FFIEC 031, FFIEC 041, and FFIEC 051 18 Question Format OMB Supporting Statement

Supporting Statement for the
Consolidated Reports of Condition and Income
(FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036)
1.

Explain the circumstances that make the collection of information necessary.

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) Consolidated Reports of Condition
and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100 0036).
With respect to the Board, these reports are required of state member banks and are filed on a
quarterly basis. The revisions to the Call Reports 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 inf ormation from banks under their
supervision.
The Board uses the information collected on the Call Reports to fulfill its statutory
obligation to supervise state member banks. State member banks are required to file detailed
schedules of assets, liabilities, and capital accounts in the form of a condition report and
summary statement as well as detailed schedules of operating income and expense, sources and
disposition of income, and changes in equity capital.
The agencies propose to revise the Call Report forms and instructions (FFIEC 031 and
FFIEC 041 only) effective for the June 30, 2021, report date to implement the FDIC’s
amendments to the deposit insurance assessment system applicable to all large insured
depository institutions (IDIs), including highly complex IDIs, to address the temporary deposit
insurance assessment effects resulting from certain optional regulatory capital transition
provisions relating to the implementation of the current expected credit losses (CECL)
methodology. The change to the Call Reports would enable the FDIC to remove the double
counting of a specified portion of the CECL transitional amount or the modified CECL
transitional amount, as applicable (collectively, the CECL transitional amounts), in certain
financial measures that are calculated using the sum of Tier 1 capital and reserves and that are
used to determine assessment rates for large and highly complex IDIs.
The agencies also propose to revise the Call Report forms and instructions effective for
the September 30, 2021, report date related to the exclusion of sweep deposits and certain other
deposits from reporting as brokered deposits, as indicated by the agencies in the Net Stable
Funding Ratio (NSFR) final rule and by the FDIC in its Final Rule on Brokered Deposits and
Interest Rate Restrictions (brokered deposits final rule), respectively. In addition, the agencies
propose to revise the Call Report instructions addressing brokered deposits to align them with the
brokered deposits final rule.
2.

Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current collection.

The Call Reports, which consist of the Reports of Condition and Income, collect basic
financial data from commercial banks in the form of a balance sheet, income statement, and
supporting schedules. The Report of Condition contains supporting schedules that provide detail
on assets, liabilities, and capital accounts. The Report of Income contains supporting schedules
that provide detail on income and expenses.
The Call Reports consist of three reporting forms that apply to different categories of state
member banks. Currently, banks that have foreign offices or that have total consolidated assets of
$100 billion or more must file the FFIEC 031, banks with domestic offices only and total
consolidated assets of less than $100 billion but more than $5 billion file the FFIEC 041, and
banks with domestic offices only and total assets less than $5 billion file the FFIEC 051.
The information collected by the Call Reports is not available from other sources.
Although there are other reports that collect information similar to certain items on the Call
Reports, the information they collect would be of limited value as a replacement for Call Report
data. For example, the Board collects various data in connection with its measurement of
monetary aggregates, bank credit, and flow of funds. These reports provide the Board with
detailed information relating to balance sheet accounts such as balances due from depository
institutions, loans, and deposit liabilities. These collections of information, however, are collected
on a weekly basis usually prepared as of dates other than the last business day of each quarter.
Moreover, information on bank credit is obtained on a sample basis rather than from all insured
banks. Additionally, institutions below a certain size are exempt entirely from some of these
reporting requirements.
The Board also collects financial data from bank holding companies on a regular basis.
Such data is generally required to be reported for the holding company on a consolidated basis,
including its banking and nonbanking subsidiaries, and on a parent-company-only basis. Data
collected from bank holding companies on a consolidated basis reflect aggregate amounts for all
entities within the organization, including banking and nonbanking subsidiaries, so that the actual
dollar amounts applicable to any banking subsidiary would not be determinable from the holding
company reporting information. Therefor, reports collected from bank holding companies lack the
data necessary to assess the financial condition of individual banks to determine whether there
had been any deterioration in their condition.
3.

Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology.

Banks are required to transmit their Call Report data electronically. The agencies have
created the Central Data Repository (CDR) as the only method available to banks and savings
associations for submitting their Call Report data. Under the CDR system, institutions file their
Call Report data via the Internet using software that contains the FFIEC’s edits for validating
Call Report data before submission.

2

4.

Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.

There is no other report or series of reports that collects from all insured banks and
savings associations the regulatory capital and other information gathered through the Call
Reports as a whole. There are other information collection systems that tend to duplicate certain
parts of the Call Report, but the information they provide would be of limited value as a
replacement for the Call Report.
5.

If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.

Of respondents to the Call Reports, 466 are considered small entities as defined by the
Small Business Administration (i.e., entities with less than $600 million in total assets),
www.sba.gov/document/support--table-size-standards. Data collected in the Call Report
information collection is tiered to the size and activity levels of reporting institutions.
The Call Report requires the least amount of data from small institutions with domestic
offices only and less than $5 billion in total assets that file the streamlined FFIEC 051 report
form. Certain institutions with less than $300 million in total assets have fewer items applicable
to them than do institutions with $300 million to $1 billion in assets. In addition, the
supplemental information schedule in the FFIEC 051, which replaced five entire schedules and
parts of certain other schedules that had been in the FFIEC 041, includes nine indicator questions
with “yes”/”no” responses that ask about an institution’s involvement in certain complex or
specialized activities. Only if the response to a particular indicator question is a “yes” is an
institution required to complete an average of three indicator items that provide data on the
extent of the institution’s involvement in that activity.
Exemptions from reporting certain Call Report data within the FFIEC 041 report form
also apply to institutions with less than $500 million, $1 billion, and $10 billion in total assets. In
both the FFIEC 051 and the FFIEC 041, other exemptions are based on activity levels rather than
total assets and these activity-based thresholds tend to benefit small institutions. In addition, for
small institutions with domestic offices only and less than $1 billion in total assets that file the
FFIEC 051, a significant number of data items in the FFIEC 051 report are collected
semiannually or annually rather than quarterly as they had been when these institutions filed the
FFIEC 041 report.
6.

Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.

