FR2314_FR2314S_FRY11_FRY11S_20210316_omb_emergency

PUBLIC/OFFICIAL RELEASE // EXTERNAL

Supporting Statement for the
Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations
(FR 2314 and FR 2314S; OMB No. 7100-0073) and
Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies
(FR Y-11 and FR Y-11S; OMB No. 7100-0244)
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
Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314 and
FR 2314S; OMB No. 7100-0073) and Financial Statements of U.S. Nonbank Subsidiaries of
U.S. Holding Companies (FR Y-11 and FR Y-11S; OMB No. 7100-0244) pursuant to its
authority to approve temporarily a collection of information without providing opportunity for
public comment.1 This information collection comprises the following four reports:
• Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314),
• Abbreviated Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations
(FR 2314S),
• Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies
(FR Y-11), and
• Abbreviated Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding
Companies (FR Y-11S).
The FR 2314 reporting forms collect financial information for non-functionally regulated
direct or indirect foreign subsidiaries of U.S. state member banks (SMBs), Edge and agreement
corporations, and holding companies (i.e., bank holding companies, savings and loan holding
companies, securities holding companies, and intermediate holding companies). Parent
organizations (SMBs, Edge and agreement corporations, or holding companies) file the FR 2314
on a quarterly or annual basis, or the FR 2314S on an annual basis, predominantly based on
whether the organization meets certain asset size thresholds. The FR 2314 data are used to
identify current and potential problems at the foreign subsidiaries of U.S. parent companies, to
monitor the activities of U.S. banking organizations in specific countries, and to develop a better
understanding of activities within the industry, in general, and of individual institutions, in
particular.
The FR Y-11 reporting forms collect financial information for individual nonfunctional
regulated U.S. nonbank subsidiaries of domestic holding companies, which is essential for
monitoring the subsidiaries’ potential impact on the condition of the holding company or its
subsidiary banks. Holding companies file the FR Y-11 on a quarterly or annual basis or the
FR Y-11S on an annual basis, predominantly based on whether the organization meets certain
asset size thresholds. The FR Y-11 data are used with other holding company data to assess the
condition of holding companies that are heavily engaged in nonbanking activities and to monitor
the volume, nature, and condition of their nonbanking operations.

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5 CFR Part 1320, Appendix A(1)(a)(3)(i)(A).

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To mitigate temporary transition costs on banking organizations related to the
coronavirus disease 2019 (COVID event), the Board, Federal Deposit Insurance Corporation
(FDIC), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued
an interim final rule2 to permit national banks, savings associations, state banks, bank holding
companies, savings and loan holding companies, and U.S. branches and agencies of foreign
banking organizations with under $10 billion in total assets as of December 31, 2019,
(community banking organizations) to use asset data as of December 31, 2019, in order to
determine the applicability of various regulatory asset thresholds during the remainder of 2020
and calendar year 2021. Consistent with the interim final rule, the Board temporarily revised the
instructions for the FR 2314, FR 2314S, FR Y-11, and FR Y-11S reports to allow a holding
company to use asset data as of December 31, 2019, in order to determine reporting
requirements. The Board believes the changes to the measurement dates for the total asset
thresholds used to determine additional reporting requirements will not result in a change in the
currently approved burden estimates. Therefore, the burden estimates for these reports remain
unchanged by the interim final rule.
The estimated total annual burden for the FR 2314 reports is 14,664 hours, and would
remain unchanged. The estimated total annual burden for the FR Y-11 reports is 15,237 hours,
and would remain unchanged. The forms and instructions are available on the Board’s public
website at https://www.federalreserve.gov/apps/reportforms/default.aspx.
Background and Justification
The FR 2314 reports are the only source of comprehensive and systematic data on the
assets, liabilities, and earnings of the foreign nonbank subsidiaries of U.S. banking organizations
and the data are used to monitor the growth, profitability, and activities of these foreign
companies. The data help the Federal Reserve identify present and potential problems of these
companies, monitor their activities in specific countries, and develop a better understanding of
activities within the industry and within specific institutions. This information, coupled with
information from the Foreign Branch Reports of Condition (FFIEC 030; OMB No. 7100-0071),
provides a picture of the breadth and scope of international banking operations for U.S. holding
companies both individually and in the aggregate.
The FR Y-11 reports collect financial information for individual U.S. nonbank
subsidiaries of domestic holding companies, which is essential for monitoring the subsidiaries’
potential impact on the holding company or its subsidiary banks’ condition. Consolidated and
parent company only data do not reveal the extent of the problems that may exist within the
nonbank subsidiaries because the size and operations of bank subsidiaries can mask the
operations of nonbank subsidiaries in a consolidated report.
In addition to providing information used in the supervision of holding companies, the
FR Y-11 reports provide essential information to assist the Federal Reserve in the formulation of
regulations and supervisory policies. The data are also used by the Federal Reserve to respond to
requests from Congress and the public for information on holding companies.

