020, providing relief through an 8.5 percent community
bank leverage ratio in 2021, and resuming the existing 9 percent community bank leverage ratio
in 2022.12 Neither interim final rule changed the methodology for calculating the CBLR, merely
the qualifying ratio for an institution to report as a CBLR institution.
There are no substantive reporting revisions associated with the revised CBLR
framework. However, it is possible that some additional holding companies that are now eligible
CBLR institutions under the lower qualifying ratio may choose to use the less burdensome
reporting for regulatory capital on Schedule HC-R. Therefore the Board has temporarily revised
6

85 FR 22924 (April 23, 2020).
85 FR 20387 (April 13, 2020).
8
See 85 FR 20811 (April 15, 2020).
9
85 FR 23445 (April 28, 2020).
10
50 U.S.C. § 1601 et seq.
11
85 FR 22924 (April 23, 2020).
12
85 FR 22930 (April 23, 2020).
7

4

the FR Y-9C instructions to accurately reflect aspects of the statutory interim final rule and the
transition interim final rule. Since the CBLR framework only came into effect for purposes of
reporting for the first quarter of 2020, the Board currently does not have an accurate estimate of
the number of holding companies that elected to use the CBLR reporting for the first quarter of
2020. Similarly, the Board cannot reliably estimate the number of holding companies that might
use the CBLR reporting in the second quarter of 2020 under the reduced ratio at this time. The
Board plans to revise the burden estimates after more data is available on holding companies’
election to use the CBLR framework.
Regulatory Capital: Paycheck Protection Program Liquidity Facility (PPPLF) and
Paycheck Protection Program (PPP) Loans - Interim Final Rule and
CARES Act Section 1102
Section 1102 of the CARES Act allows banking organizations to make loans under a
program of the Small Business Administration (SBA) in connection with COVID-19 disruptions
to small businesses (referred to as PPP loans or PPP covered loans). While the loans are funded
by the banking organizations, they receive a guarantee from the SBA. The statute specified that
these loans should receive a zero percent risk weight for regulatory capital purposes. The Federal
Reserve subsequently established a liquidity facility to permit banking organizations to obtain
non-recourse loans, for which PPP loans are pledged to the facility, to provide additional
liquidity.
On April 13, 2020, the agencies published an interim final rule with an immediate
effective date, which permits banking organizations to exclude from regulatory capital
requirements PPP loans pledged to the PPPLF.13 The interim final rule modifies the agencies’
capital rule to allow banking organizations to neutralize the effects on their risk-based and
leverage capital ratios of making PPP loans that are pledged to the PPPLF. Specifically, a
banking organization may exclude from its total leverage exposure, average total consolidated
assets, standardized total risk-weighted assets, and advanced approaches total risk-weighted
assets, as applicable, any exposure from a PPP loan pledged to the PPPLF. The interim final rule
also codified the statutory zero percent risk weight for PPP loans; however, the PPP loans
already received a zero percent risk weight under the agencies’ existing capital rules as an
exposure directly and unconditionally guaranteed by an agency of the U.S. government. The
Board has temporarily revised the FR Y-9C instructions to reflect the changes made in this
interim final rule.
The Board needs to collect information on the number and outstanding balance of PPP
loans, as well as the outstanding balance and quarterly average of PPP loans pledged to the
liquidity facility, for their use in supervising holding companies. These items also would enable
Federal Reserve supervision staff to monitor credit and liquidity risk, aggregate industry trends,
and individual institutions’ use of the PPPLF. Therefore, the Board temporarily approved the
addition of four new data items to collect this information, with the collection of these items
expected to be time-limited.

