FRY14_20210228_omb

Supporting Statement for the
Capital Assessments and Stress Testing Reports
(FR Y-14A/Q/M; OMB No. 7100-0341)
Regulatory Capital Treatment for Investments in Certain Unsecured Debt Instruments of
Global Systemically Important U.S. Bank Holding Companies, Certain Intermediate Holding
Companies, and Global Systemically Important Foreign Banking Organizations;
Total Loss-Absorbing Capacity Requirements
(Docket No. R-1655; RIN 7100-AF43)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No.
7100-0341). 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)1 (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, 2021.2 The FR Y-14A, FR Y-14Q, and FR Y-14M reports
(FR Y-14 reports) are used to support the Board’s Comprehensive Capital Analysis and Review
(CCAR) and Dodd-Frank 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, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller
of the Currency (OCC) (collectively, the agencies) adopted a final rule3 that applies to advanced
approaches banking organizations with the aim of reducing both interconnectedness within the
financial system and systemic risks. The final rule requires deduction from a banking
organization’s regulatory capital for certain investments in unsecured debt instruments issued by
foreign or U.S. global systemically important banking organizations (GSIBs) for the purposes of
meeting minimum total loss-absorbing capacity (TLAC) requirements and, where applicable,
long-term debt (LTD) requirements, or for investments in unsecured debt instruments issued by
GSIBs that are pari passu or subordinated to such debt instruments. The final rule is effective on
April 1, 2021.
To implement the reporting requirements of the final rule, the Board revised the FR Y-14
reports to add new regulatory capital line items and to amend instructions for existing regulatory
capital items. In addition, the Board has renumbered items in the FR Y-14A, Schedule A.1.d
(Capital) instructions to correspond with related items on the Consolidated Financial Statements
for Holding Companies (FR Y-9C; OMB No. 7100-0128). The revisions are effective for the
1

Covered SLHCs are those that are not substantially engaged in insurance or commercial activities. See 12 CFR
217.2.
2
See 84 FR 59032 (November 1, 2019).
3
86 FR 708 (January 6, 2021).

June 30, 2021, as of date.
The current estimated total annual burden for the FR Y-14 reports is 838,216 hours, and
would increase to 838,324 hours. The revisions would result in an increase of 108 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,
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, and section 401 of EGRRCPA 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-14 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-14 reports collect stress test and capital plan data from the largest holding
4

Pub. L. No. 111-203, 124 Stat. 1376 (2010).
See 12 U.S.C. § 5365(i)(1).
6
See 12 U.S.C. § 5365(i)(2).
7
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.
5

2

companies, which are those with $100 billion or more in total consolidated assets. The data
collected through the FR Y-14 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
• 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 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
10

In certain circumstances, a BHC or IHC may be required to re-submit its capital plan. See 12 CFR 225.8(e)(4).
Firms that must re-submit their capital plan generally also must provide a revised FR Y-14A in connection with their
resubmission.

3

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
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.
Revisions to the FR Y-14A and FR Y-14Q
The agencies adopted a final rule that applies to advanced approaches banking
organizations with the aim of reducing both interconnectedness within the financial system and
systemic risks. The final rule requires deduction from a banking organization’s regulatory capital
for certain investments in unsecured debt instruments issued by foreign or U.S. GSIBs for the
purposes of meeting minimum TLAC requirements and, where applicable, LTD requirements, or
for investments in unsecured debt instruments issued by GSIBs that are pari passu or
subordinated to such debt instruments. The final rule is effective on April 1, 2021.
On March 19, 2020, the Board proposed to revise the FR Y-14 reports to collect TLAC
and LTD information. To implement the reporting requirements of the final rule, the Board
revised the FR Y-14 reports to add new regulatory capital line items and to amend instructions
for existing regulatory capital items. In addition, the Board has renumbered items in the
FR Y-14A, Schedule A.1.d (Capital) instructions to correspond with related items on the
FR Y-9C. The revisions are effective for the June 30, 2021, as of date.
FR Y-14A, Schedule A.1.d (Capital)
In order to align Schedule A.1.d with the FR Y-9C, the Board added the following items
to Schedule A.1.d:
• Outstanding eligible long-term debt,
11

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

Total loss-absorbing capacity,
LTD and TLAC total risk-weighted assets ratios,
IHCs of foreign GSIBs only: LTD and TLAC leverage ratios,
LTD and TLAC supplementary leverage ratios,
Institution-specific TLAC buffer necessary to avoid limitations on distributions
discretionary bonus payments,
TLAC risk-weighted buffer, and
TLAC leverage buffer.
FR Y-14Q, Schedule D (Regulatory Capital)

The Board revised the instructions for item 1 (Aggregate amount of non-significant
investments in the capital of unconsolidated financial institutions) to require banking
organizations subject to Category I and II standards to include covered debt instruments.
Time Schedule for Information Collection
The following tables outline, by schedule and reporting frequency (annually, quarterly, or
monthly), the as of dates for the data and their associated due date for the current submissions to
the Board.
Schedules and
Sub-schedules

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
December 31st 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,12 and
upon resubmission of a firm’s capital plan.
June 30, 2020.
December 31st of For data as of December 31st of a given year:
a given year, and • Original submission: Data are due April 5th
June 30, 2020.
of the following year.

12

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).

5

•

•

Adjusted submission: The Board will
notify companies at least 14 calendar days
in advance of the date on which it expects
companies to submit any adjusted capital
actions.
Incremental submission: Within 15 days
after making any capital distribution in
excess of those included in a firm’s capital
plan (see 12 CFR 225.8(k)).

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.
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

6

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

Trading,
Counterparty

All firms

All firms

Quarterly

Quarter-end

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

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).
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.

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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
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 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.13 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 5365.14 In addition, section 401(g) of EGRRCPA (12 U.S.C. § 5365 note)
13

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
14

8

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.”15 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
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)).16
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System with regard to the
FR Y-14 revisions.
Public Comments
On April 8, 2019, the agencies published a notice of proposed rulemaking in the Federal
Register (84 FR 13814) for public comment. The comment period for this notice expired on June
7, 2019. On March 19, 2020, the Board separately published a notice in the Federal Register
(85 FR 15776) on the conforming changes to the FR Y-14 to effectuate the proposed deduction
framework for investments in covered debt instruments and to disclose new items related to
TLAC and LTD. The comment period for this notice expired on May 18, 2020. The Board
received no comments on the FR Y-14 proposed changes. On January 6, 2021, the agencies
published a final rule in the Federal Register (86 FR 708).
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.
15
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).
16
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).

9

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 838,324 hours as a result of the revisions. The Board
estimates that the average hours per response for the FR Y-14A filers would increase from 926
hours to 929 hours. These reporting requirements represent approximately 9.3 percent of the
Board’s total paperwork burden.
Estimated
number of
respondents17

FR Y-14

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current
FR Y-14A
FR Y-14Q18
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Current Total

36
36
34
0
36
0
13

1
4
12
1
1
1
1

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

Proposed
FR Y-14A
FR Y-14Q18
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Proposed Total

36
36
34
0
36
0
13

1
4
12
1
1
1
1

929
2,201
1,072
7,200
480
4,800
2,560

33,444
316,944
437,376
0
17,280
0
33,280
838,324

Change

108

17

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.
18
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.

10

The estimated total annual cost to the public for the FR Y-14 is $48,406,974, and would
increase to $48,413,211 with the revisions.19
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.

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/.

11