FRY14_20200724_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
necessary in response to the coronavirus disease 2019 (COVID-19) pandemic. Specifically, the
Board has temporarily revised the FR Y-14A/Q/M reports to collect data pertaining related to
implementation of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act),4
including firms’ exposures to the Paycheck Protection Program (PPP),5 and Federal Reserve
lending facilties, such as the Main Street Lending Program (MSLP),6 that have been established
to support markets and the broader economy during the ongoing COVID-19 pandemic. The
Board has also temporarily revised the FR Y-14A/Q/M reports to require the submission of
FR Y-14Q, Schedule H (Wholesale) on a more frequent basis, and make other revisions to better
understand the potentially quickly evolving effects of the COVID-19 pandemic on bank
positions and the broader economy.
The current estimated total annual burden for the FR Y-14 reports is 803,476 hours and
would increase to 835,444 hours. The temporary revisions would result in an increase of 31,968
hours. The draft reporting 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)(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
Coronavirus Aid, Relief, and Economic Security Act, Pub. L. No. 116-136, 134 Stat. 281 (March 27, 2020).
5
See 85 FR 20387 (April 13, 2020).
6
https://www.federalreserve.gov/newsevents/pressreleases/monetary20200409a.htm.
2

Background and Justification
Section 165(i)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act)7 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).8 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.9 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.10 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.11
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.12 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.
7

Pub. L. No. 111-203, 124 Stat. 1376 (2010).
See 12 U.S.C. § 5365(i)(1).
9
See 12 U.S.C. § 5365(i)(2).
10
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.
11
See 12 CFR 252, subparts B, E, F, and O.
12
See 12 CFR 225.8.
8

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.13
 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.

13

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,14 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.
In response to the COVID-19 pandemic, the Board has temporarily revised the
FR Y-14A/Q/M reports to change the submission frequency of one FR Y-14Q schedule;
incorporate the reporting of loans in loss mitigation or forbearance programs, collect information
on firm activity associated with the PPP, MSLP, and other Federal Reserve lending facilities.
The revised submission frequency of FR Y-14Q, Schedule H (Wholesale) is effective beginning
with the report as of July 31, 2020. All other FR Y-14Q and FR Y-14M temporary revisions are
effective beginning with reports as of September 30, 2020. In addition, the FR Y-14Q
instructions specify that attestations are not required for non-quarter-end submissions, or for new
items temporarily added as part of this notice. The Board has determined that it must revise the
FR Y-14Q and FR Y-14M quickly and public participation in the approval process would defeat
the purpose of the collection of information, as delaying the revisions would result in the
14

Covered SLHCs with $100 billion or more in consolidated assets are required to file the FR Y-14Q and
FR Y-14M with 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

collection of inaccurate information and would interfere with the Board’s ability to perform its
statutory duties pursuant to section 165 of the Dodd-Frank Act.15 These temporary revisions
expire six months after the date of publication of the corresponding notice in the Federal
Register, unless extended by the Board (i.e., data associated with these temporary revisions are
only required to be submitted up to and including data as of December 31, 2020 - firms are not
required to continue to submit data associated with these temporary revisions for any as of dates
in 2021 without explicit reauthorization from the Board).
FR Y-14Q Reporting Frequency
Effective for data as of July 31, 2020, the Board has temporarily revised the submission
frequency of FR Y-14Q, Schedule H (Wholesale) from a quarterly basis to a monthly basis for
Category I-III firms. This schedule has month-end as-of dates and is due either 30 days after the
as of date, or seven days after the FR Y-9C submission date (i.e., at the same time as most of the
FR Y-14Q), depending on whether the as of date aligns with a quarter-end date. In order to
effectively understand and react to the potentially quickly evolving effects of the COVID-19
pandemic on bank positions and the broader economy, particularly with respect to corporate and
commercial real estate exposures, the Board needs the information on this schedule on a more
frequent basis. Note that Schedule H data submitted monthly may be used for supervisory
purposes including, but not limited to, stress testing. The Board has committed to reviewing the
continued need for monthly reporting of Schedule H in the future. In addition, the Board has
revised the FR Y-14Q instructions to indicate the Board may require submission of the
FR Y-14Q, or certain schedules or items on the FR Y-14Q, on a more frequent basis in times of
crisis.
Loans in Loss Mitigation or Forbearance Programs
As described in the Interagency Statement on Loan Modifications and Reporting for
Financial Institutions Working with Customers Affected by the Coronavirus Guidance,16 the
CARES Act, among other things, “creates a forbearance program for federally backed mortgage
loans, protects borrowers from negative credit reporting due to loan accommodations related to
the National Emergency, and provides financial institutions the option to temporarily suspend
certain requirements under U.S. generally accepted accounting principles (GAAP) related to
troubled debt restructurings (TDR) for a limited period of time to account for the effects of
COVID-19.” In the Guidance, the Board and other regulatory agencies encouraged financial
institutions to work prudently with borrowers who are or maybe unable to meet their contractual
payment obligations because of the effects of COVID-19. Because firms may hold a larger
number of loans in forbearance programs and loans with other loss mitigation circumstances
during the COVID-19 pandemic, the Board has temporarily revised certain FR Y-14Q and
FR Y-14M schedules to add fields and options to existing fields to collect information on loans
in forbearance programs and other loss mitigation circumstances.

