FRY14_20201103_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 became 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 to conduct stressed analyses in connection with the resubmission of firms’ capital
plans, including consideration of the global market shock (GMS) component, using data as of
June 30, 2020.
The current estimated total annual burden for the FR Y-14 reports is 838,216 hours, and
would increase to 858,799 hours. The temporary would result in an increase of 20,583 hours.
The draft reporting forms and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/review.aspx.
Background and Justification
Section 165(i)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act)4 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).5 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.6 On May 24, 2018, the Economic Growth,
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
Pub. L. No. 111-203, 124 Stat. 1376 (2010).
5
See 12 U.S.C. § 5365(i)(1).
6
See 12 U.S.C. § 5365(i)(2).
2

Regulatory Relief, and Consumer Protection Act (EGRRCPA) amended sections 165(i)(1) and
(2) of the Dodd-Frank Act, among other changes.7 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.8
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.9 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.
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.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.
8
See 12 CFR 252, Subparts B, E, F, and O.
9
See 12 CFR 225.8.
10
In certain circumstances, a BHC or IHC may be required to re-submit its capital plan. See 12 CFR 225.8(e)(4).
7

2




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.
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,11 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
Firms that must re-submit their capital plan generally also must provide a revised FR Y-14A in connection with their
resubmission.
11
Covered SLHCs with $100 billion or more in consolidated assets are not required to file the FR Y-14Q and
FR Y-14M until the reports with the June 30, 2020, as of date, and are not required to file the FR Y-14A until the
report with the December 31, 2021, as of date.

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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.
On June 25, 2020, the Board notified certain large firms that they would be required to
resubmit and update their capital plans later this year and announced12 that it will conduct
additional analysis in connection with that resubmission as economic conditions evolve. The
Board has decided to conduct this additional analysis using data as of June 30, 2020. This
additional analysis will enable the Board to ensure that firms subject to the stress test are
adequately capitalized and able to withstand the economic effects of COVID-19. This additional
analysis will include GMS and largest counterparty default (LCPD) components.
Additional FR Y-14A Submission
The Board uses data collected on the FR Y-14A/Q/M reports to conduct its CCAR and
DFAST exercises. The FR Y-14Q and FR Y-14M are currently submitted for the June 30, 2020,
as-of date. However, the FR Y-14A is currently only submitted for the fourth quarter of a given
year. In order for the Board to conduct additional analysis using data as of June 30, 2020, the
Board has required firms to submit FR Y-14A data as of June 30, 2020. Specifically, firms
subject to Category I-III standards13 are required to submit the entire FR Y-14A report, while
firms subject to Category IV standards14 are required to submit FR Y-14A, Schedule C
(Regulatory Capital Instruments).15
12

See https://www.federalreserve.gov/publications/files/2020-sensitivity-analysis-20200625.pdf.
Category I standards apply to firms that qualify as U.S. GSIBs. Category II standards apply to firms with $700
billion or more in assets, or firms with $75 billion or more in cross-jurisdictional activity and $100 billion or more in
assets, that do not qualify as U.S. GSIBs. Category III standards apply to firms with $250 billion or more in assets,
or firms with $100 billion or more in assets and at least $75 billion in (1) nonbank assets, (2) weighted short-term
wholesale funding, or (3) off-balance sheet exposure, that are not subject to Category I or II standards.
14
Category IV standards apply to firms with $100 billion or more in total consolidated assets that do not meet the
criteria for Categories I, II or III.
15
The FR Y-14A submission as of June 30, 2020, would include certain revisions to the FR Y-14A, Schedules
A.1.c.1 (Standardized RWA) and A.1.d (Capital) that allow eligible firms to incorporate the effects of the tailoring
13

