FR2052a_20200731_omb_emergency

Supporting Statement for the
Complex Institution Liquidity Monitoring Report
(FR 2052a; OMB No. 7100-0361)
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
Complex Institution Liquidity Monitoring Report (FR 2052a; OMB No. 7100-0361) pursuant to
its authority to temporarily approve a collection of information without providing opportunity for
public comment.1 The FR 2052a collects quantitative information on select assets, liabilities,
funding activities, and contingent liabilities of certain large financial firms supervised by the
Board on a consolidated basis and by material legal entity. The Board uses this information to
monitor the liquidity profile of these financial institutions.
In response to significant economic disruptions caused by the coronavirus disease 2019
(COVID-19), the Board, pursuant to section 13(3) of the Federal Reserve Act, authorized the
establishment of the Money Market Mutual Fund Liquidity Facility (MMLF) and the Paycheck
Protection Program Liquidity Facility (PPPLF) to offer non-recourse, maturity-matched secured
loans to eligible borrowers. To neutralize the effect of transactions with these facilities under the
existing Liquidity Coverage Ratio (LCR) rule,2 the Office of the Comptroller of the Currency
(OCC), Federal Deposit Insurance Corporation (FDIC), and Board (collectively, the agencies)
published in the Federal Register an interagency interim final rule (LCR facilities interim final
rule),3 which described corresponding temporary revisions to the FR 2052a form and
instructions.
The estimated total annual burden for the FR 2052a is 917,440 hours, and did not change
as a result of the temporary revisions. The FR 2052a form and instructions are available on the
Board’s public website at https://www.federalreserve.gov/apps/reportforms/default.aspx.
Background and Justification
The data collected by the FR 2052a provide detailed information about the liquidity risks
within different business lines (e.g., financing of securities positions, prime brokerage activities)
of certain large financial firms supervised by the Board. In particular, these data serve as an
important part of the Board’s supervisory surveillance program in its liquidity risk management
area and provide timely information about firm-specific liquidity risks during periods of stress.
The Board uses analyses of systemic and idiosyncratic liquidity risk issues to inform its
supervisory processes, including the preparation of analytical reports that detail funding
vulnerabilities. FR 2052a data also contribute to the Board’s supervisory monitoring efforts and
risk supervision by identifying potential impediments to the movement of liquidity across legal
entities. In addition, the FR 2052a provides detailed information that the Board uses to monitor
compliance with its LCR rule. The collected information is not available from other sources.
1

See 5 CFR Part 1320, Appendix A (1)(a)(3)(A).
12 CFR Part 50 (OCC); 12 CFR Part 329 (FDIC), 12 CFR Part 249 (Board).
3
85 FR 26835 (May 6, 2020).
2

Description of Information Collection
The FR 2052a collects data regarding inflows, outflows, and supplemental items,
subdivided into 10 distinct data categories. These categories are designed to stratify the assets,
liabilities, and supplemental components of a firm’s liquidity risk profile based on products that
can be described with common data structures while maintaining a coherent framework for
liquidity risk reporting.
The FR 2052a data categories also cover broad funding classifications by product,
outstanding balance, and purpose, each segmented by maturity date. Generally, the data
categories are classified as follows:
• Inflows-Assets: Institutions report assets such as unencumbered assets, borrowing
capacity from central banks or Federal Home Loan Banks (FHLBs), unrestricted reserve
balances at central banks, restricted reserve balances at central banks, unsettled asset
purchases, and forward asset purchases.
• Inflows-Unsecured: Institutions report unsecured inflow transactions such as onshore
placements, offshore placements, required nostro balances, excess nostro balances,
outstanding draws on revolving facilities, and other unsecured loans.
• Inflows-Secured: Institutions report secured inflow transactions such as reverse
repurchase agreements, securities borrowing transactions, dollar rolls, collateral swaps,
margin loans, other secured loans where the collateral is rehypothecatable, and other
secured loans where the collateral is not rehypothecatable.
• Inflows-Other: Institutions report other inflow transactions such as derivatives
receivables, collateral called for receipt, sales in the to-be-announced market, undrawn
committed facilities purchased, lock-up balances, interest and dividends receivables, a net
30-day derivatives receivables measure, principal payments receivable on unencumbered
investment securities, and other inflow transactions.
• Outflows-Wholesale: Institutions report wholesale outflow transactions such as assetbacked commercial paper single-seller outflows, asset-back commercial paper multiseller outflows, collateralized commercial paper, asset-backed securities, covered bonds,
tender option bonds, other asset-backed financing, commercial paper, onshore borrowing,
offshore borrowing, unstructured long-term debt, structured long-term debt, government
supported debt, unsecured notes, structured notes, wholesale certificates of deposit, draws
on committed facilities, free credits, and other unsecured wholesale outflow transactions.
• Outflows-Secured: Institutions report secured outflow transactions such as repurchase
agreements, securities lending transactions, dollar rolls, collateral swaps, FHLB
advances, outstanding secured funding from facilities at central banks, customer short
transactions, firm short transactions, and other secured outflow transactions.
• Outflows-Deposits: Institutions report deposit outflow transactions such as transactional
accounts, non-transactional relationship accounts, non-transactional non-relationship
accounts, operational accounts, non-operational accounts, operational escrow accounts,
non-reciprocal brokered accounts, affiliated sweep accounts, non-affiliated sweeps
accounts, other product sweep accounts, reciprocal accounts, other third-party deposits,
and other deposit accounts.
• Outflows-Other: Institutions report other outflow transactions such as derivatives
payables, collateral called for delivery, purchases in the to-be-announced market, credit
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•