15
16

12 U.S.C. § 5365.
https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200407a1.pdf.

5

FR Y-14Q, Schedule A (Retail)
In order to capture loss mitigation and forbearance loan balances, the Board has
temporarily added the “$ Loss mitigation and forbearance” summary variable to the six retail
schedules that do not currently to capture this information. Specifically, the summary variable
has been added to the following schedules:
 Schedule A.1 (International Auto Loan),
 Schedule A.3 (International Credit Card),
 Schedule A.4 (International Home Equity),
 Schedule A.5 (International First Lien Mortgage),
 Schedule A.6 (International Other Consumer Schedule), and
 Schedule A.7 (US Other Consumer).
Three retail schedules already have summary variables to capture information regarding
loss mitigation and modified loans. However, in order to be consistent across Schedule A, the
Board has temporarily replaced the following summary variables with the same “$ Loss
mitigation and forbearance” summary variable as described above:
 Schedule A.2 (US Auto Loan), Field #26 (“$ Loss mitigation”),
 Schedule A.8 (International Small Business), Field #6 (“$ Modifications”), and
 Schedule A.9 (US Small Business), Field #6 (“$ Modifications”).
FR Y-14Q, Schedule H (Wholesale)
The Board has temporarily added the “Modifications Flag” item to Schedules H.1
(Corporate) and H.2 (Commercial Real Estate) (items 109 and 70, respectively) to capture
information on loans in loss mitigation or forbearance programs because of the COVID-19
pandemic. Prior to this revision, it was not possible to identify loans in these programs on these
schedules. Loans in loss mitigation and forbearance programs have different risk characteristics
than other loans reported on this schedule, and therefore need to be separately identified.
FR Y-14Q, Schedule J (Retail Fair Value Option/Held for Sale (FVO/HFS))
The Board has temporarily added Column J (Loss Mitigation) to Schedule J to capture
information on FVO/HFS loans in loss mitigation programs. Loans in loss mitigation programs
have different risk characteristics than other loans reported on this schedule, and therefore need
to be separately identified.
FR Y-14M, Schedule B (Home Equity)
In order to capture information regarding loans in forbearance programs and for
consistency with the corresponding item on FR Y-14M, Schedule A (First Lien), the Board has
temporarily added an option (“9 = Forbearance plan”) to item 61 (“Workout Type Completed”).
PPP
On April 9, 2020, the Federal Reserve announced it would help facilitate the Small

