FR2900_20200728_omb_emergency

FR2900_20200728_omb_emergency.pdf

Reports of Deposits

OMB: 7100-0087

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Supporting Statement for the
Reports of Deposits: Report of Transaction Accounts, Other Deposits, and Vault Cash,
Annual Report of Deposits and Reservable Liabilities,
Report of Foreign (Non-U.S.) Currency Deposits, and
Allocation of Low Reserve Tranche and Reservable Liabilities Exemption
(FR 2900, FR 2910a, FR 2915, and FR 2930; OMB No. 7100-0087)
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 Reports
of Deposits (OMB No. 7100-0087) pursuant to its authority to approve temporarily a collection
of information without providing opportunity for public comment.1 The Reports of Deposits
information collection comprises the following four reports:
• Report of Transaction Accounts, Other Deposits, and Vault Cash (FR 2900),
• Annual Report of Deposits and Reservable Liabilities (FR 2910a),
• Report of Foreign (Non-U.S.) Currency Deposits (FR 2915), and
• Allocation of Low Reserve Tranche and Reservable Liabilities Exemption (FR 2930).
The FR 2900 report is filed by depository institutions and is the primary source of data
used for the calculation of reserve requirements, and for the construction and analysis of the
monetary aggregates. The FR 2910a report is also filed by depository institutions and is used to
determine who must file the FR 2900. The FR 2915 report is filed by any FR 2900 reporter that
offers deposits denominated in foreign currencies at their U.S. offices; this report is used by the
Board in the constructon of the monetary aggregates. The FR 2930 report is filed by depository
institutions with offices (or groups of offices) in more than one state or Federal Reserve District
with data to be used in the calculation of reserve requirements.
In January 2019, the Federal Open Market Committee announced its intention to
implement monetary policy in an ample reserves regime.2 Reserve requirements do not play a
role in this operating framework. Accordingly, the Board announced that, effective March 26,
2020, reserve requirement ratios were reduced to zero percent.3 As a result of the elimination of
reserve requirements on all transaction accounts, the retention of a regulatory distinction in
Regulation D - Reserve Requirements of Depository Institutions (12 CFR Part 204) between
reservable “transaction accounts” and non-reservable “savings deposits” was no longer
necessary. In addition, in the Spring of 2020, financial disruptions arising in connection with the
1

5 CFR Part 1320, Appendix A (1)(a)(3)(i)(A).
See https://www.federalreserve.gov/newsevents/pressreleases/monetary20190130c.htm.
3
See https://www.federalreserve.gov/newsevents/pressreleases/monetary20200315b.htm; (85 FR 16525, March 24,
2020). Prior to the elimination of reserve requirements, depository institutions satisfied reserve requirements by
maintaining cash in their vault or, if vault cash was insufficient, by maintaining a balance in an account at a Federal
Reserve Bank. The amount that a depository institution had to maintain was known as the depository institution’s
reserve requirement. See 12 CFR 204.4 (computation of reserve requirements). The amount that a depository
institution had to maintain in an account at a Reserve Bank over and above the amount of its vault cash was known
as the depository institution’s reserve balance requirement. 12 CFR 204.2(ee) (definition of “reserve balance
requirement”).
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coronavirus disease 2019 (COVID-19) pandemic 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.
For the foregoing reasons, on April 28, 2020, the Board adopted an interim final rule
(Regulation D IFR) deleting the “six transfer limit” from the “savings deposit” definition in
Regulation D to allow depository institution customers more convenient access to their funds and
to simplify account administration for depository institutions.4 This supporting statement
describes temporary revisions to the FR 2900 and FR 2910a instructions that were adopted in
connection with the Regulation D IFR’s amendment to the definition of “savings deposit.” The
temporarily revisions are effective beginning with the April 27, 2020, as-of date for the FR 2900
weekly; June 22, 2020, as-of date for the FR 2900 quarterly; and June 30, 2020, as-of date for the
FR 2910a. The FR 2900 and FR 2910a instructions were revised to exclude any reference to a
numeric transfer or withdrawal limit from the definition of a “savings deposit.” As a result of the
revision, if a depository institution chooses to suspend enforcement of the six transfer limit on a
“savings deposit,” the depository institution may continue to report that account as a “savings
deposit” or may in some cases choose to report that account as a “transaction account.” No
changes have been made to the reporting forms or instructions related to the elimination of
reserve requirements; such changes will be proposed at a later date. No changes to the FR 2915
and FR 2930 reports are being made at this time.
The current estimated total annual burden for the FR 2900 reports is 129,594 hours. The
temporary revisions did not result in a change to the estimated burden hours. The forms and
instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/default.aspx.
Background and Justification
The Reports of Deposits are designed to implement the requirements of the Federal
Reserve Act, as amended by both the Monetary Control Act of 1980 (MCA)5 and the Garn-St
Germain Depository Institutions Act of 1982 (Garn-St Germain Act).6 The MCA requires
depository institutions that have transaction accounts or nonpersonal time deposits to maintain
reserves in ratios of between zero percent and fourteen percent, as established by the Board. In
implementing the MCA, the Board required quarterly instead of weekly deposit reporting for
depository institutions that have total transaction accounts, savings deposits, and small time
deposits below a certain amount (the nonexempt deposit cutoff). The Garn-St Germain Act
imposes a reserve requirement ratio of zero percent on a specific amount (the reserve
requirement exemption amount)7 of a depository institution’s total reservable liabilities
(transaction accounts, nonpersonal time deposits, and Eurocurrency liabilities) that are less than
or equal to that amount. The Garn-St Germain Act also requires that, consistent with the Board’s
responsibility to monitor and control the monetary and credit aggregates, depository institutions
which have a reserve requirement of zero percent be subject to less overall reporting
4

