FFIEC101_20201125_omb

Supporting Statement for the
Regulatory Capital Reporting for Institutions Subject to the
Advanced Capital Adequacy Framework
(FFIEC 101; OMB No. 7100-0319)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Regulatory Capital Reporting for
Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101; OMB No.
7100-0319). The FFIEC 101 collects data regarding the levels and components of risk-based
capital from firms subject to the Board’s advanced approaches capital framework (advanced
approaches framework), as well as data regarding the supplementary leverage ratio (SLR) from
firms subject to that requirement. The FFIEC 101 must be filed quarterly by certain large or
internationally active state member banks (SMBs), bank holding companies (BHCs), savings and
loan holding companies (SLHCs) that are subject to the advanced approaches framework and
other Board-regulated institutions that adopt the framework on a voluntary basis (collectively,
advanced approaches banking organizations); additionally, certain BHCs, SLHCs, SMBs, and
U.S. intermediate holding companies (IHCs) that are not advanced approaches banking
organizations must report only certain information regarding the SLR. The revisions to the
FFIEC 101 that are the subject of this request have been approved by the FFIEC. The Federal
Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC)
(together with the Board, the agencies) have also submitted similar requests for OMB review to
request this information from banks under their supervision.
The agencies propose to revise the FFIEC 101 related to interim final rules and a final
rule issued in response to disruptions related to the Coronavirus Disease 2019 (COVID-19) that
revise the agencies’ capital rule, as well as a certain section of the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act) for which the agencies received emergency approvals
from OMB. The agencies also propose revisions to the FFIEC 101 that would implement various
changes to the agencies’ capital rule that the agencies have finalized or are considering
finalizing. The proposed reporting revisions resulted from the final total loss absorbing capacity
(TLAC) investments rule.
The current estimated total annual burden for the FFIEC 101 is 35,288 hours, and would
not change with the proposed revision. The forms and instructions are available on the FFIEC’s
public website at https://www.ffiec.gov/ffiec_report_forms.htm.
Background and Justification
A number of federal laws require the Board to establish capital requirements for entities it
supervises.1 The Board’s current risk-based and leverage capital standards are codified in the
1

Section 171 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires the Board to establish
minimum risk-based and leverage capital requirements on a consolidated basis for the insured depository

Board’s Regulation Q - Capital Adequacy of Bank Holding Companies, Savings and Loan
Holding Companies, and State Member Banks (12 CFR Part 217). The Board’s risk-based capital
standards include an advanced approaches capital framework for large and internationally active
banking organizations. Banking organizations that use this framework report information related
to their risk-based capital requirements using the FFIEC 101.
With respect to the advanced approaches framework, the Board uses the data reported on
the FFIEC 101 to:
 Assess the components of each advanced approaches banking organization’s risk-based
capital requirements,
 Assess each advanced approaches banking organization’s capital relative to inherent risks
and the Board’s minimum capital requirements,
 Assess the components of each advanced approaches banking organization and top-tier
Category III BHCs, SHCs, and SMBs, and all Category III IHCs of its SLR. The SLR is
the ratio of tier 1 capital to total leverage exposure, as defined in the regulatory capital
rule,
 Monitor the levels and components of the risk-based capital requirements for advanced
approaches banking organizations through peer, outlier, and risk trend analyses,
 Evaluate the quantitative impact and competitive implications of the implementation of
the framework on risk-based capital levels within advanced approaches banking
organizations and on an overall industry basis,
 Ensure that the advanced approaches framework is implemented in the United States in a
safe and sound manner,
 Provide market participants, depositors, the public, supervisors, and other interested
parties with information about advanced approaches banking organizations’ risk-based
capital, and
 Supplement on-site examination processes and decisions pertaining to the allocation of
supervisory resources.
The information collected by the FFIEC 101 is not available from other sources.
Description of Information Collection
The mandatory FFIEC 101 report collects information from all Board-regulated advanced
approaches banking organizations, as well as information regarding the SLR from Category III
institutions. Advanced approaches banking organizations are required to submit detailed data on
the components of their capital and risk-weighted assets in nineteen schedules (A through S).
Category III institutions must complete only Schedule A, SLR Tables 1 and 2.

institutions, depository institution holding companies, and nonbank financial companies it supervises (12 U.S.C.
§ 5371(b)(1)-(2)). Further, the International Lending Supervision Act of 1983 (12 U.S.C. § 3907(a)(1)) mandates
that each federal banking agency require banks to achieve and maintain adequate capital by establishing minimum
levels of capital or by other methods that the agency may deem appropriate and section 38(c) of the Federal Deposit
Insurance Act (12 U.S.C. § 1831o(c)) requires each federal banking agency to adopt a risk-based capital requirement
for insured depository institutions.