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Global Market Shock (GMS)
The GMS is a set of hypothetical shocks to a large set of risk factors reflecting general
market distress and heightened uncertainty. Firms with significant trading activity must consider
the global market shock as part of their supervisory severely adverse scenario, and recognize
associated losses in the first quarter of the planning period.16 In addition, certain large and highly
interconnected firms must apply the same GMS to project losses under the counterparty default
scenario component. The global market shock is applied to asset positions held by the firms on a
given as of date. These shocks do not represent a forecast of the Federal Reserve.
The design and specification of the global market shock differ from that of the
macroeconomic scenarios for several reasons. First, profits and losses from trading and
counterparty credit are measured in mark-to-market terms, while revenues and losses from
traditional banking are generally measured using the accrual method. Another key difference is
the timing of loss recognition. The GMS affects the mark-to-market value of trading positions
and counterparty credit losses in the first quarter of the projection horizon. This timing is based
on an observation that market dislocations can happen rapidly and unpredictably any time under
stress conditions.
Typically, the GMS is applicable only to FR Y-14 data associated with the fourth quarter
submission of a given year. However, the Board has required firms subject to the GMS
component to submit the stressed data portion of FR Y-14Q, Schedule L (Counterparty), as well
as to incorporate the GMS component into their FR Y-14A submissions, for data as of June 30,
2020, so that the Board can conduct additional analysis (i.e., June 30, 2020, is the GMS as of
date).
Largest Counterparty Default (LCPD)
The Board has required certain firms17 to incorporate a LCPD component in the severely
adverse scenario used for the additional analysis that are conducted using data as of June 30,
2020. The LCPD component is intended to assess the potential losses and capital impact
associated with the default of each applicable firm’s largest counterparty. The Board will include
a substantially similar largest counterparty default scenario component in its additional analysis
for each firm in the severely adverse scenario.

rule, the capital simplifications rule, and the standardized approach for counterparty credit risk (SA-CCR). See
84 FR 59230 (November 1, 2019) (tailoring rule); 84 FR 35234 (July 22, 2019) (capital simplifications rule);
85 FR 4362 (January 24, 2020) (SA-CCR). These revisions also include the removal of FR Y-14A, Schedules
A.1.c.2 (Advanced RWA) and A.7.c (PPNR Metrics), and were recently adopted by the Board.
16
The global market shock component applies to a firm that is subject to the supervisory stress test and that has
aggregate trading assets and liabilities of $50 billion or more, or aggregate trading assets and liabilities equal to 10
percent or more of total consolidated assets, and is not a large and noncomplex firm under the Board’s capital plan
rule (12 CFR 225.8).
17
Bank of America Corporation, The Bank of New York Mellon, Barclays US LLC, Citigroup Inc., Credit Suisse
Holding (USA), DB USA Corporation, The Goldman Sachs Group, Inc., HSBC North American Holdings Inc.,
JPMorgan Chase & Co., Morgan Stanley, State Street Corporation, UBS Americas Holdings LLC, and Wells Fargo
& Company.

5

The counterparty default scenario component will allow the Board and each firm to
evaluate whether the firm has sufficient capital to withstand the default of its largest
counterparty. The counterparty default scenario component will account for the possibility that a
firm experiences counterparty losses from certain activities that are not captured in supervisory
macroeconomic scenarios. Generally, firms are subject to the counterparty default scenario
component in addition to the GMS.
The counterparty default scenario component must be treated as an add-on to the
macroeconomic environment specified in the severely adverse scenario. Any potential losses
from the counterparty default scenario component must be assumed to occur instantaneously and
must be included in projected losses for the first quarter of the planning horizon. The largest total
net stressed loss amount associated with a single counterparty default must be reported as the
loss associated with the counterparty default scenario component.
The counterparty default scenario component for the additional analysis using data as of
June 30, 2020, is generally similar to the component provided for the stress test cycle that began
on January 1, 2020. It requires each firm to assume an instantaneous and unexpected default of
its largest counterparty, where the largest counterparty is identified based on net stressed losses.
In selecting its largest counterparty, each firm is required to not consider certain sovereign
entities (Canada, France, Germany, Italy, Japan, the United Kingdom, and the United States) or
qualifying central counterparties (QCCP).18 For an IHC, affiliates, as defined by 12 CFR
252.71(b), are also excluded from the selection of a firm’s largest counterparty. Furthermore,
each firm is required to aggregate net stressed losses across securities lending and repurchase
agreement (collectively, Securities Financing Transactions, or SFT)19 activities and derivatives
for each counterparty.20
In selecting the largest counterparty, each firm is required to aggregate net stressed losses
across SFT activities and derivatives for each counterparty, taking into account close-out netting
agreements in place for the derivatives and SFT activities with each legal entity of that
counterparty. For SFT and derivatives transactions where a netting agreement is legally
enforceable in the jurisdiction where the counterparty legal entity is located, a firm is authorized
to assume close-out netting such that estimated losses reflects the difference between the stressed
value of securities or cash transferred to the counterparty legal entity and the stressed value of
securities or cash received from the same counterparty legal entity, within each master netting
agreement. For SFT activities, each firm is required to include potential losses associated with
acting as a principal as well as potential losses that could result from transactions where each
firm is acting as an agent but provides borrower-default indemnification in the event of a
counterparty default.