•

facilities, liquidity facilities, retail mortgage commitments, trade finance instruments,
potential derivative valuation changes, loss of rehypothecation rights and collateral
required due to changes in financial condition, excess customer margin, commitments to
lend on margin to customers, interest and dividends payables, a net 30-day derivatives
payables measure, other outflows related to structured transactions, and other cash
outflow transactions.
Supplemental-Informational: Institutions report supplemental information such as initial
margin posted and received, variation margin posted and received, collateral dispute
receivables and deliverables, collateral that may need to be delivered, collateral that the
institution could request to be received, collateral that could be substituted by the
institution or a counterparty, long and short market value of client assets, gross client
wires received and paid, subsidiary liquidity that cannot be transferred, Federal Reserve
Act section 23A capacity,4 outflows or inflows from closing out hedges early, and
potential outflows from non-structured or structured debt maturing beyond 30 days where
the institution is the primary market maker in that debt.
Supplemental-Foreign Exchange: Institutions report foreign exchange information such
as foreign exchange spot, forwards and futures, and swap transactions.

All U.S firms with total consolidated assets of $700 billion or more or with assets under
custody of $10 trillion or more, and all foreign banking organizations (FBOs) with combined
U.S. assets of $250 billion or more, report data elements denominated in major currencies, while
other data elements denominated in non-major currencies are converted into United States
dollars (USD) and flagged as converted. All other reporting entities report exclusively in USD by
flagging data as converted as appropriate. All entities that are required to comply with the LCR
rule are considered material entities for the purpose of FR 2052a reporting.
Respondent Panel
The FR 2052a is filed by (1) any top-tier U.S. bank holding company (BHC) with
$100 billion or more in total consolidated assets that is not a subsidiary of an FBO, (2) any toptier U.S. savings and loan holding company (SLHC) with $100 billion or more in total
consolidated assets that is subject to the LCR rule as a covered depository institution holding
company, and (3) any FBO, as defined by the Board’s Regulation K - International Banking
Operations,5 with combined U.S. assets of $100 billion or more.
Revisions to the FR 2052a
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 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
4

See 12 U.S.C. § 371c (limiting the aggregate amount of covered transactions between an insured depository
institution and its affiliates).
5
See 12 CFR 211.21(o).