13

85 FR 20387 (April 13, 2020).

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Starting with the June 30, 2020, reporting period, a holding company will report the total
number of PPP loans outstanding, the outstanding balance of PPP loans, the outstanding balance
of PPP loans pledged to the Federal Reserve’s liquidity facility, and the quarterly average
amount of PPP loans pledged to the Federal Reserve’s liquidity facility and excluded from
average total assets in the calculation of the leverage ratio. These items will tentatively be added
to Schedule HC-M, as items 25.a, 25.b, 25.c, and 25.d.
Also starting with the June 30, 2020, reporting period, the quarterly average amount of
PPP loans pledged to the liquidity facility and reported in 25.d would be reported as a deduction
in Schedule HC-R, part I, item 29, “LESS: Other deductions from (additions to) assets for
leverage ratio purposes,” and thus excluded from Schedule HC-R, Part I, item 30, “Total assets
for the leverage ratio.”
Since PPP loans, regardless of whether they are pledged to the liquidity facility, receive a
zero percent risk weight, they are effectively not included in the standardized total risk-weighted
assets. Similarly, advanced approaches holding companies would not reflect PPP loans in “Total
risk-weighted assets” reported on Schedule HC-R, Part I, item 46.a. HCs subject to the
supplementary leverage ratio requirement would report their adjusted “Supplementary leverage
ratio” in Schedule HC-R, Part I, items 53.
Regulation D Amendments - Interim Final Rule
The Board published in the Federal Register on April 28, 2020, an interim final rule that
amends the Board’s Regulation D (Reserve Requirements of Depository Institutions).14 The
interim final rule amends the six per month transfer limit in the “savings deposit” definition in
Regulation D. This interim final rule deleted a provision in the “savings deposit” definition that
required depository institutions either to prevent transfers and withdrawals in excess of the limit
or to monitor savings deposits ex post for violations of the limit. The interim final rule also
makes conforming changes to other definitions in Regulation D that refer to “savings deposit,” as
necessary.
The interim final rule allows depository institutions to immediately suspend enforcement
of the six transfer limit and to allow their customers to make an unlimited number of convenient
transfers and withdrawals from their savings deposits. The interim final rule permits, but does
not require, depository institutions to suspend enforcement of the six transfer limit. The interim
final rule also does not require any changes to the deposit reporting practices of depository
institutions.
The Board has temporarily revised the instructions to the FR Y-9C to reflect the revised
definition of “savings deposits” in accordance with the amendments to Regulation D in the
interim final rule. Specifically, the Board revised the General Instructions for Schedule HC-E,
Deposit Liabilities, and the Glossary entry for “Deposits” in the FR Y-9C instructions to remove
references to the six transfer limit. As a result of the amendments to Regulation D, if a holding
company chooses to suspend enforcement of the six transfer limit on a “savings deposit” the
14

85 FR 23445 (April 28, 2020).

6

holding company may continue to report that account as a “savings deposit” or may instead
choose to report that account as a “transaction account.”
In addition, certain reporting items on Schedule HC-E differentiate between transaction
accounts and nontransaction accounts, in part based on the definitions in Regulation D (including
the previous six transfer limit distinction). Specifically, the revised definition would apply to the
classification of deposits in Schedule HC-E, items 1.b, 1.c, 2.b and 2.c. Nevertheless, the Board
anticipates there will be no material change in burden resulting from these revisions to the
reporting of deposit accounts.
Section 4013 - Temporary Relief from Troubled Debt Restructurings
Section 4013 of the CARES Act suspends the requirements under United States generally
accepted accounting principles for eligible loan modifications related to the COVID-19
pandemic that would otherwise be categorized as troubled debt restructurings (TDRs). The
CARES Act defines an eligible loan under section 4013 (section 4013 loan) as a loan
modification that is (1) related to COVID-19, (2) executed on a loan that was not more than 30
days past due as of December 31, 2019, and (3) executed between March 1, 2020, and the earlier
of (A) 60 days after the date of termination of the National Emergency concerning the
COVID-19 outbreak or (B) December 31, 2020. Section 4013(d)(2) of the CARES Act provides
that federal banking agencies may collect data about section 4013 loans for supervisory
purposes.
Holding companies accounting for eligible loans under section 4013 are not required to
apply ASC Subtopic 310-40 to the section 4013 loans for the term of the loan modification. In
addition, HCs do not have to report section 4013 loans as TDRs in regulatory reports. However,
as provided for under section 4013, HCs should maintain records of the volume of section 4013
loans and the collection of data about such loans may be required for supervisory purposes.
Consistent with section 4013(d)(2) of the CARES Act, the Board has temporarily
approved the addition of two new data items to the FR Y-9C. These confidential items would
enable Federal Reserve supervision staff to monitor credit risk, aggregate industry trends, and
individual institutions’ use of the temporary relief provided by section 4013. These new items,
Memorandum item 16.a, “Number of Section 4013 loans outstanding,” and Memorandum item
16.b, “Outstanding balance of Section 4013 loans”, will be added to Schedule HC-C, Loans and
Lease Financing Receivables. Holding companies will be instructed to report the total number of
loans outstanding that have been modified under section 4013 in Memorandum item 16.a, and
the outstanding balance of these loans in Memorandum item 16.b, beginning as of the June 30,
2020, report date. Therefore, the Board temporarily approved the addition of four new data items
to collect this information, with the collection of these items expected to be time-limited.
The Board will collect institution-level section 4013 loan information on a confidential
basis. The Board has encouraged financial institutions to work with their borrowers during the