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Advanced Approaches Regulatory Capital and Summary Risk-Weighted Asset
Information. Schedule A collects information about the components of Tier 1 capital, Tier 2
capital, and adjustments to regulatory capital as defined within the rule. Schedule B contains
summary information about risk-weighted assets by risk type, and, in the case of credit risk
exposures, outstanding balances and aggregated information about the drivers and estimates that
underlie the calculation of risk-weighted assets. Tables 1 and 2 of Schedule A collect
information about each advanced approaches banking organization and top-tier Category III
BHCs, SHCs, and SMBs, and all Category III IHCs SLR, the ratio of tier 1 capital to total
leverage exposure. Table 1 reconciles balance sheet assets reported in published financial
statements and total leverage exposure. Table 2 collects components of on-balance sheet and offbalance sheet exposures, for the calculation of total leverage exposure, tier 1 capital, and the
calculation of the SLR.
Schedule B collects general exposure information from advanced approaches banking
organizations. Respondents must report:
 Wholesale exposures, including separate reporting for the following types of exposures:
Corporate; Bank; Sovereign; Income producing real estate; High volatility commercial
real estate; Eligible margin loans, repo-style transactions, and OTC derivatives with cross
product netting; and Eligible margin loans, repo-style transactions, and OTC derivatives
without cross product netting,
 Retail Exposures, including separate reporting for the following types of exposures:
Residential mortgage closed-end first liens, Residential mortgage closed-end junior liens,
Residential mortgage revolving exposures, Qualifying revolving exposures, and Other
retail exposures,
 Securitization exposures,
 Cleared transactions, including separate reporting for the following types of exposures:
Derivative contracts and netting sets to derivatives, Repo-style transactions, and Default
fund contributions,
 Equity exposures, and
 Other assets; including separate reporting for the following types of exposures: Unsettled
transactions, Assets not included in a defined exposure category, Non-material portfolios
of exposures, Credit valuation adjustments, Assets subject to the general risk-based
capital requirements, Excess eligible credit reserves not included in Tier 2 capital,
Advanced market risk equivalent assets; and Operational risk.
Some of the aggregate data items submitted in Schedule B are derived from information
contained in the more detailed confidential supporting schedules described below. The data
contained in Schedule B describe the main summary-level components of respondents’ riskweighted assets.
Wholesale Exposures. Schedules C through J request data on respondents’ wholesale
exposures. Each schedule represents a sub-portfolio of the wholesale exposure category as listed
on Schedule B. For each reported sub-portfolio, the schedule groups exposures into sub-portfolio
segments using supervisor-defined probability of default (PD) ranges. The reported cells within
these schedules then describe the main risk parameters and characteristics of each sub-portfolio
segment.
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Retail Exposures. Schedules K through O request data on respondents’ retail exposure
category. Each schedule represents a sub-portfolio of the retail exposure category as listed on
Schedule B. PD ranges are used to sub-divide each sub-portfolio into segments.2 The reported
cells within these schedules then describe the main risk parameters and characteristics of each
sub-portfolio segment. The retail schedules also incorporate risk characteristics that are believed
to be commonly used drivers within respondents’ risk management and measurement processes,
including the distribution of each sub-portfolio segment by loan-to-value ranges (applies only to
real estate exposures), weighted average credit bureau score, and weighted average account age. 3
Securitization Exposures. Schedule P requests data on respondents’ securitization and
resecuritization exposures that are subject to either the supervisory formula approach, the
simplified supervisory formula approach, a 1250 percent risk weight, or deduction. A respondent
completes Schedule P by providing information on exposure amount, risk-weighted asset
amount, and deduction amount for each securitization and resecuritization based on the treatment
the exposure is subject to under the rule.
Cleared Transactions. Schedule Q requests data on respondents’ cleared transaction
exposures. The schedule divides cleared transactions into subcategories relating to the Clearing
member client bank and to the Clearing member bank. For the Clearing member client bank
category, a respondent completes Schedule Q by providing exposure amount and risk weighted
asset amount information on derivative contracts or netting sets of derivative contracts and repostyle transactions. Schedule Q requests that respondents’ provide exposure amount from default
fund contributions and risk-weighted asset amounts for exposures within the Clearing member
bank category, which include derivative contracts or netting sets of derivative contracts, repostyle transactions, and default fund contributions to non-qualified and qualified central
counterparties.
Equities. Schedule R requests information about respondents’ equity exposures by type of
exposure and by approach to measuring required capital. Schedule R also requests information
on equity exposures subject to specific risk weights and equity exposures to investment funds. A
respondent completes the appropriate section of the schedule based on whether it uses a simple
risk-weight approach, a full internal models approach, or a partially modeled approach to
measuring required capital for equity exposures.
Operational Risk. Schedule S requests data on respondents’ operational risk exposure.
Data items submitted in this schedule include various details about historical operational losses,
on a stand-alone and group-wide basis, for the current reporting period and those historical
operational losses used to model operational risk capital. The schedule also requests data related
to scenarios, distribution assumptions, and loss caps used to model operational risk capital.