The agencies must have condition and income data at least quarterly to properly monitor
individual bank and industry trends and to comply with a statutory requirement to obtain four
reports of condition per year. Less frequent collection of this information would impair the
agencies’ ability to monitor financial institutions and could delay regulatory response.

3

7.

Explain any special circumstances that would cause an information collection to be
conducted in a manner inconsistent with 5 CFR 1320.5(d)(2).

This information collection is conducted in a manner consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Describe comments in response to the Federal Register notice and efforts to consult
outside the agency.

On December 18, 2020, the agencies, under the auspices of the FFIEC, published an
initial notice in the Federal Register (85 FR 82580) requesting public comment for 60 days on
the extension, with revision, of the Call Reports deposit insurance assessment-related revision.
The comment period for this notice expired on February 16, 2021. On February 5, 2021, the
agencies, under the auspices of the FFIEC, published an initial notice in the Federal Register (86
FR 8480) requesting public comment for 60 days on the extension, with revision, of the Call
Reports revisions related to brokered deposits and sweep deposits. The comment period for this
notice expired on April 6, 2021.
Deposit Insurance Assessment-Related Revision
The agencies received one comment on the December 2020 notice to revise the Call
Report to implement the FDIC’s proposed amendments to the deposit insurance assessment
system. The commenter discussed another potential double-counting in the computation of the
leverage ratio.
This comment is not specifically applicable to the deposit insurance assessment
regulations or the related revision to the Call Report addressed in the December 2020 notice. The
calculation of the leverage ratio in the Call Report is aligned with the calculation pursuant to the
agencies’ regulatory capital rules, which is outside the scope of the proposed changes.
To improve the clarity of the reporting changes for deposit insurance assessments, the
agencies plan to add examples to the instructions for Schedule RC-O, Memorandum item 5, to
show what an institution that has elected the three-year or the five-year 2020 CECL transition
provision would report in the new Memorandum item. These examples would be added at the
end of the instructions for the Schedule RC-O, Other Data for Deposit Insurance Assessments.
After considering the comments on the deposit insurance assessment-related revision, the
agencies are proceeding with the changes to the Call Reports as proposed with the added
examples to show what an institution would report in the new Memorandum item in Schedule
RC-O (FFIEC 031 and FFIEC 041 only).
Deposit-Related Revisions
The agencies received one comment letter from three trade associations on the February
2021 notice to revise the Call Report forms and instructions related to sweep deposits. The
commenters recommended that institutions that report sweep deposits on the Board’s Complex
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Institution Liquidity Monitoring Report (FR 2052a; OMB No. 7100-0361) should not be
required to provide comparable data on the Call Report. Additionally, the commenters requested
that the proposed Call Report memorandum items receive confidential treatment consistent with
the treatment of comparable data items provided on the FR 2052a. The commenters further
requested that the proposed Call Report memorandum items be delayed until the March 2022
report date. The commenters requested that the agencies confirm whether institutions are
permitted to incorporate the new brokered deposits regime for purposes of reporting beginning
with the June 30, 2021 Call Report, even if such institutions are still in the primary purpose
exception application process. Finally, the commenters requested clarification with respect to the
definition of “not fully insured” as it would apply to the proposed Call Report memorandum
items.
The FR 2052a is required to be filed on a consolidated basis by (1) certain top -tier bank
holding companies and top-tier covered savings and loan holding companies that in each case
have consolidated assets of $100 billion or more, and (2) certain foreign banking organizations
with combined U.S. assets of $100 billion or more. The largest and most complex FR 2052a
filers additionally submit data in respect to a limited number of subsidiaries, including large
depository institution subsidiaries, and U.S. branches. The FR 2052a report is collected on a
daily or monthly basis, depending on the size of the reporting organization. 1 In contrast, the
proposed Call Report data collection would reflect deposit data from all depository institutions
regardless of size. The Call Report data also would be collected on a quarterly or semiannual
basis. Due to the differences in scope and frequency of the reporting, the agencies do not believe
that there is material duplication between the data requested.
Regarding the comment on confidential treatment, the Board notes that the information
collected in the FR 2052a is collected as part of the agencies’ supervisory framework and is
provided confidential treatment for several reasons. The FR 2052a collection is reported on a
frequent basis and includes a wide range of financial exposures providing detailed information
on the liquidity profile of reporting firms (e.g., financing of securities positions and prime
brokerage activities). Additionally, FR 2052a data is used as a supervisory tool to monitor
individual organizations’ overall liquidity profile, including during periods of stress, and may
reflect risks and exposures between a respondent’s material legal entities. As a resu lt, public
availability of an individual banking organization’s detailed and frequent FR 2052a data could
result in disclosure of proprietary business information.
By comparison, the proposed Call Report data items would be reported on a less frequent
basis (quarterly or semiannually) by all individual depository institutions and do not include the
same extensive scope of items reported under the FR 2052a collection. The agencies therefore do
not believe public disclosure of the proposed Call Report data items would result in disclosure of
proprietary business information which would harm a bank’s competitive position. For example,
because the proposed Call Report data items would be reported on a quarterly or semiannual
In general, banking organizations subject to the full liquidity coverage ratio requirements of the agencies’ Liquidity
Coverage Ratio (LCR) rule, including all Category I and II banking organizations and certain Category III banking
organizations (as such categories are defined in the rule), must submit the FR 2052a data on a daily basis while other
banking organizations with total consolidated assets greater than $100 billion, including certain Category III and all
Category IV banking organizations, must submit FR 2052a data on a monthly basis.
1