7

National Emergency related to COVID-19, including use of the relief under section 4013.15
However, the Board considers that public disclosure of supervisory information on section 4013
loans could have a detrimental impact on holding companies offering modifications under this
provision to borrowers that need relief due to COVID-19.
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 FFIEC website: https://www.ffiec.gov/NPW.
Legal Status
The Board has the authority to impose the reporting and recordkeeping requirements
associated with the FR Y-9 family of reports on bank holding companies pursuant to section 5 of
the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. § 1844); on savings and loan
holding companies 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 DoddFrank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act); on U.S. intermediate
holding companies 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);16 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
See “Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with
Customers Affected by the Coronavirus (Revised)” (April 7, 2020), available at https://www.occ.gov/newsissuances/news-releases/2020/nr-ia-2020-50a.pdf.
16
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. intermediate holding company is
treated as a bank holding company 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 bank holding companies,
section 5(c) provides additional authority to require U.S. intermediate holding companies to report the information
contained in the FR Y-9 series of reports.
15

8

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, Schedule HC’s memorandum item 2.b. and the
FR Y-9SP report, Schedule SC’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.
Additionally, items on the FR Y-9C, Schedule HC-C for loans modified under section
4013, data items Memorandum items 16.a, “Number of Section 4013 loans outstanding” and
Memorandum items 16.b, “Outstanding balance of Section 4013 loans” are considered
confidential. While the Board generally makes institution-level FR Y-9C report data publicly
available, the Board is collecting section 4013 loan information as part of condition reports for
the impacted HCs and the Board considers disclosure of these items at the HC level would not be
in the public interest.17 Such information is permitted to be collected on a confidential basis,
consistent with 5 U.S.C. § 552(b)(8). Exemption 8 of FOIA specifically exempts from disclosure
information “contained in or related to examination, operating, or condition reports prepared by,
on behalf of, or for the use of an agency responsible for the regulation or supervision of financial
institutions.” In addition, holding companies may be reluctant to offer modifications under
section 4013 if information on these modifications made by each holding company is publicly
available, as analysts, investors, and other users of public FR Y-9C report information may
penalize an institution for using the relief provided by the CARES Act. The Board may disclose
section 4013 loan data on an aggregated basis, consistent with confidentiality or as otherwise
required by law.

17

See 12 U.S.C. § 1464(v)(2).

9

Aside from the data items described above, the remaining data items 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-9CS18 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 work papers 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 coordinated and consulted with the FDIC and the OCC about the revisions to
the FR Y-9C.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-9 is 119,667
hours, and would increase to 119,725 hours with the temporary revisions. The Board estimates
that the revisions would increase the estimated average hours per response for FR Y-9C non AA
HCs filers by 0.03 hours and FR Y-9C AA HCs filers by 0.21 hours. These reporting and
recordkeeping requirements represent 1.3 percent of the Board’s total paperwork burden.

18

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)).

10

FR Y-9
Current
Reporting
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-9CS
Recordkeeping
FR Y-9C
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Current Total
Proposed
Reporting
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

Estimated
number of
respondents19

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

71

4

29.14

8,276

35

4

35.11

4,915

84

4

40.98

13,769

154
19
434
3,960
83
236

4
4
4
2
1
4

46.95
48.59
5.27
5.40
0.50
0.50

28,921
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
119,667

71

4

29.17

8,284

35

4

35.14

4,920

84

4

41.01

13,779

19

Of these respondents, 4 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.

11

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-9CS
Recordkeeping
FR Y-9C
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Proposed Total

154
19
434
3,960
83
236

4
4
4
2
1
4

46.98
48.80
5.27
5.40
0.50
0.50

28,940
3,709
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
119,725

Change

58

The estimated total annual cost to the public for the FR Y-9 is $6,910,769, and would
increase to $6,914,119 with the revisions.20
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 is $2,050,800.

20

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/.

12