18

Any state-owned enterprise backed by the full faith and credit of an excluded sovereign entity should
also be excluded. See definition of QCCP at 12 CFR 217.2.
19
SFT activities subject to the counterparty default scenario component include repurchase agreements, reverse
repurchase agreements, securities lending, and securities borrowing.
20
All exposures within a consolidated organization, including to any subsidiaries and related companies, will
be treated as exposures to a single counterparty. However, losses should first be computed at the subsidiary or
related company level, accounting for legal netting agreements at that level, and then aggregated to the
consolidated organization.

6

In estimating net stressed losses of a counterparty, each firm is required to revalue its
exposures and collateral (securities or cash) using the hypothetical GMS scenario. Certain large
and highly interconnected firms not subject to the GMS component must also apply the same
global market shock to project losses under the counterparty default scenario component. Each
firm must apply the global market shock to stress the current exposure, collateral, and value of
derivatives-related transactions. Each firm must assume a recovery rate that the firm views as
appropriate, based on its own internal analysis, for purposes of the counterparty default scenario
component in the severely adverse scenario used in its additional analysis. A firm should not
assume any additional recovery in subsequent quarters of the planning horizon. Reinvestment of
collateral should be included to the extent that the reinvested collateral is part of another SFT
agreement.
The total net stressed losses should be calculated as follows: First, firms should compute
the total stressed net current exposure (Total Stressed Net CE), as defined in the instructions for
FR Y-14Q, Schedule L (Counterparty). “Total Stressed Net CE” represents the stressed current
exposures to a counterparty after applying the GMS to any derivatives and SFT assets
(securities/collateral) exchanged under repo-style transactions, as defined in section 2 of 12 CFR
Part 217, associated with the counterparty after taking all applicable netting agreements into
account. Next, firms should subtract the notional amount of any single-name Credit Default
Swap (CDS) hedges.21 Exclude from the trading book stress results the mark-to-market gain
related to these single-name CDS hedges. Then, firms should multiply the result by one minus
the recovery rate. Finally, firms should subtract the stressed Credit Value Adjustment (CVA)
attributed to the counterparty.22
The LCPD component is generally only applicable to FR Y-14 data associated with the
fourth quarter submission of a given year. However, in order to be able to conduct additional
analysis, the Board has required firms subject to the LCPD component to incorporate the LCPD
component into their FR Y-14A submissions for data as of June 30, 2020 (i.e., June 30, 2020, is
the LCPD as of date).
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.

21

When reporting gains associated with CVA hedges on Trading Schedule A.4 of the FR Y-l4A for all
counterparties, firm s are instructed to exclude gains from name-specific credit default swaps associated with
the counterparty default scenario component.
22
This is to reflect the fact that stressed CVA loss and baseline CVA are already incorporated in the FR Y-14A
Summary Schedule and the firm's balance sheet, respectively.