5

basis and constitute limited information about a bank’s liquidity risk or structural funding, it
would not be possible for the public to determine an individual bank’s Liquidity Coverage Ratio
(LCR) or NSFR at any point within a quarter. 2 Therefore, the agencies are not proposing to adopt
confidential treatment for the proposed Call Report memorandum items.
With regard to the implementation date of the revisions to the Call Reports, the agencies
acknowledge that institutions may need additional time to make system changes to capture the
relevant data. Accordingly, in response to comments, the agencies are proposing to delay the
implementation date for the new memorandum items in the Call Report forms and instructions
until the September 30, 2021, reporting date rather than for June 30, 2021, as originally
proposed. As the collection in the FFIEC 051 occurs semiannually, FFIEC 051 filers will report
the new data items for the first time for the December 31, 2021, reporting date. This delay should
provide institutions with sufficient additional time to put in place systems to begin reporting on
the proposed memorandum items.
The agencies will provide clarifications in the Call Report Glossary and Schedule RC-E,
Deposit Liabilities instructions in response to comments related to reporting deposits as brokered
in instances where a primary purpose application is pending or where an institution wishes to
rely upon a previous staff advisory opinion or interpretation through December 31, 2021.
With respect to pending applications for a primary purpose exception, an IDI that
receives deposits from a third party that is a “deposit broker” where an application for a primary
purpose exception is pending, would report such deposits as brokered deposits if and until the
FDIC approves such application. This is because the deposits being placed by or through a third
party that is a deposit broker are brokered deposits unless the third party meets an exception to
the definition.
In response to the commenters’ request, the agencies are clarifying the definition of “not
fully insured” as it would apply to the deposit-related Call Report revisions. As described in the
agencies’ February 2021 notice, the proposal aligns with the final NSFR rule and revised Call
Report Glossary definition of “Sweep Deposits.” Under the agencies’ LCR and NSFR rules, a
sweep deposit is considered “fully insured” if the entire amount of the sweep deposit is covered
by deposit insurance provided by the FDIC under the Federal Deposit Insurance Act. 3 A sweep
deposit is “not fully insured” if less than the entire balance of the sweep deposit is covered by
FDIC insurance.
The brokered deposits final rule included clarifications to the definition of “deposit
broker” in section 29(g) of the Federal Deposit Insurance Act and section 337.6(a)(5 ) of the
FDIC’s regulations. The meaning of the term “brokered deposit” depends on the meaning of the
term “deposit broker.” The term “Brokered Deposits” is defined in the Call Report Glossary, and
the term “deposit broker” is also addressed in instructions to Schedule RC-E, Deposit Liabilities.
Consistent with the agencies’ proposal to revise the Call Report instructions in the February 2021
notice, the agencies plan to update the Glossary and Schedule RC-E instructions to align with the
Holding companies subject to the agencies’ LCR and NSFR rules must publicly disclose their consolidated LCR
and NSFR on a quarterly basis.
3
12 U.S.C. § 1811 et seq.
2

6

clarifications to the definition of “deposit broker” in the brokered deposits final rule.
After considering the comments, the agencies are clarifying the proposed instructions as
described above and proceeding with the clarifications in the Call Report Glossary and Schedule
RC-E instructions related to the definition of “deposit broker.”
The agencies are also making several technical corrections to proposed revisions in the
February 2021 notice. In that notice, the agencies proposed to revise the Call Report instructions
to add the LCR rule’s definition 4 of “retail customer or counterparty,” but inadvertently excluded
references to living or testamentary trusts as part of that definition. The agencies will correct the
Call Report instructions to include the complete definition of retail customer or counterparty
from the agencies’ LCR rule.
In the February 2021 notice, the agencies stated that the Call Report instructions would
add the LCR rule’s definition of “wholesale customer or counterparty.” Because there are no
proposed line items that require the definition of wholesale customer or counterparty, the
agencies do not plan to make this change in the Call Report instructions.
Revised Memorandum Item for Non-Brokered Sweep Deposits
As part of the February 2021 notice, the agencies proposed including the following data
item that would be collected quarterly on the FFIEC 031 and FFIEC 041 Call Reports and
semiannually on the FFIEC 051 Call Report:
•

Memorandum item 1.i for total sweep deposits that are not brokered due to a primary
purpose exception, which corresponds to the 25 percent test exception above.
As provided in the February 2021 notice, the agencies intend to collect this data to
monitor sweep deposits that are not brokered due to the primary purpose exception to
determine the supervisory and deposit insurance assessment implications of these
deposits, if any.

However, the agencies note that certain sweep deposits placed by third parties with IDIs
may not be classified as brokered when the third party has an exclusive deposit placement
arrangement with only one IDI. 5 For example, a broker dealer that is sweeping excess customer
balances to only one IDI will not meet the deposit broker definition and therefore would not need
to rely upon a primary purpose exception. Only reflecting exclusions related to the primary
purpose exception could significantly limit the agencies’ ability to monitor non -brokered sweep
deposits. Therefore, to ensure a more complete collection of sweep deposits that are excluded
from being reported as brokered, the agencies are proposing the following memo item in place of
the proposed item above from the February 2021 notice:
• Memorandum item 1.i for total sweep deposits that are not brokered deposits.

4
5

79 FR 61439, 61527 (October 10, 2014).
12 CFR 337.6(a)(5).

7

Updates to the Glossary and instructions will provide clarifications for determining
whether certain third parties that place sweep deposits at IDIs are deposit brokers and the
exceptions to the definition of deposit broker.
As stated in the December 2020 notice, beginning with the June 30, 2021, Call Report,
Schedule RC-O, Memorandum item 5, “Applicable portion of the CECL transitional amount or
modified CECL transitional amount that has been added to retained earnings for regulatory
capital purposes as of the report date and is attributable to loans and leases held for investment,”
would be completed only by large and highly complex institutions that have adopted ASU 2016 13 and reported having a CECL transition election in effect as of the quarter-end report date.
The new deposit-related items would be effective starting with the September 30, 2021,
Call Report (FFIEC 031 and FFIEC 041), and with the December 31, 2021, Call Report
(FFIEC 051). These items are Schedule RC-E, Memorandum items 1.h.(1) through 1.h.(4) and
1.i. Thereafter, these data items would be collected quarterly on the FFIEC 031 and FFIEC 041
Call Reports and semiannually on the FFIEC 051 Call Report. Beginning as of the same report
date, all institutions filing the FFIEC 031 Call Report with $100 billion or more in total assets
would report deposit data in four additional items in Schedule RC-E, Memorandum items
1.h.(1)(a), 1.h.(2)(a), 1.h.(3)(a), and 1.h.(4)(a).
The agencies note that the brokered deposits final rule became effective April 1, 2021,
with a mandatory compliance date of January 1, 2022. Therefore, for the September 30, 2021,
Call Report dates, institutions may rely on either existing staff advisory opinions and
interpretations or the new provisions in the brokered deposits final rule when assessing w hether a
sweep deposit is brokered for Call Report purposes. The agencies will make available on the
FFIEC website redline changes to the Glossary instructions for brokered deposits.
On May 24, 2021, the agencies, under the auspices of the FFIEC, published a final notice
in the Federal Register (86 FR 27961) requesting public comment for 30 days on the extension,
with revision, of the Call Reports. The comment period for this notice expires on June 23, 2021.
9.

Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There are no payments or gifts provided to respondents.

10.

Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy. If the collection requires a
systems of records notice (SORN) or privacy impact assessment (PIA), those should
be cited and described here.

Most of the information provided on the Call Reports is made public. However, the
following items are confidential: (1) the FDIC deposit insurance assessment information reported
in response to item 2.g on schedule RI-E, (2) the prepaid deposit insurance assessments
information reported in response to item 6.f on schedule RC-F, and (3) the information regarding
other data for deposit insurance and FICO assessments reported in response to memorandum

8

items 6-9, 14-15, and 18 on schedule RC-O. Board staff have determined that it is possible to
reverse engineer an institution’s Capital, Asset Quality, Management, Earnings, Liquidity, and
Sensitivity (CAMELS) rating based on the data reported under the FDIC deposit insurance
assessment data item and the prepaid deposit insurance assessments data item. If this information
were publicly available, it would be possible to determine the state member bank’s CAMELS
rating. Therefore, this information can be kept confidential under exemption 8 of the Freedom of
Information Act (FOIA), which specifically exempts from disclosure information “conta ined 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” (5 U.S.C. §
552(b)(8)). Board staff have also advised that the release of this information and information
regarding other data for deposit insurance and FICO assessments reported in response to
memorandum items 6-9, 14-15, and 18 on schedule RC-O would likely cause substantial harm to
the competitive position of the institution from whom the information was obtained if it was
released. Therefore, this information can be kept confidential also under exemption 4 of FOIA,
which exempts “trade secrets and commercial or financial information obtained from a person
and privileged or confidential” (5 U.S.C. § 552(b)(4)). Additionally, items on Call Report,
Schedule RC-C, Part I, for loans modified under Section 4013, Memorandum item 16.a,
“Number of Section 4013 loans outstanding”; and Memorandum item 16.b, “Outstanding
balance of Section 4013 loans” are considered confidential. The Board is collecting Section 4013
loan information as part of condition reports for the impacted state member banks and the Board
considers disclosure of these items at the bank level would not be in the public interest. Such
information is permitted to be collected on a confidential basis, consistent with 5 U.S.C.
552(b)(8). In addition, state member banks may be reluctant to offer modifications under Section
4013 if information on these modifications made by each state member bank is publicly
available, as analysts, investors, and other users of public Call Report information may penalize
an institution for using the relief provided by the CARES Act. The Board may disclose Section
4013 loan data on an aggregated basis, consistent with confidentiality or as otherwise required by
law.
11.

Provide additional justification for any questions of a sensitive nature.
There are no questions of a sensitive nature.

12.

Provide estimates of the annual hourly burden of the collection of information.

As shown in the table below, the estimated total annual burden for the Call Reports is
132,205 hours, and would increase to 132,845 hours with the proposed revisions. The average
estimated hours per response for Board Call Report filers would increase from 45.40 hours to
45.62 hours due to the proposed revisions. The estimated average hours per response for the
quarterly filings of the Call Report is a weighted average of the three versions of the Call Report
(FFIEC 031, FFIEC 041, and FFIEC 051). Both the weighted average Call Report burden
estimate and the three separate versions of the Call Report vary by agency because of differences
in the composition of the institutions under each agency’s supervision (e.g., size distribution of
institutions, types of activities in which they are engaged, and existence of foreign offices).
These reporting requirements represent 1.7 percent of the Board’s total paperwork burden.

9

Estimated
number of
respondents

Annual
frequency

Current

728

4

45.40

132,205

Proposed

728

4

45.62

132,845

FFIEC 031, FFIEC 041, and
FFIEC 051

Estimated
Estimated
average hours annual burden
per response
hours

Change

640

The estimated total annual cost to the public for the Call Reports is $7,857,782.
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 $73, 15% Lawyers at $72, and 10% Chief Executives
at $95). 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 2020,
published March 31, 2021, http://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, http://www.bls.gov/soc/.
13.

Provide an estimate for the total annual cost burden to respondents or record
keepers resulting from the collection of information.
There are no annualized costs to the respondents.

14.

Provide estimates of annualized costs to the Federal government.

The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 031, FFIEC 041, and FFIEC 051 is $1,871,500 per year.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
Deposit Insurance Assessment-Related Revision

Upon adoption of the CECL methodology, an institution will record a one-time
adjustment to its credit loss allowances as of the beginning of its fiscal year of adoption equal to
the difference, if any, between the amount of credit loss allowances required under the incurred
loss methodology and the amount of credit loss allowances required under CECL. An
institution’s implementation of CECL will affect its retained earnings, deferred tax assets, credit
loss allowances, and, as a result, its regulatory capital ratios.
In recognition of the potential for the implementation of CECL to affect regulatory
capital ratios, on February 14, 2019, the agencies issued a final rule that revised certain
regulations, including the agencies’ regulatory capital regulations (capital rule), 6 to account for
6