2

Unlike the wholesale credit exposure reporting schedules, the PD ranges for retail exposures differ from subportfolio to sub-portfolio.
3
For qualifying revolving exposures and other (non-mortgage) retail exposures, the exposure at default of accounts
under two years old is reported instead of weighted average age for each sub-portfolio exposure segment.

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Respondent Panel
The FFIEC 101 respondent panel consists of all SMBs, BHCs, and SLHCs that are
subject to the Board’s advanced approaches capital framework pursuant to 12 CFR 217.100(b),
which must submit all schedules of the FFIEC 101, as well as all BHCs, SLHCs, SMBs, and
IHCs that are Category III institutions, as defined in 12 CFR 217.2, which must complete only
Schedule A, SLR Tables 1 and 2.
Proposed Revisions
Regulation-Related Revisions
From March through June 2020, in response to the impact on the financial markets and
the strains on the U.S. economy as a result of COVID-19, the agencies published in the Federal
Register numerous interim final rules to make certain changes to their regulatory capital and
liquidity rules to support prudent lending by banking organizations and facilitate banking
organizations’ use of the Board’s emergency facilities. These revisions primarily affect the
instructions for the calculation of certain amounts reported on Schedule A, Advanced
Approaches Regulatory Capital on the FFIEC 101.
The agencies requested and received emergency approvals on April 3, 2020, from OMB
to implement revisions to the FFIEC 101 that took effect beginning with the March 31, 2020,
report date. Subsequently, the agencies requested and received emergency approvals on May 27,
2020, from OMB to implement revisions to the FFIEC 101 that take effect beginning with the
June 30, 2020, report date. The agencies have requested comment in connection with each of the
interim final rules described below. If modifications are made to the associated final rules, the
agencies would modify the information collection revisions in this proposal to incorporate such
changes.
Money Market Mutual Fund Liquidity Facility
To enhance the liquidity and functioning of money markets, the Federal Reserve Bank of
Boston (FRBB) launched the Money Market Mutual Fund Liquidity Facility (MMLF) on March
18, 2020.4 On March 23, 2020, the agencies published an interim final rule, which permits
banking organizations to exclude from regulatory capital requirements exposures related to the
MMLF (MMLF interim final rule).5
The MMLF interim final rule modifies the agencies’ capital rule to allow banking
organizations to neutralize the effects of purchasing assets from money market mutual funds
under the MMLF on their risk-based and leverage capital ratios. This treatment extends to the
community bank leverage ratio. Specifically, a banking organization may exclude from its total
leverage exposure, average total consolidated assets, standardized total risk-weighted assets, and
advanced approaches total risk-weighted assets, as applicable, any exposure acquired from an
eligible money market mutual fund pursuant to a non-recourse loan under the MMLF and
4
5

See https://www.federalreserve.gov/newsevents/pressreleases/monetary20200318a.htm.
85 FR 16232 (March 23, 2020).

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pledged to the FRBB. The MMLF interim final rule applies only to activities under the MMLF.
The facility is scheduled to terminate on December 31, 2020, unless the facility is extended by
the Board.
Consistent with U.S. GAAP, the agencies would expect banking organizations to report
assets purchased from money market mutual funds under the MMLF on their balance sheets. To
be eligible collateral for pledging to the FRBB, assets must be purchased from an eligible money
market mutual fund at either the seller’s amortized cost or fair value. Thereafter, banking
organizations would subsequently measure the assets at amortized cost or fair value depending
on the asset category in which the assets are reported on their balance sheets. The non-recourse
nature of the transaction through the MMLF would impact the valuation of the liability to the
FRBB. After reflecting any appropriate discounts on the assets purchased and the associated
liabilities, organizations are not expected to report any material net gains or losses (if any) at the
time of purchase. Any discounts generally would be accreted over time into income and expense.
Starting with the March 31, 2020, report date, advanced approaches banking
organizations should not include assets purchased from money market funds under the MMLF in
the “Total risk-weighted assets” reported in the FFIEC 101, Schedule A, item 60 or for advanced
approaches banking organizations that file Call Reports, in Schedule RC-R, Part I, item 48.b. For
banking organizations subject to the supplementary leverage ratio requirement that file the
FFIEC 101, assets purchased from money market funds under the MMLF would receive similar
treatment as under the “leverage ratio” and should be reported in the FFIEC 101, Schedule A,
SLR Tables. The outstanding balance of these assets would continue to be reported in SLR
Table 1, item 1.1, “Total consolidated assets as reported in published financial statements,” and
Table 2, item 2.1, “The balance sheet carrying value of all on-balance sheet assets.” The average
amount of these assets calculated as of each day of the reporting quarter also would be reported
in SLR Table 1, item 1.7.c, “Adjustments for deductions of qualifying central bank deposits for
custodial banking organizations,” and in SLR Table 2, item 2.2.b, “Deductions of qualifying
central bank deposits from total on-balance sheet exposures for custodial banking organizations,”
even if a banking organization is not a custodial banking organization.
5-Year 2020 CECL Transition Provision
The instructions for certain items in the FFIEC 101 have been revised effective as of the
March 31, 2020, report date to incorporate revisions reflected in the interim final rule,
Regulatory Capital Rule: Revised Transition for the Current Expected Credit Losses
Methodology for Allowances, published in the Federal Register on March 27, 2020 (CECL
interim final rule).6 This interim final rule provides institutions that were required to adopt the
current expected credit losses methodology (CECL) for accounting purposes during the 2020
calendar year with the option to delay for two years the estimated impact of CECL on regulatory
capital, followed by a three-year transition period to phase out the aggregate amount of the
capital benefit provided during the initial two-year delay (i.e., a five-year transition, in total). The
CECL interim final rule does not replace the current CECL transition option in the agencies’
6