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Schedules and
Sub-schedules

Summary,
Macro Scenario,
Operational Risk, and
Business Plan Changes
CCAR Market Shock
exercise
Summary schedule
 Trading Risk
 Counterparty

Regulatory Capital
Instruments

Submission Date
to Board

Data as of date

FR Y-14A (Annual Filings)
April 5th of the following year for data as of
st
December 31 of December 31st of a given year, 45 calendar
a given year and
days following the publication of the scenarios
June 30, 2020.
for data as of June 30, 2020, or, if required,
upon resubmission of a firm’s capital plan.
A specified date
in the first quarter April 5th of the following year for data as of
of a given year
December 31st of a given year, 45 calendar
that would be
days following the publication of the scenarios
communicated by for data as of June 30, 2020, or, if required,
the Board,23 and
upon resubmission of a firm’s capital plan.
June 30, 2020.
For data as of December 31st of a given year:
 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.
December 31st of  Incremental submission: Within 15 days
a given year, and
after making any capital distribution in
June 30, 2020.
excess of those included in a firm’s capital
plan (see 12 CFR 225.8(k)).
For data as of June 30, 2020:
 45 calendar days following the publication
of the scenarios
Upon resubmission of a firm’s capital plan:
 As required.

23

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).

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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

9

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 as
of date.
Fourth quarter Counterparty stressed
GMS submission: April
5th.
June 30, 2020 Counterparty stressed
GMS submission: 45
calendar days following
the publication of the
scenarios.
All other: 47 calendar
days after the calendar
quarter-end (Seven days
after the FR Y-9C
reporting schedule).
Upon resubmission of a
firm’s capital plan Counterparty stressed
GMS submission: as

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required.
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 this information collection is made available to the public.
Legal Status
The Board has the authority to require BHCs 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.24 The Board has authority to require SLHCs file the FR Y-14
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-14 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 5365.25 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.”26 The obligation to file the three
FR Y-14 reports is mandatory.
The information reported in the FR Y-14 reports is collected as part of the Board’s
supervisory process, and therefore, such information is afforded confidential treatment pursuant
24

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-14 reports.
26
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-14 reports. See 79 FR 17240, 17304 (March 27, 2014).
25

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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)).27
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System with regard to the
FR Y-14A/Q/M temporary revisions.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-14 is
838,216 hours, and would increase to 858,799 hours as a result of these temporary revisions.
These reporting requirements represent approximately 9.3 percent of the Board’s total paperwork
burden.

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. 7100-0380).
27

12

Estimated
number of
respondents28

FR Y-14
Current
FR Y-14A
FR Y-14Q29
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Current Total
Proposed
FR Y-14A
FR Y-14Q30
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
One-time June 30, 2020,
submission31
Proposed Total

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

36
36
34
0
36
0
13

1
4
12
1
1
1
1

926
2,201
1,072
7,200
480
4,800
2,560

33,336
316,944
437,376
0
17,280
0
33,280
838,216

36
36
34
0
36
0
13

1
4
12
1
1
1
1

926
2,201
1,072
7,200
480
4,800
2,560

33,336
316,944
437,376
0
17,280
0
33,280

36

1

Change

571.75

20,583
858,799
20,583

28

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.
29
Note that FR Y-14Q, Schedule H (Wholesale), is submitted 12 times a year by firms subject to Category I-III
standards. However, the rest of the FR Y-14Q schedules are only submitted 4 times a year.
30
Note that for firms subject to Category I-III standards, FR Y-14Q, Schedule H (Wholesale), is submitted 12 times
a year and the stressed counterparty data on FR Y-14Q, Schedule L (Counterparty) is submitted twice a year.
However, the rest of the FR Y-14Q schedules are only submitted 4 times a year.
31
This burden estimate assumes firms subject to Category I-III standards would submit the entire FR Y-14A report,
firms subject to Category IV standards would submit FR Y-14A, Schedule C (Regulatory Capital Instruments), and
firms subject to GMS would submit stressed data on FR Y-14Q, Schedule L (Counterparty).

13

The estimated total annual cost to the public for this collection of information is currently
$48,406,974 and would increase to $49,595,642 with the proposed revisions.32
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System is $2,677,200 for ongoing costs.

32

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