12 CFR Part 3 (OCC); 12 CFR Part 217 (Board); 12 CFR Part 324 (FDIC).

10

the aforementioned changes to credit loss accounting under U.S. generally accepted accounting
principles (GAAP), including CECL (2019 CECL rule). 7 The 2019 CECL rule includes a
transition provision that allows institutions to phase in over a three-year period the day-one
adverse effects of CECL on their regulatory capital ratios.
As part of the efforts to address the disruption of economic activity in the United States
caused by the spread of the coronavirus disease 2019 (COVID–19), on March 31, 2020, the
agencies adopted a second CECL transition provision through an interim final rule. 8 The
agencies subsequently adopted a final rule (2020 CECL rule) on September 30, 2020, that is
consistent with the interim final rule, with some clarifications and adjustments related to the
calculation of the transition and the eligibility criteria for using the 2020 CECL transition
provision.9 The 2020 CECL rule provides that only institutions that adopt CECL for a fiscal year
that begins during the 2020 calendar year, have the option to delay for up to two years an
estimate of CECL’s effect on regulatory capital, followed by a three-year transition period (i.e., a
five-year transition period in total). The 2020 CECL rule does not replace the three-year
transition provision in the 2019 CECL rule, which remains available to any institution at the time
that it adopts CECL. 10
Certain financial measures that are used to determine assessment rates for large and
highly complex institutions11 are calculated using both Tier 1 capital and reserves. For
institutions that elect either the three-year transition provision contained in the 2019 CECL rule
or the five-year transition provision contained in the 2020 CECL rule, the amount of Tier 1
capital reported in Call Report Schedule RC-R, Part I, item 26, includes (due to adjustments to
the amount of retained earnings reported on the Call Report balance sheet) the applicable portion
of the CECL transitional amount (or the modified CECL transitional amount). For deposit
insurance assessment purposes, reserves are calculated using the amount of the allowance for
loan and lease losses reported in Call Report Schedule RC, item 4.c. For all institutions that have
adopted CECL, Schedule RC, item 4.c, reflects the allowance for credit losses on loans and
leases. The issue of double counting arises in certain financial measures used to determine
assessment rates for large and highly complex institutions that are calculated using both Tier 1
capital and reserves because the allowance for credit losses on loans and leases is included
during the transition period in both reserves and, as a portion of the CECL or modified CECL
transitional amount, Tier 1 capital.
For institutions that elect either the three-year transition provision contained in the 2019
CECL rule or the five-year transition provision contained in the 2020 CECL rule, the CECL
transitional amounts, as defined in the regulatory capital rules, 12 additionally include the effect
on retained earnings, net of tax effect, of establishing allowances for credit losses in accordance
with the CECL methodology on held-to-maturity (HTM) debt securities, other financial assets
measured at amortized cost, and off-balance sheet credit exposures as of the beginning of the
7

84 FR 4222 (February 14, 2019).
85 FR 17723 (March 31, 2020).
9
See 85 FR 61577 (September 30, 2020).
10
See 85 FR 61578 (September 30, 2020).
11
See 12 CFR 327.8 and 12 CFR 327.16(f).
12
See 12 CFR 3.301 (OCC); 12 CFR 217.301 (Board); 12 CFR 324.301 (FDIC).
8

11

fiscal year of adoption. The applicable portions of the CECL transitional amounts attributable to
allowances for credit losses on HTM debt securities, other financial assets measured at amortized
cost, and off-balance sheet credit exposures are included in Tier 1 capital only and are not double
counted with reserves for deposit insurance assessment purposes.
To address the temporary deposit insurance assessment effects resulting from certain
optional regulatory capital transition provisions under the 2019 and 2020 CECL rules, the FDIC
proposed amendments to the deposit insurance assessment system applicable to all large and
highly complex IDIs on December 7, 2020. 13 Under these proposed amendments to the
assessment system, the FDIC would remove the double counting of the applicable portion of the
CECL transitional amounts that is added to retained earnings for regulatory capital purposes and
is attributable to the allowance for credit losses on loans and leases held for investment in certain
financial measures that are calculated using the sum of Tier 1 capital and reserves, and also from
the loss severity measure, which are used to determine assessment rates for large and highly
complex institutions.
In calculating certain financial measures used in the scorecards for determining deposit
insurance assessment rates for large and highly complex institutions, the FDIC has proposed to
remove a portion of the CECL transitional amounts added to retained earnings for regulatory
capital purposes under the transitions provided for under the 2019 or 2020 CECL rules.
Specifically, in certain measures used in the scorecard approach for determining assessment rates
for large and highly complex institutions, the applicable portion of the CECL transitional amount
(or modified CECL transitional amount) that is added to retained earnings for regulatory capital
purposes and is attributable to the allowance for credit losses on loans and leases held for
investment would be removed under the FDIC’s proposal. However, large and highly complex
institutions that have elected a CECL transition provision do not currently report these specific
portions of the CECL transitional amounts in the Call Report. Thus, implementing the FDIC’s
proposed amendments to the risk-based deposit insurance assessment system applicable to large
and highly complex institutions requires a new, temporary memorandum item and corresponding
changes to the FFIEC 031 and FFIEC 041 versions of the Call Report forms and instructions.
In this regard, the CECL effective dates assigned by the Financial Accounting Standards
Board’s Accounting Standards Update (ASU) No. 2016-13, Financial Instruments—Credit
Losses, Topic 326, Measurement of Credit Losses on Financial Instruments (ASU 2016-13) as
most recently amended by ASU No. 2019-10, the optional temporary relief from complying with
CECL afforded by the CARES Act, and the transitions under the 2019 CECL rule and 2020
CECL rule provide that, at present, all institutions will have completely reflected in regulatory
capital the day-one effects of CECL (plus, if applicable, an estimate of CECL’s effect on
regulatory capital, relative to the incurred loss methodology’s effect on regulatory capital, during
the first two years of CECL adoption) by December 31, 2026. As a result, the reporting change
for large and highly complex institutions would be required only while the temporary relief
under the 2019 and 2020 CECL rules is reflected in institutions’ Call Reports. The agencies
would remove the proposed new Call Report item when all large and highly complex institutions
are no longer using a CECL transition.
13