2

See 85 FR 77345 (December 2, 2020).

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Description of Information Collection
The FR 2314 reports collect financial information for direct or indirect foreign
subsidiaries of U.S. SMBs, Edge and agreement corporations, and holding companies. The
FR 2314 consists of an income statement and balance sheet, schedules that collect information
on changes in equity capital, the allowance for loan and lease losses, off-balance-sheet data
items, loans, and a memoranda section. A parent U.S. banking organization must file the
FR 2314 quarterly, as of the last calendar day of March, June, September, and December, for its
subsidiary if the subsidiary is owned or controlled by a parent U.S. holding company that has
total consolidated assets of $500 million or more as of June 30 of the preceding year or files the
Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No. 7100-0128) to
meet supervisory needs, or the subsidiary is owned or controlled by a SMB or an Edge or
agreement corporation that has total consolidated assets equal to or greater than $500 million,
and the subsidiary has (1) total assets of $1 billion or more, (2) total off-balance-sheet activities
of at least $5 billion, (3) equity capital of at least 5 percent of the top-tier organization’s
consolidated equity capital, or (4) operating revenue of at least 5 percent of the top-tier
organization’s consolidated operating revenue. The FR 2314 is filed annually, as of December
31, for each individual subsidiary that does not meet the criteria for filing quarterly and that has
total assets of at least $500 million but less than $1 billion.
The FR 2314S is an abbreviated reporting form that collects four data items: net income,
total assets, equity capital, and total off-balance-sheet data items. The FR 2314S is filed
annually, as of December 31, for each individual subsidiary (that does not meet the criteria for
filing the FR 2314) with assets of at least $250 million but less than $500 million.
Domestic holding companies file the FR Y-11 reports for their U.S. nonbank subsidiaries.
The FR Y-11 consists of an income statement and balance sheet, schedules that collect
information on changes in equity capital, the allowance for loan and lease losses, off-balancesheet data items, loans, and a memoranda section. A top-tier holding company must file the
FR Y-11 quarterly for each nonbank subsidiary that it owns and controls if the top-tier holding
company has total consolidated assets of $500 million or more as of June 30 of the preceding
year or files the FR Y-9C to meet supervisory needs and the subsidiary meets any one of the
following criteria: (1) total assets of $1 billion or more, (2) total off-balance-sheet activities of at
least $5 billion, (3) equity capital of at least 5 percent of the top-tier holding company’s
consolidated equity capital, or (4) operating revenue of at least 5 percent of the top-tier holding
company’s consolidated operating revenue. The FR Y-11 is filed annually, as of December 31,
by top-tier holding companies for each individual nonbank subsidiary that does not meet the
criteria for filing quarterly with total assets of at least $500 million, but less than $1 billion.
The FR Y-11S is an abbreviated reporting form that collects four data items: net income,
total assets, equity capital, and total off-balance-sheet data items. The FR Y-11S is filed
annually, as of December 31, by top-tier holding companies for each individual nonbank
subsidiary that does not meet the criteria for filing the FR Y-11 with total assets of at least $250
million, but less than $500 million.