85 FR 23445 (April 28, 2020).
Pub. L. No. 96-221, 94 Stat. 132 (March 31, 1980).
6
Pub. L. No. 97-320, 96 Stat. 1469 (October 15, 1982).
7
See 84 FR 64705 (November 25, 2019) for a detailed description of the reserve requirement exemption amount.
5

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requirements than depository institutions which have a reserve requirement of greater than zero
percent. In 1990, the Board reduced the reserve requirement ratios applicable to nonpersonal
time deposits and Eurocurrency liabilities to zero percent. As discussed above, effective March
26, 2020, the Board reduced the reserve requirement ratios applicable to all transaction accounts
to zero percent, eliminating all reserve requirements.
Respondents submit completed deposit reports to their local Reserve Banks, which
collect and review the deposit data on a schedule that allows the Board to incorporate these
aggregate data in a timely manner into the production of public statistical releases and internal
reports.
Description of Information Collection
Report of Transaction Accounts, Other Deposits, and Vault Cash (FR 2900)
The FR 2900 report comprises 15 data items.8 Twelve data items are reported at a daily
frequency for a reporting week that begins on a Tuesday and ends the following Monday, and
reported either weekly or quarterly to the Federal Reserve Banks. The data are ultimately
reported to the Board via the Reserve Banks. These 12 data items are necessary for the
construction of the monetary aggregates. The remaining three data items—those that supply data
on the nontransaction components of total reservable liabilities—are submitted at an annual
frequency for use in indexing the exemption amount and low reserve tranche amount each year,9
as required by statute. The exemption amount, nonexempt deposit cutoff, and reduced reporting
limit are used to determine how frequently a depository institution must file the FR 2900.10
Respondent Panel and Frequency. Depository institutions (other than banking Edge
and agreement corporations and U.S. branches and agencies of foreign banks) with net
transaction accounts greater than the exemption amount and with a sum of total transaction
accounts, savings deposits, and small time deposits greater than or equal to the nonexempt
deposit cutoff, or with a sum of total transaction accounts, savings deposits, and small time
deposits greater than or equal to the reduced reporting limit, regardless of the amount of net
transaction accounts, will be required to submit the FR 2900 weekly. The weekly reporting
period for the 12 data items on the FR 2900 covers the seven-day period beginning each Tuesday
and ending the following Monday. Banking Edge and agreement corporations and U.S. branches
and agencies of foreign banks, regardless of size, must also submit the FR 2900 weekly.
Depository institutions that have net transaction accounts greater than the exemption
amount, and that have a sum of total transaction accounts, savings deposits, and small time
deposits less than the nonexempt deposit cutoff, are required to submit the FR 2900 once each
quarter, in March, June, September, and December.