85 FR 17723 (March 27, 2020). The agencies published a correcting amendment in the Federal Register 85 FR
29839 (May 19, 2020).

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capital rule, which was adopted in 2019 and allows banking organizations to phase in over a
three-year period the day-one effects on regulatory capital that may result from the adoption of
CECL (2019 CECL rule).7 This transition option remains available to institutions that adopt
CECL. Thus, institutions required to adopt CECL in 2020, including those that began reporting
in accordance with CECL in their first quarter 2020 regulatory reports, have the option to elect
the three-year transition option contained in the 2019 CECL rule or the five-year CECL
transition option contained in the CECL interim final rule, beginning with, if applicable, the
FFIEC 101 for the March 31, 2020, report date or such later report date in 2020 as of which
institutions first report in accordance with CECL.
The agencies have revised the FFIEC 101 instructions for the following items in
Schedule A to enable advanced approaches institutions and top-tier Category III institutions that
elect the five-year CECL transition option to report their regulatory capital data in accordance
with the CECL interim final rule:
 Schedule A, Item 2, “Retained earnings,”
 Schedule A, Item 21, “DTAs arising from temporary differences that could not be
realized through net operating loss carrybacks, net of related valuation allowances and
net of DTLs, that exceed the 10 percent common equity tier 1 capital deduction
threshold,”
 Schedule A, Item 50, “Eligible credit reserves includable in Tier 2 capital,” and
 SLR Table 1, Item 1.8, and Table 2, Item 2.21, “Total leverage exposure.”
Paycheck Protection Program (PPP) Loans and Liquidity Facility (PPPLF)
Section 1102 of the CARES Act allows banking organizations to make loans under the
PPP of the U.S. Small Business Administration (SBA) in connection with COVID-19 disruptions
to small businesses. Although the PPP loans are funded by lenders, the loans receive a guarantee
from the SBA. The statute specified that these PPP loans should receive a zero percent risk
weight for regulatory capital purposes. The Board subsequently established a liquidity facility,
the PPPLF, to extend non-recourse loans to eligible financial institutions to fund PPP loans
pledged to the PPPLF and thereby provide additional liquidity to these institutions.8
On April 13, 2020, the agencies published an interim final rule with an immediate
effective date, which permits banking organizations to exclude from regulatory capital
requirements PPP loans pledged to the PPPLF.9 This interim final rule modifies the agencies’
capital rule to allow banking organizations to neutralize the effects on their risk-based capital and
leverage ratios of making PPP loans that are pledged under the Board’s liquidity facility.
Specifically, a banking organization may exclude from its total leverage exposure, average total
consolidated assets, standardized total risk-weighted assets, and advanced approaches total riskweighted assets, as applicable, any exposure from a PPP loan pledged to the Board’s liquidity
facility. The interim final rule also codified the statutory zero percent risk weight for PPP loans.