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Respondent Panel
U.S. banking organizations file the FR 2314 and FR 2314S for its foreign subsidiaries.
U.S. holding companies file the FR Y-11 and FR Y-11S for U.S. nonbank subsidiaries owned or
controlled.
Temporary Revisions
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.
During 2020, relief measures enacted by Congress through the Coronavirus Aid, Relief,
and Economic Security Act (CARES Act) in response to the strains on the U.S. economy and
disruptions to the financial markets as a result of COVID-19 have led to unprecedented growth at
many institutions, including loans made through the Paycheck Protection Program (PPP). This
rapid growth has caused the assets of some institutions to rise above certain asset-based
thresholds, and may cause other institutions to do so in the near future. Much of this growth,
especially growth related to PPP lending, is likely to be temporary, and the increase in assets
currently held by an institution may not reflect a change in the institution’s longer-term risk
profile. Community banking organizations have played an instrumental role in the nation’s
financial response to the COVID event and many have experienced unexpected and sharp
increase in assets, swelling their balance sheets in some cases by more than 25 percent. Further,
community banking organizations have originated a disproportionately large percentage of PPP
loans, as compared with the organizations’ market share.
Many community institutions may have unexpectedly crossed these total asset thresholds
during 2020 due to participation in CARES Act relief programs or other COVID-19-related
stimulus activities, which would otherwise trigger additional reporting obligations starting in
calendar year 2021. The Board expects some of these institutions may fall below the relevant
total asset threshold as of June 30, 2021, for example, after forgiveness of PPP loans and
redemption of borrowings obtained through the Board’s PPP liquidity facility. The Board does
not want to create a short-term increase in burden on these community institutions to comply
with the additional reporting for a single year. For community institutions that remain above a
total asset threshold as of the June 30, 2021, measurement date, the one-year reporting relief
provided in the interim final rule would assist those institutions in focusing on COVID-19related stimulus activities in the near term while providing additional time to comply with any
additional reporting requirements starting in 2022 rather than 2021.

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PUBLIC/OFFICIAL RELEASE // EXTERNAL

The interim final rule adjusts for community banking organizations the measurement
dates for certain total asset thresholds that would otherwise trigger additional collection
requirements for the remainder of calendar years 2020 through the end of 2021. The temporary
relief applies only to filing requirements associated with asset-based reporting thresholds of $10
billion or less. To implement the interim final rule, the Board is temporarily revising the
instructions for the following reports: FR 2314, FR 2314S, FR Y-11, and FR Y-11S. The revised
instructions instruct community banking organizations to use the lesser of total assets as of
December 31, 2019, or the most recent applicable measurement period to determine the
applicability of asset-based filing thresholds for the remainder of calendar years 2020 through
the end of 2021. All reporting eligibility criteria for these collections, besides the temporarily
revised total assets measurement date, continue to apply. Holding companies must revert back to
normal measurement dates for determining applicability of the reporting requirements in
calendar year 2022, as summarized in Table 1 of the interim final rule.
Time Schedule for Information Collection
Holding companies are required to file the quarterly the FR 2314 and the FR Y-11 as of
the end of March, June, September, and December, and must submit them within sixty days after
the as of date. The annual FR 2314 and FR Y-11, the FR 2314S, and the FR Y-11S are filed as of
December 31 and are also submitted within sixty days after the as of date. The FR 2314 annual,
FR 2314S, FR Y-11 annual, and FR Y-11S are filed as of December 31 and are also submitted
within sixty days after the as of date.
Public Availability of Data
The data from the FR 2314 and FR Y-11 reports that are not given confidential treatment
are available to the public and are available through the Board’s Freedom of Information Office,
but are not published routinely.
Legal Status
The Board has the authority to require bank holding comanies and any subsidiary thereof,
savings and loan holding companies and any subsidiary thereof, and securities holding
companies and any affiliate thereof to file the FR 2314 and FR Y-11 pursuant to, respectively,
section 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. § 1844(c)),
section 10(b) of the Home Owners’ Loan Act (12 U.S.C. § 1467a(b)), and section 618 of the
Dodd-Frank Wall Street Reform and Consumer Protection Act (12 U.S.C. § 1850a). The Board
has the authority to require SMBs, agreement corporations, and Edge corporations to file the
FR 2314 pursuant to, respectively, sections 9(6), 25(7), and 25A(17) of the Federal Reserve Act
(12 U.S.C. §§ 324, 602, and 625). With respect to FBOs and their subsidiary intermediate
holding companies, section 5(c) of the BHC Act, in conjunction with section 8 of the
International Banking Act of 1978 (12 U.S.C. § 3106), authorizes the board to require FBOs and
any subsidiary thereof to file the FR 2314 reports and FR Y-11 reports. These reports are
mandatory.