85 FR 78794 (December 7, 2020).

12

Specifically, the agencies propose to add a new Memorandum item 5 to Schedule RC-O,
Other Data for Deposit Insurance Assessments, in the FFIEC 031 and the FFIEC 041 Call
Reports, only in order to quantify the applicable portions of the CECL transitional amounts
added to retained earnings for regulatory capital purposes and attributable to the allowance for
credit losses on loans and leases held for investment. The removal of this portion of the CECL
transitional amounts is needed because, for large and highly complex institutions that have
adopted CECL, the measure of reserves used in the scorecard is limited to the allowance for
credit losses on loans and leases.
To adjust the calculations of certain financial measures used to determine deposit
insurance assessment rates for large and highly complex institutions, the FDIC would remove the
amount reported in the new Schedule RC-O Memorandum item from scorecard measures that are
calculated using the sum of Tier 1 capital and reserves and also from the loss severity measure in
the scorecards.
Beginning with the June 30, 2021, Call Report, Schedule RC-O, Memorandum item 5,
“Applicable portion of the CECL transitional amount or modified CECL transitional amount that
has been added to retained earnings for regulatory capital purposes as of the report date and is
attributable to loans and leases held for investment,” would be completed only by large and
highly complex institutions that have adopted ASU 2016-13 and reported having a CECL
transition election in effect as of the quarter-end report date.
Revisions Related to Brokered Deposits and Sweep Deposits
Net Stable Funding Ratio Rulemaking
On October 20, 2020, the agencies announced the adoption of a final rule implementing
the NSFR relevant for certain large U.S. banking institutions with $100 billion or more in total
consolidated assets.14 The final rule assigned a 90 percent Available Stable Funding (ASF) factor
to affiliate sweep deposits provided by a retail customer or counterparty. Also, a 95 percent ASF
factor was assigned to affiliate sweep deposits provided by a retail customer or counterparty
where the entire amount of the sweep deposit is covered by deposit insurance and where an
institution subject to the NSFR final rule has demonstrated to the satisfaction of its appropriate
Federal banking agency that withdrawal of the deposit is highly unlikely to occ ur during a
liquidity stress event. Other sweep deposits (i.e., non-affiliate sweep deposits provided by a retail
customer or counterparty and certain sweep deposits provided by wholesale, non-financial
customers) were assigned a 50 percent ASF factor, irrespective of the level of deposit insurance.
Additionally, in the Supplementary Information section to the NSFR final rule, the agencies
indicated they will continue to review the treatment of sweep deposits under the Liquidity
Coverage Ratio (LCR) and NSFR rules.15 As part of this effort, the agencies are proposing to
collect new data items in the Call Reports that would help evaluate funding stability of sweep
deposits over time to determine their appropriate treatment under applicable liquidity regulations.
14

See the NSFR final rule attached to OCC News Release 2020-138, Board Press Release, and FDIC Press Release
116-2020, all of which are dated October 20, 2020.
15
12 CFR Part 50 (OCC); 12 CFR Part 249 (Board); 12 CFR Part 329 (FDIC) (referred to as the liquidity
regulations).

13

This proposal to capture new Call Report data items for sweep deposits would provide
the agencies with several benefits for its understanding of liquidity risks relevant to institutions
of all sizes. First, the agencies would be able to better observe funding dynamics, between
insured and partially insured sweep deposits, thereby providing data on the funding stability of
partially insured sweep deposits. Second, by having institutions with $100 billion or more in total
assets report sweep deposits for different types of counterparties, any material differences in the
stability of different types of counterparties that transact in sweep deposits would be more
transparent for monitoring over time to determine their appropriate treatment under liquidity
regulations.
Further, as noted in the NSFR final rule, sweep deposits received from affiliates have
different stability characteristics than sweep deposits received from non -affiliates based on the
varying priority and reliability of each affiliate and non-affiliate sweep deposits. The proposed
new data items would provide the agencies with observations about the varying liquidity and
other risk characteristics of these different types of sweep deposits.
Brokered Deposits Rulemaking
On December 15, 2020, the FDIC issued the brokered deposits final rule. 16 This rule
accomplished several objectives, including establishing a new framework for analyzing certain
provisions of the “deposit broker” definition, 17 including “facilitating” and “primary purpose.”18
The brokered deposits final rule also reaffirmed the intent stated in the interagency NSFR final
rule to update the Call Report to collect information related to sweep deposits.19 The FDIC plans
to monitor this data and could consider in the future whether modifications to deposit insurance
assessment pricing are warranted, consistent with the statutory requirement that the assessments
be risk-based.
Relevant for brokered deposits, section 29 of the FDI Act provides that an agent or
nominee meets the primary purpose exception to the “deposit broker” definition when the
primary purpose of the agent or nominee is not the placement of funds with depository
institutions. In the brokered deposits final rule, the FDIC adopted revised criteria for the primary
purpose exception based on the relationship between the agent or nominee and its customers.
Specifically, the primary purpose exception applies when the primary purpose of the agent’s or
nominee’s business relationship with its customers is not the placement of funds with depository
institutions. The following business relationships were identified in the brokered deposits final
rule as “designated exceptions” from the deposit broker definition and are business relationships
in which, with respect to a particular business line:
(1) less than 25 percent of the total assets that the agent or nominee has under
administration for its customers is placed at depository institutions (25 percent test),
(2) 100 percent of depositors’ funds that the agent or nominee places, or assists in
16

86 FR 6742 (January 22, 2021).
See Section 29(g) of the Federal Deposit Insurance Act (FDI Act) (12 U.S.C. § 1831f(g)).
18
The final rule also amended the FDIC’s methodology for calculating the national rate, the national rate cap, and
the local market rate cap for the interest rate restrictions under section 29 that apply to less than well-capitalized
institutions.
19
86 FR 6742 (January 22, 2021).
17