8

Refer to the table in Appendix A for a list of the 15 data items on the FR 2900 reporting form.
See 84 FR 64705 (November 25, 2019) for a detailed description of the “exemption amount” and “low reserve
tranche amount”.
10
See id. (describing the “nonexempt deposit cutoff” and “reduced reporting limit”).
9

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The quarterly reporting period for the 12 daily items on the FR 2900 covers the sevenday period beginning on the third Tuesday of the reporting month and ending the following
Monday. All FR 2900 respondents submit the three annual data items on the FR 2900 report one
day each year as follows. FR 2900 weekly reporters should report their outstanding balance as of
close of business on June 30 each year while FR 2900 quarterly reporters should report their
outstanding balance as of close of business on Monday of June report week each year.
Annual Report of Deposits and Reservable Liabilities (FR 2910a)
Depository institutions with net transaction accounts less than or equal to the exemption
amount, total deposits greater than the exemption amount, and total transaction accounts, savings
deposits, and small time deposits below the reduced reporting limit are required to submit the
FR 2910a. This report is filed as of June 30 each year.
The FR 2910a reporting form collects three data items: total transaction accounts, savings
deposits, and small time deposits; reservable liabilities; and net transaction accounts. The first
data item, total transaction deposits, savings deposits, and small time deposits, is used to
determine whether an institution is exempt from reporting the FR 2900, and if not, the frequency
at which the institution must submit FR 2900 data (weekly or quarterly). The second data item,
reservable liabilities, is the sum of net transaction accounts, nonpersonal savings deposits, and
nonpersonal time deposits, regardless of maturity. Data on reservable liabilities are used for the
annual indexation of the exemption amount (as required by statute). The third data item, net
transaction accounts, comprises total transaction accounts less demand balances due from
depository institutions and cash items in process of collection. Data on net transaction accounts
are used in the annual indexation of the low reserve tranche (as required by statute) and are used
to determine whether an institution must file the FR 2900. In addition, these data are used in the
annual indexation of the nonexempt deposit cutoff and the reduced reporting limit.
Respondent Panel and Frequency. Any depository institution that does not submit
FR 2900 data and that has total deposits greater than the exemption amount on its December Call
Report must submit FR 2910a data the subsequent year.11 FR 2910a data are submitted annually.
Report of Foreign (Non-U.S.) Currency Deposits (FR 2915)
All FR 2900 respondents, both weekly and quarterly, that offer deposits denominated in
foreign currencies at their U.S. offices file the FR 2915 quarterly on the same reporting schedule
as quarterly FR 2900 respondents.
Respondent Panel and Frequency. The FR 2915 data are reported quarterly. The Board
determined that quarterly measures would suffice both for backing the data out of the monetary
aggregates as well as for monitoring the overall volume of the deposits.
11

Institutions are added to the FR 2910a reporting panel based on total deposits (not total transaction accounts,
savings deposits, and small time deposits), because nonpersonal savings and time deposits (a component of
FR 2910a data item 2, Reservable Liabilities) typically include some large time deposits. In addition, any institution
that does not submit a December Call Report, or whose Call Report is not readily available, must submit an
FR 2910a report.

4

Allocation of Low Reserve Tranche and Reservable Liabilities Exemption (FR 2930)
This report is used in the computation of reserve requirements. Specifically, the report
collects data from depository institutions on how they intend to allocate the reserve requirement
exemption amount and low reserve tranche amount, which are both used in the calculation of a
reserve requirement.
Respondent Panel and Frequency. The FR 2930 data are collected at least once a year
after the low reserve tranche and reservable liabilities exemption thresholds are adjusted toward
the end of each calendar year or upon the establishment of an office outside the home state or
Federal Reserve District. The data are required at least one week before the beginning of the
reserve computation period (a fourteen-day period beginning on Tuesday and ending two
Mondays thereafter) in which the revised allocations are to be effective. The FR 2930 reporting
panel consists of a single designated office from each family of U.S. branches and agencies of a
foreign bank, and a single designated office from each banking Edge or agreement corporation
that has offices located in more than one state or Federal Reserve District.
Revisions to the FR 2900 and FR 2910a
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 a notice in the
Federal Register seeking public comment.
In light of the elimination of reserve requirements on March 26 and the elimination of the
six-transfer limit on April 28, the Board temporarily revised the FR 2900 and FR 2910a
instructions to exclude any reference to a numeric transfer or withdrawal limit from the
definition of a savings deposit. The revision does not require any changes to the forms
themselves. The temporarily revisions are effective beginning with the April 27, 2020, as-of date
for the FR 2900 weekly; June 22, 2020, as-of date for the FR 2900 quarterly; and June 30, 2020,
as-of date for the FR 2910a.
As a result of the revision, if a depository institution chooses to suspend enforcement of
the six transfer limit on a “savings deposit,” the depository institution may continue to report that
account as a “savings deposit” or may in some cases choose to report that account as a
“transaction account.” The Board determined that this revision needed to be instituted quickly,
without first seeking public comment, in order to ensure that depository institutions would not be
required to continue reporting deposit data in a manner inconsistent with the amended definition
of a savings deposit in Regulation D.