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Information collected in these reports generally is not considered confidential. However,
because the information is collected as part of the Board’s supervisory process, certain
information may be afforded confidential treatment pursuant to exemption 8 of FOIA (5 U.S.C. §
552(b)(8)). Individual respondents may request that certain data be afforded confidential
treatment pursuant to exemption 4 of FOIA if the data has not previously been publicly disclosed
and the release of the data would likely cause substantial harm to the competitive position of the
respondent (5 U.S.C. § 552(b)(4)). Additionally, individual respondents may request that
personally identifiable information be afforded confidential treatment pursuant to exemption 6 of
FOIA if the release of the information would constitute a clearly unwarranted invasion of
personal privacy (5 U.S.C. § 552(b)(6)). The applicability of these FOIA exemptions would be
determined on a case-by-case basis.
Consultation Outside the Agency
The Board coordinated and consulted with the FDIC and OCC regarding the temporary
revisions to the FR 2314, FR 2314S, FR Y-11, and FR Y-11S.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2314 reports is
14,664 hours, and would remain unchanged. These reporting requirements represent less than 1
percent of the Board’s total paperwork burden.
Estimated
Estimated
Annual
number of
average hours
frequency
respondents3
per response
439
4
7.2
239
1
7.2
300
1
1

FR 2314 and FR 2314S
FR 2314 (quarterly)
FR 2314 (annual)
FR 2314S
Total

Estimated
annual burden
hours
12,643
1,721
300
14,664

The estimated total annual cost to the public for the FR 2314 reports is $846,846.4

3

Of these respondents, 48 FR 2314 (quarterly) filers; 40 FR 2314 (annual) filers; and 300 FR 2314S filers 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. There are no special accommodations
given to mitigate the burden on small institutions.
4
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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PUBLIC/OFFICIAL RELEASE // EXTERNAL

As shown in the table below, the estimated total annual burden for the FR Y-11 reports is
15,237 hours, and would remain unchanged. These reporting requirements represent less than 1
percent of the Board’s total paperwork burden.
Estimated
Estimated
Annual
number of
average hours
frequency
respondents5
per response
445
4
7.6
189
1
7.6
273
1
1

FR Y-11 and FR Y-11S
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S
Total

Estimated
annual burden
hours
13,528
1,436
273
15,237

The estimated total annual cost to the public for the FR Y-11 reports is $879,937.6
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FR 2314 and FR 2314S is $83,200. The estimated cost to the Federal Reserve System for
collecting and processing the FR Y-11 and FR Y-11S is $110,600.

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Of these respondents, 153 FR Y-11 (quarterly) filers; 189 FR Y-11 (annual) filers; and 273 FR Y-11S filers 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. There are no special accommodations
given to mitigate the burden on small institutions.
6
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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