7

84 FR 4222 (February 14, 2019).
See https://www.federalreserve.gov/newsevents/pressreleases/monetary20200406a.htm and
https://www.federalreserve.gov/newsevents/pressreleases/monetary20200416a.htm.
9
80 FR 20387 (April 13, 2020).
8

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Starting with the June 30, 2020, report date, advanced approaches banking organizations
would not include PPP loans in “total risk-weight assets” under the advanced approaches
reported in the FFIEC 101, Schedule A, item 60. Since these loans already receive a zero percent
risk weight, PPP loans are effectively excluded from advanced approaches total risk-weighted
assets under the current capital rule.
For banking organizations subject to the supplementary leverage ratio requirement that
file the FFIEC 101, PPP loans pledged to the Board’s liquidity facility would be deducted as part
of the calculation of total leverage exposure for the supplementary leverage ratio. The
outstanding balance of PPP loans would continue to be reported in SLR Table 1, item 1.1, “Total
consolidated assets as reported in published financial statements,” and Table 2, item 2.1, “The
balance sheet carrying value of all on-balance sheet assets.” A banking organization calculating
its supplementary leverage ratio also would include the average amount of PPP loans pledged to
the PPPLF as of each day of the reporting quarter in SLR Table 1, item 1.7.c, “Adjustments for
deductions of qualifying central bank deposits for custodial banking organizations,” and in SLR
Table 2, item 2.2.b, “Deductions of qualifying central bank deposits from total on-balance sheet
exposures for custodial banking organizations,” even if a banking organization is not a custodial
banking organization.
Temporary Exclusions From the Supplementary Leverage Ratio
On April 14, 2020, the Board published in the Federal Register an interim final rule to
temporarily exclude U.S. Treasury Securities (Treasuries) and deposits in their accounts at
Federal Reserve Banks (deposits at Federal Reserve Banks) from total leverage exposure for
bank holding companies, savings and loan holding companies, and intermediate holding
companies subject to the supplementary leverage ratio through March 31, 2021.10
On June 1, 2020, the agencies published in the Federal Register an interim final rule
(Depository Institution SLR IFR) to provide depository institutions subject to the supplementary
leverage ratio the ability to temporarily exclude Treasuries and deposits at Federal Reserve
Banks from total leverage exposure.11 An electing depository institution must notify its primary
Federal banking regulator of its election within 30 days after the interim final rule is effective.
The interim final rule will terminate after March 31, 2021.
For top-tier advanced approaches and Category III bank holding companies, savings and
loan holding companies, and intermediate holding companies (and top-tier advanced approaches
and Category III depository institutions that elect to opt into these temporary exclusions),
Treasuries and deposits at Federal Reserve Banks would continue to be reported in the
FFIEC 101, Schedule A, SLR Table 1, item 1.1, “Total consolidated assets as reported in
published financial statements,” and Table 2, item 2.1, “The balance sheet carrying value of all
on-balance sheet assets.” Starting as of the June 30, 2020, report date, the average amount of
Treasuries and deposits at Federal Reserve Banks calculated as of each day of the reporting
quarter also would be reported in SLR Table 1, item 1.7.c, “Adjustments for deductions of
qualifying central bank deposits for custodial banking organizations,” and in SLR Table 2, item
10
11

85 FR 20578 (April 14, 2020).
85 FR 32980 (June 1, 2020).

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2.2.b, “Deductions of qualifying central bank deposits from total on-balance sheet exposures for
custodial banking organizations,” even if a holding company or an electing depository institution
is not a custodial banking organization.12 For purposes of reporting the supplementary leverage
ratio as of June 30, 2020, holding companies and electing depository institutions would be
permitted the exclusion of Treasuries and deposits at Federal Reserve Banks from total leverage
exposure as if these interim final rules had been in effect for the entire second quarter of 2020.
The temporary exclusions from total leverage exposure would be available through the March
31, 2021, report date.
Custodial banking organizations would also be able to deduct from total leverage
exposure deposits with qualifying foreign central banks, subject to the limits in the Section 402
rule, in addition to the deductions of Treasuries and deposits at Federal Reserve Banks under
these interim final rules.
Total Loss Absorbing Capacity Investments Rule
On April 8, 2019, the agencies published a notice of proposed rulemaking that would
address an advanced approaches banking organization’s regulatory capital treatment of an
investment in unsecured debt instruments issued by foreign or U.S. global systemically important
banks (GSIBs) for the purposes of meeting minimum TLAC and, where applicable, long-term
debt (LTD) requirements, or liabilities issued by GSIBs that are pari passu or subordinated to
such debt instruments (TLAC Investments NPR).13 Under the TLAC Investments NPR,
investments by an advanced approaches banking organization in certain unsecured debt
instruments generally would be subject to deduction from the advanced approaches banking
organization’s regulatory capital if such investments exceed certain thresholds. The Board also
proposed to require that banking organizations subject to minimum TLAC and LTD
requirements under Board regulations publicly disclose their TLAC and LTD issuances in a
manner described in the TLAC Investments NPR.
The agencies are proposing changes to FIEC 101 Schedule A, Advanced Approaches
Regulatory Capital to implement the changes proposed to the agencies’ capital rule. If
modifications are made to the proposed TLAC investments rule when it is adopted in final form,
the agencies would modify the FFIEC 101 proposals to incorporate such changes.
Deductions From Regulatory Capital
The agencies propose to make a number of revisions to the instructions for FFIEC 101
Schedule A and add a new data item to this schedule. Specifically, the agencies propose to revise
the instructions for existing items 52 through 54 and add a new data item to effectuate any
deductions from regulatory capital for advanced approaches banking organizations for
investments in excluded covered debt instruments. Existing item 56, “Other deductions from tier
2 capital,” would be renumbered and recaptioned as item 56.b, “All other deductions from tier 2
12

A holding company or electing depository institution may not deduct on-balance Treasuries in SLR Table 2, item
2.12, “Gross assets for repo-style transactions, with no recognition of netting,” if it already reports such on-balance
sheet Treasuries in SLR Table 2, item 2.2.b.
13
84 FR 13814 (April 8, 2019).