5

Time Schedule for Information Collection
The FR 2900 weekly respondents submit daily data on a weekly basis for a reporting
week that begins on a Tuesday and ends on the following Monday. The FR 2900 quarterly
respondents submit seven days of daily data once a quarter for the week beginning the third
Tuesday of March, June, September, and December, and ending the following Monday.
FR 2910a respondents submit data annually as of the close of business on June 30 each
year. The FR 2915 respondents submit weekly average data for the week beginning the third
Tuesday of March, June, September, and December, and ending the following Monday. The
FR 2930 reporters submit data at least one week before the beginning of the reserve computation
period (a fourteen-day period beginning on Tuesday and ending two Mondays thereafter) in
which the requested allocations are to be effective.
Public Availability of Data
Aggregate data for deposits, reserves, or both are published in numerous publicly
available statistical releases: Aggregate Reserves of Depository Institutions and the Monetary
Base (H.3 statistical release), Money Stock Measures (H.6 statistical release), and Assets and
Liabilities of Commercial Banks in the United States (H.8 statistical release).
Legal Status
The FR 2900, FR 2915,12 and FR 293013 are authorized to be collected from depository
institutions (commercial banks, credit unions and savings and loan associations) pursuant to
section 11(a)(2) of the Federal Reserve Act (FRA) (12 U.S.C. § 248(a)(2)), from banking
agreement corporations pursuant to section 25(5) and (7) of the FRA (12 U.S.C. §§ 603 and
604a), from banking Edge corporations pursuant to section 25A(17) of the FRA (12 U.S.C. §
625), and from branches and agencies of foreign banks pursuant to section 7 of the International
Banking Act of 1978 (IBA). The FR 2910a report is authorized to be collected from insured or
eligible-to-make-application banks, from mutual or stock savings banks, from insured or
eligible-to-make-application building, savings and loan or homestead associations, and
cooperative banks, and from insured or eligible-to-make-application credit unions pursuant to
section 11(a)(2) of the FRA (12 U.S.C. § 248(a)(2)). The FR 2900, FR 2910a, FR 2915, and
FR 2930 reports are all mandatory.
The data collected on these reports are considered confidential commercial and financial
information, and respondents are assured that the data being collected will be treated as
confidential by the Federal Reserve (except to the extent that aggregate data, which does not
identify any individual institution, may be disclosed). Accordingly, the data collected on these
reports are considered confidential pursuant to exemption 4 of the Freedom of Information Act,

12

The FR 2915 report is collected from a subset of FR 2900 respondents (those that offer foreign currencydenominated deposits at their U.S. offices).
13
The FR 2930 report is collected from a subset of FR 2900 respondents in order to allocate the respondent’s low
reserve tranche and exemption amounts.

6

which protects confidential commercial or financial information from public disclosure (5 U.S.C.
§ 552(b)(4)).
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2900 reports is
129,594 hours, and is unchanged with the temporary revisions. These reporting requirements
represent approximately 1.41 percent of the Board’s total paperwork burden.
Estimated
number of
respondents14
949
5,453
2,941
122
93

FR 2900
FR 2900 (weekly)
FR 2900 (quarterly)
FR 2910a
FR 2915
FR 2930

Annual
frequency
52
4
1
4
1

Total

Estimated
average hours
per response
1.25
3
0.75
0.5
0.25

Estimated
annual burden
hours
61,685
65,436
2,206
244
23
129,594

The estimated total annual cost to the public for these collections of information is
$7,484,054.15
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 the
FR 2900 reports is $4,935,600 per year.
14

Of these respondents, 258 for the FR 2900 (weekly), 4,291 for the FR 2900 (quarterly), 2,907 for the FR 2910a,
10 for the FR 2915, and 31 for the FR 2930 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.
15
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/.