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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.
Consistent with the purposes of the MMLF and PPPLF, and to reflect more accurately the
liquidity risks of participation in such facilities, the agencies published in the Federal Register
the LCR facilities interim final rule, which revised the LCR rule to facilitate eligible banking
organizations’ participation in the facilities and to ensure such participation receives consistent
and predictable treatment under the LCR rule. The LCR facilities interim final rule requires a
banking organization to neutralize the effect on its LCR of advances from the MMLF and
PPPLF. Specifically, the LCR facilities interim final rule excludes from banking organizations’
total net cash outflow amounts certain outflow amounts associated with borrowing from these
facilities and certain inflow amounts associated with collateral securing the borrowings.
The Board has temporarily revised the reporting form and instructions of the FR 2052a
effective May 6, 2020, to accurately reflect the regulatory amendments made by the LCR
facilities interim final rule. Specifically, the Board has added:
(1) the sub-product value of “Covered Federal Reserve Facility Funding” to the product
O.S.6: Exceptional Central Bank Operations and a corresponding instruction to exclude
balances reported under this sub-product from the pre-existing sub-product of “Federal
Reserve Bank”,
(2) a sentence to the “General Guidance” paragraphs under the I.U: Inflows-Unsecured and
I.S: Inflows-Secured headings: “Exclude assets that secure Covered Federal Reserve
Facility Funding”,
(3) a sentence to the definition of product I.O.6: Interest and Dividends Receivable: “Exclude
interest and dividends receivable on assets securing Covered Federal Reserve Facility
Funding”,
(4) a sentence to the definition of product O.O.19: Interest and Dividends Payable: “Exclude
interest payable on Covered Federal Reserve Facility Funding”, and
(5) a collateral class of “L-12” representing loans guaranteed by U.S. government agencies.
The Board has determined that these temporary revisions to the FR 2052a needed to be
instituted quickly and that public participation in the approval process would have defeated the
purpose of the collection of information, as delaying the revisions would interfere with the
Board’s ability to perform its statutory duties and would have caused public harm if firms were
unable to take full advantage of the emergency relief provided by the facilities in response to
significant financial industry disruptions caused by COVID-19.
Time Schedule for Information Collection
FR 2052a data is reported monthly by (1) U.S. bank holding companies and savings and
loan holding companies with $50 billion or more in total consolidated assets but less than $700
billion in total consolidated assets and less than $10 trillion in assets under custody and (2) FBOs
that are not identified as Large Institution Supervision Coordinating Committee (LISCC) firms
and have $50 billion or more in combined U.S. assets. Daily reporting is required for (1) U.S.
bank holding companies and savings and loan holding companies with $700 billion or more in
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total consolidated assets or $10 trillion or more in assets under custody and (2) FBOs identified
as LISCC firms. The revisions did not affect the time schedule of the FR 2052a. Consistent with
current supervisory authority and processes, during periods of stress the Federal Reserve may
temporarily request FR 2052a liquidity data from monthly filers on a more frequent basis.
Public Availability of Data
In general, data from the FR 2052a is confidential and is not publicly available. In limited
circumstances, aggregate data for multiple respondents, which does not reveal the identity of any
individual respondent, may be released.
Legal Status
The FR 2052a is authorized to be collected from BHCs pursuant to section 5(c) of the
Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. § 1844(c)); from FBOs pursuant to
section 8(a) of the International Banking Act of 1978 (IBA) (12 U.S.C. § 3106(a)); from certain
BHCs and FBOs pursuant to section 165 of the Dodd-Frank Wall Street Reform and Consumer
Protection Act (Dodd-Frank Act) (12 U.S.C. § 5365); and from SLHCs pursuant to section
10(b)(2) and (g) of the Home Owners’ Loan Act (HOLA) (12 U.S.C. § 1467a(b)(2) and (g)).
Section 5(c) of the BHC Act authorizes the Board to require BHCs to submit reports to the Board
regarding their financial condition, and section 8(a) of the IBA subjects FBOs to the provisions
of the BHC Act. Section 165 of the Dodd-Frank Act requires the Board to establish prudential
standards, including liquidity requirements, for certain BHCs and FBOs. Section 10(g) of HOLA
authorizes the Board to collect reports from SLHCs. The FR 2052a report is mandatory for
covered institutions.
The information required to be provided on the FR 2052a is collected as part of the
Board’s supervisory process. Accordingly, such information is afforded confidential treatment
under exemption 8 of the Freedom of Information Act (FOIA), which protects information from
disclosure that is contained in or related to the examination or supervision of a financial
institution (5 U.S.C. § 552(b)(8)). In addition, the information may also be kept confidential
under exemption 4 for the FOIA, which protects trade secrets or confidential commercial or
financial information (5 U.S.C. § 552(b)(4)). In limited circumstances, aggregate data for
multiple respondents, which does not reveal the identity of any individual respondent, may be
released.
Consultation Outside the Agency
The Board consulted with the OCC and FDIC in development of the LCR facilities
interim final rule, which included corresponding temporary revisions to the FR 2052a.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2052a is
917,440 hours, and is unchanged with the temporary revisions. These reporting requirements
represent approximately 9.96 percent of the Board’s total paperwork burden.
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Estimated
number of
respondents6
26
16

FR 2052a
Monthly
Daily
Total

Estimated
Annual
average hours
frequency
per response
12
120
250
220

Estimated
annual burden
hours
37,440
880,000
917,440

The estimated total annual cost to the public for this collection of information is
$52,982,160.7
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 will be $532,800.

6

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.
7
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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