6

Business Administration’s PPP by supplying liquidity to participating financial institutions
through term financing backed by PPP loans to small businesses.17 The PPP provides loans to
small businesses so that they can keep their workers on the payroll. The Paycheck Protection
Program Liquidity Facility (PPPLF) extends credit to eligible financial institutions that originate
PPP loans, taking the loans as collateral at face value.
FR Y-14Q, Schedule A (Retail)
In order to identify loans fully guaranteed by the U.S. government, such as loans
associated with the PPP, the Board has temporarily added the “$ Under federally guaranteed
programs” (item 13) summary variable to Schedule A.9 (US Small Business). This summary
variable is necessary as the credit risk characteristics of loans fully guaranteed under federal
programs differ from other loans reported on Schedule A.9, and therefore these loans need to be
reported separately from other small business exposures for appropriate evaluation during the
stress test.
FR Y-14Q, Schedule H
In response to questions received from the industry, the Board has temporarily revised the
instructions to Schedules H.1 and H.2 to explicitly exclude PPP loans. The Board does not need
information for PPP loans on these schedules.
FR Y-14Q, Schedule M (Balances)
The Board has temporarily added item 2.b.(1),“Paycheck Protection Program (PPP)
loans,” to Schedule M.1 (Quarter-end Balances), to capture the balance of PPP loans. The Board
has also temporarily added references to new item 2.b.(1) to Schedule M.2 (FR Y-9C
Reconciliation). In addition, the Board has temporarily added language to the instructions for
items 2.a, “Graded C&I loans,” and 2.b, “Small business loans,” requiring that PPP loans be
excluded from these items. PPP loans have different risk characteristics than non-guaranteed
loans, and therefore need to be separately identified.
MSLP
On April 9, 2020, the Board announced the MSLP, which will enhance support for small
and mid-sized businesses that were in good financial standing before the crisis by offering 4-year
loans to companies employing up to 10,000 workers or with revenues of less than $2.5 billion.18
Additionally, businesses with up to 15,000 employees or up to $5 billion in annual revenue are
now eligible, compared to the initial program terms, which were for companies with up to 10,000
employees and $2.5 billion in revenue.19 Principal and interest payments will be deferred for one
year. Under the MSLP, banks will retain a share of loans, selling the remaining share to the Main
Street facility.
17

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200409a.htm.
https://www.federalreserve.gov/newsevents/pressreleases/monetary20200409a.htm.
19
https://www.federalreserve.gov/newsevents/pressreleases/monetary20200430a.htm.
18

7

FR Y-14Q, Schedule A
The Board has temporarily added the following items to Schedule A.9: item 14, “$ Main
Street New Loan Facility (MSNLF),” item 15, “$ Main Street Priority Loan Facility (MSPLF),”
and item 16, “$ Main Street Expanded Loan Facility (MSELF).” MSLP loans have different risk
characteristics than other loans reported on this schedule, and therefore need to be separately
identified.
FR Y-14Q, Schedule H
The Board has temporarily added the “Extended Facility ID” item to Schedules H.1 and
H.2 (items 110 and 71, respectively). The Board has also temporarily added options to the
“Credit Facility Purpose” item on Schedule H.1 (item 25) and the “Loan Purpose” item on
Schedule H.2 (item 22) to capture information on MSLP loans. Specifically, the Board has
temporarily added the following options to both items: “MSLP New Loan Facility,” “MSLP
Expanded Loan Facility,” and “MSLP Priority Loan Facility.” MSLP loans have different risk
characteristics than other loans reported on these schedules, and so need to be separately
identified.
FR Y-14Q, Schedule K (Supplemental)
In order to capture MSLP loans that aren’t reported on FR Y-14Q, Schedules A and H,
the Board has temporarily added three columns to Schedule K: D.1, “Main Street Loan Program
New Loan Facility loans under $1M in committed balance,” D.2, Main Street Loan Program
Expanded Loan Facility loans under $1M in committed balance,” and D.3, Main Street Loan
Program Priority Loan Facility loans under $1M in committed balance.” In addition, the Board
has temporarily added language to the instructions for column D, “Outstanding Balance of
Commercial Real Estate (CRE) and Corporate loans under $1M in committed balance,” requiring
that firms exclude MSLP loans balances from this column.
Other Federal Reserve Lending Facilities
FR Y-14Q, Schedule B (Securities)
The Board has temporarily added an item (COVID-19 facility) to Schedule B.1 (Main
Schedule) to capture securities that have been pledged under a Federal Reserve facility that
supports the flow of credit during the COVID-19 pandemic (e.g., Money Market Mutual Fund
Liquidity Facility). This information is needed to determine the amount of protection provided
by the put option positions associated with these facilities.
FR Y-14Q, Schedule F (Trading)
The Board has temporarily created new submission types for Schedule F dedicated to
capturing information on trading assets that have been pledged to Federal Reserve lending
facilities. The submission type would mirror the other submission types of the trading schedule
and firms would complete the submission type in the same manner as for other submission types,