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Appendix A
Uses of FR 2900 Data Items
The following table summarizes the current uses of each data item on the FR 2900. As
shown in the table, the separate reporting of various deposit categories is needed because of the
different treatment of particular data items in the definitions of reservable liabilities or monetary
aggregates.
Current Uses of each FR 2900 Data Item

Data Item
A. Transaction accounts:

Construction
of monetary
aggregates1

Comment

1. Demand Deposits:
a. Due to depository
institutions

n.a.

Not included in the monetary aggregates.

b. Of U.S. government

n.a.

Not included in the monetary aggregates, but
published as a memorandum item on the H.6.

c. Other demand

M1

Monetary aggregates. For banks, other demand
(data item A.l.c) is used to calculate the demand
deposits adjusted component of M1, which is
published on the H.6. For thrifts, this item is a
component of other checkable deposits.

2. ATS accounts and NOW
accounts/share drafts,
and telephone and
preauthorized transfers

3. Total transaction
accounts

M1/M2

n.a.

Monetary aggregates. ATS and NOW accounts
(data item A.2) are included in the other checkable
deposits component of M1, while telephone and
preauthorized transfer accounts are included in M2.
With all three types of accounts submitted as a
single total on the FR 2900, the Board estimates
the amount of telephone and preauthorized transfer
accounts to be subtracted from that total and
included in M2.
Reserve calculations. Total transaction accounts
(data item A.3) must equal the sum of data items
A.1 through A.2 above.

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Construction
of monetary
Data Item
aggregates1
B. Deductions from transaction accounts:

Comment

1. Demand balances due
from depository
institutions in the U.S.

n.a.

Not included in the monetary aggregates.

2. Cash items in process of
collection

M1

Monetary aggregates. Cash items in process of
collection (data item B.2) are deducted from other
demand deposits in calculating the demand
deposits adjusted component of M1 for banks and
the other checkable deposits component of M1 for
thrifts.

C.1 Total savings deposits
(including MMDAs)

M2

Monetary aggregates. Savings deposits are a major
component of M2.

D.1

Total time deposits

M22

E.1

Vault cash

M1

Monetary aggregates. Small-denomination time
deposits (those in amounts less than $100,000) are
calculated by subtracting memorandum item F.1,
large time deposits, from total time deposits (Item
D.1).
Monetary aggregates. Vault cash is deducted from
currency in circulation to arrive at the currency
component of M1.
Reserve aggregates. Vault cash is used to meet
reserve requirements. The amount used is applied
vault cash.

F. Memorandum Item:
1. All time deposits with
balances of $100,000 or
more (included in Item
D.1 above)

M22

Monetary aggregates. See comments for item D.1
above.
Also used in the construction of the Board’s
weekly H.8 statistical release, Assets and
Liabilities of Commercial Banks in the United
States.

9

Schedule AA:
1. Ineligible acceptances
and obligations issued
by affiliates maturing in
less than 7 days

n.a.

Reserve calculations. A depository institution is
required to maintain reserves against ineligible
acceptances and certain obligations issued by a
nondepository affiliate if the proceeds of such
obligations are channeled to the depository
institution. These obligations are not direct
obligations of the depository institution but are
reservable obligations under Regulation D.

Schedule BB: Nonpersonal data items
1. Total nonpersonal
savings and time
deposits (included in
Items C.1 and D.1
above)

n.a.

A component of total reservable liabilities, used
in the annual indexation of the exemption
amount. (Annual indexation of the exemption
amount is required by statute.)

2. Ineligible acceptances
and obligations issued
by affiliates maturing
in 7 days or more
(nonpersonal only)
Schedule CC:

n.a.

A component of total reservable liabilities that is
used in the annual indexation of the exemption
amount. (Annual indexation of the exemption
amount is required by statute.)

1. Net Eurocurrency
liabilities

n.a.

A component of total reservable liabilities that is
used in the annual indexation of the exemption
amount. (Annual indexation of the exemption
amount is required by statute.)

Notes to Table:
1. For additional information on the monetary aggregates, please see the H.6 statistical release.
2. As of March 23, 2006, the Board ceased construction and publication of M3. Given that daily
data on small denomination time deposits (the difference between total time deposits and large
time deposits) are necessary for use in constructing the M2 monetary aggregate, the Board has
determined that it is least burdensome for depository institutions to continue to collect total and
large time deposit data on the FR 2900 reporting form.

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