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capital.” The new item would be inserted as item 56.a, “Investments in excluded covered debt
instruments,” which would be applicable only to GSIBs and subsidiaries of GSIBs.
LTD and TLAC Amounts, Ratios, and Buffer
In conjunction with the issuance of the TLAC Investments NPR, the Board also proposed
revisions to the Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No.
7100-0128), Schedule HC-R, Part I, that would collect information from U.S. GSIBs and the
intermediate holding companies of foreign GSIBs. Specifically, the proposed items would collect
information on these holding companies’ LTD and TLAC amounts, LTD and TLAC ratios, and
TLAC buffer.
Since the minimum LTD and TLAC requirements and TLAC buffer are only applied at
the holding company-level, the agencies are not proposing to amend the FFIEC 101 to include
this information. Collecting this information in the FFIEC 101 would be a duplicative reporting
requirement and would only be applicable to a subset of FFIEC 101 filers. However, the
agencies are interested in public feedback on this issue, especially if commenters believe
including these items would enhance or simplify public disclosure.
Time Schedule for Information Collection and Publication
The FFIEC 101 is collected quarterly as of the end of the last calendar day of March,
June, September, and December. Respondents must begin reporting on the FFIEC 101,
Schedule A, except for a few specific line items, beginning with the calendar quarter
immediately following the quarter in which the respondent becomes an advanced approaches or
Category III banking institution (Schedule A, SLR Tables 1 and 2 only for Category III banking
institutions), or elects to use the advanced approaches rule (an opt-in institution), and must begin
reporting data on the remaining schedules (except for Category III banking institutions) of the
FFIEC 101 at the end of the first quarter in which they have begun their parallel run period.
The report due dates are 60 days following the end of a quarter while a respondent is in
its parallel run period. After completing its parallel run period, the report due dates are the same
as the report due dates currently required of respondents when filing their respective Call Report
or FR Y-9C14. SMBs must submit the FFIEC 101 to the appropriate Federal Reserve Bank within
thirty calendar days following the as-of date; a five-day extension may be given to banks with
more than one foreign office. BHCs, SLHCs, and IHCs must submit the FFIEC 101 to the
appropriate Federal Reserve Bank within forty calendar days after the March 31, June 30, and
September 30 as of dates unless that day falls on a weekend or holiday (received on the first
business day after the Saturday, Sunday, or holiday) and within forty-five calendars days after
the December 31 as of date.
In general, a reporting entity should maintain in its files a signed and attested record of its
completed FFIEC 101 report, including any amended reports, and the related work papers and
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Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB
Number 7100-0036) and the Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB Number
7100-0128).