8

as outlined in the Schedule F instructions, unless otherwise indicated. This information is needed
to determine the amount of protection provided by the put option positions associated with these
facilities.
Other Revisions Related to the COVID-19 Pandemic
FR Y-14Q, Schedule D (Regulatory Capital)
In order to provide capital relief related to CECL to align with the purpose of the interim
CECL final rule and CARES Act, the Board has temporarily revised Schedule D to allow firms
to apply the CECL transition provisions to reported values.
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.20

April 5th.



Regulatory Capital
Instruments

December 31st.


20

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 distribution 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).

9

Schedules

Firm
Category

Data as-of
date
FR Y-14Q Filings

Frequency

Submission Date
to Board
For non quarter-end
month-ends (e.g., July):
By the 30th calendar day
after the last day of the
preceding calendar
month.

Category I-III

Monthly

Last day of
each calendar
month

Category IV

Quarterly

Quarter-end

Wholesale
Risk

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

All firms

Quarterly

Quarter-end

10

For quarter-end monthends (e.g., September):
Seven days after the
FR Y-9C reporting
schedule: Reported data
(47 days after the
calendar quarter-end for
March, June, and
September and 52 days
after the calendar
quarter-end for
December).
Seven days after the
FR Y-9C reporting
schedule: Reported data
(47 calendar days after
the calendar quarter-end
for March, June, and
September and 52
calendar days after the
calendar quarter-end for
December)
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).

Trading,
Counterparty

All firms

Fourth
Quarter:
GMS as-of
date for all
exposures
except
Trading FVO
Loan Hedges,
which should
be reported as
of calendar
quarter-end.

Quarterly

All Other:
Quarter-end

Fourth Quarter Trading and
Counterparty
regular/unstressed
submission: 52 calendar
days after the
notification date
(notifying respondents
of the as-of-date) or
March 15, whichever
comes earlier. Unless
the Board requires the
data to be provided
over a different weekly
period, BHCs, SLHCs,
and IHCs may provide
these data as-of the most
recent date that
corresponds to their
weekly internal risk
reporting cycle as long
as it falls before the asof-date.
Fourth quarter Counterparty stressed
GMS submission: April
5th
All other: 47 calendar
days after the calendar
quarter-end (Seven days
after the FR Y-9C
reporting schedule).

Schedules

All schedules

Data as-of date

Submission Date
to Board

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

Public Availability of Data
No data received through this information collection is made available to the public.

11

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.21 The Board has authority to require SLHCs 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 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).22 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.” 23 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)).24

21

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.
23
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).
24
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).
22

12

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 estimated total annual burden for the FR Y-14 is
803,476 hours, and would increase to 835,444 hours as a result of the temporary revisions. The
Board estimates that the revisions would increase the estimated average hours per response for
the FR Y-14Q by 222 hours. These reporting requirements represent approximately 9.1 percent
of the Board’s total paperwork burden.

13

Estimated
number of
respondents25

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

1,085
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

Proposed
FR Y-14A
FR Y-14Q26
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
2,142
1,072
7,200
480
4,800
2,560

39,060
308,448
437,376
0
17,280
0
33,280
835,444

Change

31,968

The estimated total annual cost to the public for this collection of information is currently
$46,400,739 and would increase to $48,246,891 with the temporary revisions.27
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
25

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.
26
Note that the FR Y-14Q, Schedule H (Wholeseale), is submitted 12 times a year. However, the rest of the
FR Y-14Q scheudles are only submitted 4 times a year.
27
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/.

14

OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System is $2,677,200 for ongoing costs.

15