14

placing, at depository institutions are placed into transactional accounts that do not pay any fees,
interest, or other remuneration to the depositor,
(3) a property management firm places, or assists in placing, customer funds into d eposit
accounts for the primary purpose of providing property management services,
(4) the agent or nominee places, or assists in placing, customer funds into deposit
accounts for the primary purpose of providing cross-border clearing services to its customers,
(5) the agent or nominee places, or assists in placing, customer funds into deposit
accounts for the primary purpose of providing mortgage servicing,
(6) a title company places, or assists in placing, customer funds into deposit accounts for
the primary purpose of facilitating real estate transactions,
(7) a qualified intermediary places, or assists in placing, customer funds into deposit
accounts for the primary purpose of facilitating exchanges of properties under section 1031 of
the Internal Revenue Code,
(8) a broker-dealer or futures commission merchant places, or assists in placing, customer
funds into deposit accounts in compliance with 17 CFR 240.15c3-3(e) or 17 CFR 1.20(a),
(9) the agent or nominee places, or assists in placing, customer funds into deposit
accounts for the primary purpose of posting collateral for customers to secure credit-card loans,
(10) the agent or nominee places, or assists in placing, customer funds into deposit
accounts for the primary purpose of paying for or reimbursing qualified medical expenses under
section 223 of the Internal Revenue Code,
(11) the agent or nominee places, or assists in placing, customer funds into deposit
accounts for the primary purpose of investing in qualified tuition programs under section 529 of
the Internal Revenue Code,
(12) the agent or nominee places, or assists in placing, customer funds into deposit
accounts to enable participation in the following tax-advantaged programs: individual retirement
accounts under section 408(a) of the Internal Revenue Code, Simple individual retirement
accounts under section 408(p) of the Internal Revenue Code, and Roth individual retirement
accounts under section 408A of the Internal Revenue Code,
(13) a Federal, State, or local agency places, or assists in placing, customer funds into
deposit accounts to deliver funds to the beneficiaries of government programs, and
(14) the agent or nominee places, or assists in placing, customer funds into deposit
accounts pursuant to such other relationships as the FDIC specifically identifies as a designated
business relationship that meets the primary purpose exception.
The brokered deposits final rule discussed the FDIC’s consideration, as part of the
rulemaking process, for requiring reporting of deposits that are excluded from being reported as
brokered deposits because of the application of the primary purpose exception, which may
include sweep deposits placed at insured depository institutions. Supervision and deposit
insurance assessments evaluate risk, in part, based on data institutions report on the Call Report.
Institutions report total brokered deposits but generally do not distinguish between different
types of deposits that are currently classified as brokered. As a result of the final rule, the FDIC
expects that some sweep deposits that are currently brokered deposits placed by third parties will
meet the revised primary purpose exception and therefore no longer be reported on the Call
Report as brokered. Sweep deposits placed by a third party that meet the p rimary purpose
exception may, in some cases, still pose varying levels of funding risk as well as elevated risk of

15

loss to the deposit insurance fund in the event of an insured depository institution’s failure. 20 As
such, FDIC plans to monitor sweep deposits that are not brokered due to the primary purpose
exception over time to determine the supervisory and deposit insurance assessment implications
of these deposits, if any. As such, the agencies are proposing including an additional Call Report
item related to sweep deposits placed by third parties that meet the primary purpose exception.
Proposed Data Items to Capture Sweep Deposits and Deposits Categorized as
Meeting the Primary Purpose Exception and Related Instructions
Under the NSFR Final Rule and the brokered deposits final rule, the agencies stated their
intent to update the Call Report to obtain data that will assist in better evaluations of funding
stability for sweep deposits over time to determine their appropriate treatment under applicab le
liquidity regulations and to assess the risk factors associated with sweep deposits for determining
their deposit insurance assessment implications, if any. Accordingly, the agencies propose to add
the following data items applicable to all institutions that file the Call Report. Specifically, the
following five data items would be added to Schedule RC-E, Deposit Liabilities, on all three
versions of the Call Report (FFIEC 031, FFIEC 041, and FFIEC 051). These five data items
would be collected quarterly on the FFIEC 031 and FFIEC 041 Call Reports and semiannually
on the FFIEC 051 Call Report.
• Memorandum item 1.h.(1) for fully insured, affiliate sweep deposits to capture sweep
deposits that are deposited in accordance with a contract between a customer or
counterparty and the reporting institution, a controlled subsidiary of the reporting
institution, or a company that is a controlled subsidiary of the same top -tier company of
which the reporting institution is a controlled subsidiary, where the entire amo unt of the
deposit is covered by deposit insurance,
• Memorandum item 1.h.(2) for not fully insured, affiliate sweep deposits to capture sweep
deposits that are deposited in accordance with a contract between a customer or
counterparty and the reporting institution, a controlled subsidiary of the reporting
institution, or a company that is a controlled subsidiary of the same top -tier company of
which the reporting institution is a controlled subsidiary, where less than the entire
amount of the deposit is covered by deposit insurance,
• Memorandum item 1.h.(3) for fully insured, non-affiliate sweep deposits to capture
sweep deposits that are not deposited in accordance with a contract between a customer
or counterparty and the reporting institution, a controlled subsidiary of the reporting
institution, or a company that is a controlled subsidiary of the same top -tier company of
which the reporting institution is a controlled subsidiary, where the entire amount of the
deposit is covered by deposit insurance,
• Memorandum item 1.h.(4) for not fully insured, non-affiliate sweep deposits to capture
sweep deposits that are not deposited in accordance with a contract between a customer
or counterparty and the reporting institution, a controlled subsidiary of the reporting
institution, or a company that is a controlled subsidiary of the same top -tier company of
As described in the preamble to the brokered deposits final rule, “Nothing in the final rule is intended to limit the
FDIC’s ability to review or take supervisory action with respect to funding-related matters, including funding
concentrations, that may affect the safety and soundness of individual banks or the industry generally. FDIC
examiners will continue to review funding as part of safety and soundness examinations, regardless of whether or
not the deposits used by the [insured depository institution] IDI are brokered.”
20

16

•

which the reporting institution is a controlled subsidiary, where less than the entire
amount of the deposit is covered by deposit insurance, and
Memorandum item 1.i for total sweep deposits that are not brokered due to a primary
purpose exception, which corresponds to the 25 percent test exception above.