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supporting documentation for five years after the report date, unless there are applicable state
requirements that mandate a longer retention time.
Public Availability of Data
For report dates before a reporting institution has completed its parallel run period,
Schedule A will be available to the public, except for items 78 (total eligible credit reserves
calculated under the advanced approaches rules), 79 (amount of eligible credit reserves
includable in tier 2 capital), 86 (expected credit loss that exceeds eligible credit reserves);
87 (advanced approaches risk-weighted assets), 88 (common equity tier 1 capital ratio calculated
using the advanced approaches), 89 (additional tier 1 capital ratio calculated using the advanced
approaches), and 90 (total capital ratio using the advanced approaches). Information reported in
all other schedules of the FFIEC 101 are confidential. For report dates after a reporting
institution has completed its parallel run period, all items reported in Schedules A and B (except
for Schedule B, items 31.a and 31.b, column D) and items 1 and 2 of Schedule S are available to
the public. All other items reported in the FFIEC 101 are confidential. Note that for both before
and after an institution has completed its parallel run period, all items reported on Schedule A,
SLR Tables 1 and 2, are available to the public.
Individual respondent data, excluding confidential information, are available on the
National Information Center public website.
Legal Status
The Board is authorized to collect the information on the FFIEC 101 report from SMBs
pursuant to section 9(6) of the Federal Reserve Act (12 U.S.C. § 324), from BHCs pursuant to
section 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. § 1844(c)(1)(a)),
from SLHCs pursuant to section 10 of the Home Owners’ Loan Act (12 U.S.C. § 1467a(b)(2)),
and from IHCs pursuant to section 5(c) of the BHC Act (12 U.S.C. § 1844(c)(1)(A)), as well as
pursuant to sections 102(a)(1) and 165 of the Dodd-Frank Wall Street and Consumer Protection
Act (Dodd-Frank Act) (12 U.S.C. §§ 5311(a)(1) and 5365),15 and sections 8(a) and 13(a) of the
International Banking Act of 1978 (12 U.S.C. §§ 3106(a) and 3108(a)). The quarterly FFIEC 101
report is mandatory for reporting institutions.
For report dates before a reporting institution has completed its parallel run period,
Schedule A, except for items 78, 79, and 86-90, is released to the public. Items 78, 79, and 86-90
on Schedule A and all of the information reported in Schedules B through S are withheld as
Section 165(b)(2) of Title I of the Dodd-Frank Act (12 U.S.C. § 5365(b)(2)), refers to “foreign-based bank
holding company.” Section 102(a)(1) of the Dodd-Frank Act (12 U.S.C. § 5311(a)(1)), defines “bank holding
company” for purposes of Title I of the Dodd-Frank Act to include foreign banking organizations that are treated as
bank holding companies under section 8(a) of the International Banking Act of 1978 (12 U.S.C. § 3106(a)). The
Board has required, pursuant to section 165(b)(1)(B)(iv) of the Dodd-Frank Act (12 U.S.C. § 5365(b)(1)(B)(iv)),
certain of the foreign banking organizations that are 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 FFIEC 101 report.
15

11

confidential. For report dates after an institution has completed its parallel run period, all of the
data items in Schedules A and B, except for Schedule B, items 31.a and 31.b, column D, and data
items 1 and 2 of Schedule S are released to the public. Data items 31.a and 31.b, column D of
Schedule B, and all of the data items in Schedules C through S, except for Schedule S, data items
1 and 2, continue to be withheld as confidential after the institution’s parallel run period is
completed.
Data items 78, 79, and 86-90 of Schedule A collect information on total eligible credit
reserves, risk weighted assets, tier one capital ratios and other data calculated using advanced
approaches. Schedule B contains summary information about risk-weighted assets and
aggregated information that underlie the calculation of risk-weight assets using advanced
approaches. Data items 1 and 2 of Schedule S reflect high-level information on an institution’s
total risk-based capital requirement for operational risk. During the parallel run period,
supervisors may request a banking organization amend its internal models, risk measurement,
and management infrastructure to implement calculations using advanced approaches. Public
disclosure of the above referenced data items before the parallel run period is completed could
lead investors, competitors, and the public to misjudge the financial health of the institutions,
when in fact there has been no change to their underlying fundamentals and, therefore, could
result in substantial competitive harm. Thus, data items 78, 79, and 86-90 of Schedule A, all of
Schedule B (except for data items 31.a and 31.b, column D), and data items 1 and 2 of
Schedule S only will be released to the public by the FFIEC for the reporting periods after the
institution’s parallel run period is completed.16 Before completion of the parallel run period,
such information may be withheld as confidential pursuant to exemption 4 of the Freedom of
Information Act (FOIA), which exempts from disclosure “trade secrets and commercial or
financial information obtained from a person and privileged or confidential” (5 U.S.C. §
552(b)(4)).
Data items 31.a and 31.b, column D of Schedule B, data items 3-24 of Schedule S, and all
of the data items in Schedules C through R. The data items found in these schedules contain
more detailed information than are included in the public schedules, including sensitive
information breaking down individual banking organization exposures to borrowers by
probability of default, exposures at default, and detailed information on the data used to model
operational risk capital. Disclosure of this information could result in substantial competitive
harm to the reporting institution, particularly because other financial institutions, which are not
required to publicly report such data, would competitively benefit from the public disclosure of
such detailed information by each reporting institution. Accordingly, these items are withheld as
confidential pursuant to exemption 4 of the FOIA after the parallel run period.
If a reporting institution believes that disclosing the data items designated for public
disclosure on the FFIEC 101 report is reasonably likely to result in substantial harm to its
competitive position, then consistent with exemption 4 of the FOIA, the respondent may request
confidential treatment for such information, which will be evaluated on a case-by-case basis.

16

Before determining an institution’s risk-based capital requirements, the institution must conduct a parallel run of
no less than four consecutive calendar quarters during which it complies with the qualification requirements in 12
CFR 217.122 to the Board’s satisfaction (12 CFR 217.121).