In addition, the following four data items would be added to Schedule RC-E, Deposit
Liabilities, on the FFIEC 031 Call Report only and would be completed quarterly only by
institutions with $100 billion or more in total assets.21
• Memorandum item 1.h.(1)(a) to capture the portion of fully insured, affiliate sweep
deposits reported in Memorandum item 1.h.(1) that are deposited in accordance with a
contract between a retail customer or counterparty and the reporting institution, a
controlled subsidiary of the reporting institution, or a company that is a controlled
subsidiary of the same top-tier company of which the reporting institution is a controlled
subsidiary, where the entire amount of the deposit is covered by deposit insurance,
• Memorandum item 1.h.(2)(a) to capture the portion of not fully insured, affiliate sweep
deposits reported in Memorandum item 1.h.(2) that are deposited in accordance with a
contract between a retail customer or counterparty and the reporting institution, a
controlled subsidiary of the reporting institution, or a company that is a controlled
subsidiary of the same top-tier company of which the reporting institution is a controlled
subsidiary, where less than the entire amount of the deposit is covered by deposit
insurance,
• Memorandum item 1.h.(3)(a) to capture the portion of fully insured, non-affiliate sweep
deposits reported in Memorandum item 1.h.(3) that are deposited by a retail customer or
counterparty and not in accordance with a contract between the retail customer or
counterparty and the reporting institution, a controlled subsidiary of the reporting
institution, or a company that is a controlled subsidiary of the same top-tier company of
which the reporting institution is a controlled subsidiary, where the entire amount of the
deposit is covered by deposit insurance, and
• Memorandum item 1.h.(4)(a) to capture the portion of not fully insured, non-affiliate
sweep deposits reported in Memorandum item 1.h.(4) that are deposited by a retail
customer or counterparty and not in accordance with a contract between the retail
customer or counterparty and the reporting institution, a controlled subsidiary of the
reporting institution, or a company that is a controlled subsidiary of the same top -tier
company of which the reporting institution is a controlled subsidiary, where less than the
entire amount of the deposit is covered by deposit insurance.
Definitions
The agencies propose to revise the Call Report instructions to add the following
definition for “sweep deposit”: A sweep deposit means a deposit held at the reporting institution
by a customer or counterparty through a contractual feature that automatically transfers to the
reporting institution from another regulated financial company at the close of each business day
amounts identified under the agreement governing the account from which the amount is being
21

The $100 billion asset-size test is based on the total assets reported as of June 30 each year to determine whether
an institution not otherwise required to file the FFIEC 031 Call Report must file the FFIEC 031 report form
beginning in March of the following year.

17

transferred.22 Note: This definition would be distinctly separate from the existing “retail sweep
arrangements” and “retail sweep programs” definitions in the Glossary entry for “Deposits” in
the Call Report instructions.
Furthermore, consistent with the discussion of the data items proposed to be collected in
the Call Report, “affiliate sweep deposits” would be defined as sweep deposits that are deposited
in accordance with a contract between a customer or counterparty and a reporting institution, a
reporting institution’s consolidated subsidiary, or a company that is a consolidated subsidiary of
the same top-tier company of which the reporting institution is a consolidated subsidiary. “Nonaffiliate sweep deposits” would be defined as sweep deposits that are not deposited in accordance
with a contract between a customer or counterparty and a reporting institution, a reporting
institution’s consolidated subsidiary, or a company that is a consolidated subsidiary of the same
top-tier company of which the reporting institution is a consolidated subsidiary.
The agencies also propose to revise the Call Report instructions to add the LCR rule’s
definition 23 of “retail customer or counterparty,” which reads, “A retail customer or counterparty
means a customer or counterparty that is:
(1) An individual, or
(2) A business customer, but solely if and to the extent that (i) The reporting institution
manages its transactions with the business customer, including deposits, unsecured funding, and
credit facility and liquidity facility transactions, in the same way it manages its transactions with
individuals, (ii) Transactions with the business customer have liquidity risk characteristics that
are similar to comparable transactions with individuals, and (iii) The total aggregate funding
raised from the business customer is less than $1.5 million.”
In addition, the Call Report instructions would add the LCR rule’s def inition of
“wholesale customer or counterparty,” which reads, “A wholesale customer or counterparty
means a customer or counterparty that is not a retail customer or counterparty.” 24
Beginning with the June 30, 2021, report date, the agencies propose all institutions filing
the FFIEC 031, FFIEC 041, and FFIEC 051 Call Reports would complete Schedule RC-E,
Memorandum items 1.h.(1) through 1.h.(4) and 1.i, to report the deposit data. Thereafter, these
data items would be collected quarterly on the FFIEC 031 and FFIEC 041 Call Reports and
semiannually on the FFIEC 051 Call Report. Beginning as of the same report date, all
institutions filing the FFIEC 031 Call Report with $100 billion or more in total assets would
complete Schedule RC-E, Memorandum items 1.h.(1)(a), 1.h.(2)(a), 1.h.(3)(a), and 1.h.(4)(a) to
report the additional deposit data.
The brokered deposits final rule takes effect April 1, 2021. Full compliance with this final
rule is extended to January 1, 2022. The extended compliance date is intended to provide
sufficient time for institutions to put in place systems to implement the new regulatory regime.
See 79 FR 61524 for the LCR Rule’s definition of brokered sweep deposit which was renamed to “sweep deposit”
when the NSFR rule was finalized in October 2020, https://www.fdic.gov/news/board/2020/2020-10-20-notice-disb-fr.pdf.
23
79 FR 61439, 61527 (October 10, 2014).
24
79 FR 61439, 61528 (October 10, 2014).
22

18

The Call Report will provide two sets of instructions that will allow institutions to either
(1) comply with the new regulation starting on the June 30, 2021, report date, or (2) continue to
rely upon existing FDIC staff advisory opinions or other interpretations that predated the
brokered deposits final rule in determining whether deposits placed by or through an agent or
nominee are brokered deposits for purposes of reporting brokered deposit data in the Call Report
through the December 31, 2021, report date.
16.

Provide information regarding plans for publication of data.

Aggregate data are published in the Federal Reserve Bulletin and the Annual Statistical
Digest. Additionally, data are used in the Uniform Bank Performance Report (UBPR) and the
Annual Report of the FFIEC. Individual respondent data, excluding confidential information, are
available to the public from the National Technical Information Service in Springfield, Virginia,
upon request approximately twelve weeks after the report date. Data are also available from the
FFIEC Central Data Repository Public Data Distribution (CDR PDD) website
(https://cdr.ffiec.gov/public/). Data for the current quarter are made available, shortly after a
bank’s submission, beginning the first calendar day after the report date. Updated or revised data
may replace data already posted at any time thereafter.
17.

If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
No such approval is sought.

18.

Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
There are no exceptions.

19