12

Finally, the Board uses data from the FFIEC 101 to supplement on-site examination
processes. Therefore, this information can be kept confidential under exemption 8 of FOIA
(5 U.S.C. § 552(b)(8)), which specifically exempts from disclosure information “contained in or
related to examination, operating, or condition reports prepared by, on behalf of, or for the use of
an agency responsible for the regulation or supervision of financial institutions.”
Consultation Outside the Agency
The Board coordinated and consulted with the FDIC and OCC in developing these
revisions.
Public Comments
On July 22, 2020, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (85 FR 44361) requesting public comment for 60 days on the
extension, with revision, of the FFIEC 101. The comment period for this notice expired on
September 21, 2020. On October 4, 2019, the agencies, under the auspices of the FFIEC,
published an initial notice in the Federal Register (84 FR 53227) requesting public comment for
60 days on the extension, with revision, of the FFIEC 101 resulting from the proposed TLAC
investments rule. The comment period for this notice expired on December 3, 2019. The
agencies received 2 public comments on the proposed reporting changes related to the TLAC
investments rule from banking trade associations.
Comments Received on Revisions Related to the Total Loss Absorbing Capacity
Investments Rule
General Comments
Commenters requested that any changes to regulatory reporting related to the TLAC
investments NPR – including changes to the FFIEC 101 – be implemented after the effective
date of the final rule. The agencies concur, and are not implementing associated changes to
regulatory reports until the June 30, 2021, report date. The TLAC investments final rule’s
effective date is April 1, 2021.
Commenters further requested that the agencies delay implementation of the proposed
changes to the FFIEC 101 until 18 months after the TLAC investments final rule becomes
effective to provide more time to modify reporting systems and identify exposures to “covered
debt instruments.” In addition, commenters requested that the agencies not require application of
the final rule’s deduction treatment to an exposure to a global systemically important banking
organization until the reporting banking organization has the information necessary to determine
whether such exposure qualifies as a “covered debt instrument.”
As discussed in the preamble of the TLAC investments final rule, the agencies maintain
the supervisory expectation that large and internationally active banking organizations should be
deeply knowledgeable of the securities exposures reported on their own balance sheets, if only
for the purposes of prudent risk management. The final rule will become effective on April 1,

13

2021, and associated changes to the FFIEC 101 would be implemented as of the June 30, 2021,
report date. The agencies believe the effective date for the reporting changes provides sufficient
time for advanced approaches banking organizations to evaluate investments in covered debt
instruments and apply the final rule’s deduction treatment. Further, the agencies believe that the
effective date for the reporting changes provides sufficient time for these banking organizations
to change reporting systems and accurately identify exposures to covered debt instruments for
purposes of regulatory reporting.
Comments on FFIEC 101, Schedule A
One commenter remarked that the FR Y-9C included new reporting items for long-term
and TLAC amounts, ratios, and the TLAC buffer. However, these items were not included in the
agencies’ proposed revisions to the FFIEC 101. This commenter requested that such data items
not be added to the FFIEC 101, as this would constitute a duplicative reporting requirement and
unnecessarily increase burden on banking organizations that complete the FFIEC 101. The
agencies concur with this commenter, as the Board’s TLAC rule applies to only holding
companies. Therefore, such data items are only to be reported on the FR Y-9C and are not being
added to the FFIEC 101.
Timing
As stated in the July 2020 notice, the reporting revisions associated with the interim final
rules, and the CARES Act provisions have been approved by OMB through the emergency
clearance process, and these revisions have taken effect for the March 31, 2020, and June 30,
2020, FFIEC 101. Subject to OMB approval, the reporting revisions for which emergency
approvals were received will remain in effect.17
The reporting changes to the FFIEC 101 for the TLAC investments final rule would take
effect June 30, 2021. The specific wording of the captions for the new or revised FFIEC 101 data
items discussed in the October 2019 and July 2020 notices and this notice and the numbering of
these data items should be regarded as preliminary.
On November 23, 2020, the agencies, under the auspices of the FFIEC, published a final
notice in the Federal Register (85 FR 74784) requesting public comment for 30 days on the
extension, with revision, of the FFIEC 101. The comment period for this notice expires on
December 23, 2020.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FFIEC 101 is
35,288 hours, and would remain unchanged with the proposed revisions. These reporting
requirements represent less than 1 percent of the Board’s total paperwork burden.

17

As stated in the July 2020 notice, the collection of the new Call Report data items for which emergency approvals
were received is expected to be time-limited.

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Estimated
Estimated
Annual
number of
average hours
frequency
respondents18
per response
4
4
674
9
4
677

FFIEC 101
SMBs
BHCs and SLHCs
BHCs and SLHCs
(SLR Tables 1 and 2 only)
IHCs

5
6

4
4

Total

3
3

Estimated
annual burden
hours
10,784
24,372
60
72
35,288

The estimated total annual cost to the public for the FFIEC 101 is $2,037,882.19
Sensitive Questions
This collection of information contains 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 this
information collection is $157,700 per year.

18

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.
19
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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