FR2018_20210528_omb

Supporting Statement for the
Senior Loan Officer Opinion Survey on Bank Lending Practices
(FR 2018; OMB No. 7100-0058)
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,
without revision, the Senior Loan Officer Opinion Survey on Bank Lending Practices (SLOOS)
(FR 2018; OMB No. 7100-0058).1 A senior loan officer at each respondent bank completes this
voluntary survey through an electronic submission, up to six times a year. 2 Consistent with the
Senior Financial Officer Survey (FR 2023; OMB No. 7100-0223), senior staff at the Reserve
Banks with knowledge of bank lending practices serve as the main contacts for SLOOS
respondents in their district and help administer the survey. The current reporting panel consists
of up to 80 large domestically chartered commercial banks and up to 24 large U.S. branches and
agencies of foreign banks. The purpose of the survey is to provide qualitative and limited
quantitative information on credit availability and demand, as well as on evolving developments
and lending practices in the U.S. loan markets. A portion of each survey typically covers special
topics of timely interest; therefore, a sample form is not included in this proposal.
Although the Board has the authority to conduct the survey up to six times a year, the
survey has typically been conducted only four times a year since 1992. Consistent with the
FR 2023, other types of respondents, such as other depository institutions, bank holding
companies, or other financial entities, may be surveyed, if appropriate. The respondents’ answers
provide information that is critical to the Federal Reserve’s monitoring of bank lending practices
and credit markets. The Federal Reserve relies on the regular opportunity to solicit information
from banks within the framework of the survey. Aggregated survey results from 1997 to present
are available to the public on the Board’s website.3
The estimated total annual burden for the FR 2018 is 1,248 hours. There is no formal
reporting form for this collection of information; the FR 2018 designation is for internal purposes
only.

1

A portion of the FR 2018 information collection is ad hoc. Certain criteria apply to information collections
conducted via the Board’s ad hoc clearance process. Such information collections shall (1) be vetted by the Board’s
clearance officer, as well as the Division director responsible for the information collection, (2) display the OMB
control number, (3) inform respondents that the information collection has been approved, (4) be used only in such
cases where response is voluntary, (5) not be used to substantially inform regulatory actions or policy decisions,
(6) be conducted only and exactly as described in the OMB submission, (7) involve only noncontroversial subject
matter that will not raise concerns for other Federal agencies, (8) include information collection instruments that are
each conducted only one item, (9) include a detailed justification of the effective and efficient statistical survey
methodology (if applicable), and (10) collect personally identifiable information (PII) only to the extent necessary
(if collecting sensitive PII, the form must display current Privacy Act notice). In addition, for each information
collection instrument, respondent burden will be tracked and submitted to OMB.
2
In some cases, especially at larger banks, multiple loan officers complete the survey, with each loan officer
answering the questions relevant to their area of lending expertise. Up to two of the collections may be special
surveys.
3
See https://www.federalreserve.gov/data/sloos.htm.

Background and Justification
The Federal Reserve initiated a survey on bank lending practices in 1964. Until 1981, it
was conducted quarterly at 120 respondent banks and consisted of 22 standard questions, seeking
qualitative information with respect to changes in bank lending practices in the three months
preceding the survey date. The survey’s original questions dealt with perceived changes in
business loan demand, willingness to make business loans, various non-rate aspects of business
loan pricing, and willingness to extend consumer, mortgage, and certain other types of loans.
In 1981, the number of respondents was decreased by half, the number of core questions
was reduced to six, and a provision was made to include additional questions in each survey that
would address current topics on bank lending practices. In 1984, the authorized frequency was
increased from four to eight times a year, most of the remaining core questions were dropped,
and the survey came to consist mainly of questions focusing on one or more topics of current
interest. For example, banks were queried about the market for interest rate swaps, the market for
business loan sales and participations, business lending to middle market firms, and the effects of
tax changes on bank lending. In 1987, the Federal Reserve reduced the authorized frequency
from eight to six times a year after determining that this would reduce the burden on respondents
without compromising the Federal Reserve’s ability to keep abreast of important banking
developments. 4
In August 1990, the respondent panel was enlarged to include 18 of the largest U.S.
branches and agencies of foreign banks. In November 1994, the Board increased the number of
foreign banks surveyed to 24 to make the foreign bank coverage more thorough and to rectify an
under-representation of branches and agencies of European banks.
In May 2012, the Federal Reserve reduced the minimum asset size for panel institutions
from $3 billion to $2 billion and added 20 domestically chartered commercial banks with $2 to
$10 billion in total assets to the authorized panel. The expanded panel provided deeper coverage
of commercial real estate loans and small business lending, as well as a more comprehensive
picture of differences in lending conditions at the largest banks and regional banks.
The information obtained from the survey provides valuable insights on credit market and
banking developments and is helpful in the formulation of monetary policy. Information from the
survey is reported regularly to the Board and to the Federal Open Market Committee (FOMC) as
an official memorandum to FOMC participants and in other internal briefing materials. This
information has been particularly valuable in the recent period as it has provided the Federal
Reserve with insight into the effects of the coronavirus disease 2019 (COVID-19) crisis and the
subsequent potential gradual economic recovery on the availability of credit to households and
businesses. The survey has also attracted considerable attention from the business and financial

4

The survey was conducted five times in 1985, 1986, and 1987, four times in 1988 and 1989, five times in 1990,
and six times in 1991. Since that time, it has been conducted four times every year, except for 1998 and 2001, in
which the survey was conducted five times.

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press and is used in academic research on banking and macroeconomic activity. 5 Aggregate
survey responses have been used to study the effects of the more stringent international capital
requirements commonly referred to as Basel III. 6 The results are also included in the Board’s
reports to Congress on Availability of Credit to Small Businesses, which are produced every five
years pursuant to section 2227 of the Economic Growth and Regulatory Paperwork Reduction
Act of 1996. The survey results have also been useful in enabling the Federal Reserve to keep
abreast of complex banking developments that have evolved over time, and analysis based on the
survey results often appears in Federal Reserve publications as the Monetary Policy Report,
which is submitted to Congress semiannually, and the recently inaugurated Financial Stability
Report.
In the last several years, the survey has provided critical information on a number of
important banking topics. Recent special questions have addressed issues in rapidly c hanging
credit markets banks’ lending terms and outlook for commercial real estate lending standards and
demand, banks’ assessments of the levels of their lending standards relative to longer-term
norms, and banks’ expectations about changes in asset quality and credit standards over the
coming year. Regarding lending to households, the survey has provided valuable information on
timely topics including the asset quality of consumer loans in areas most affected by falling
energy prices, and the likelihood of approving credit card applications by borrowers’ credit
score. In addition, the survey helped shed light on broader issues, such as the relationship
between banks’ lending policies and movements in the yield curve for Treasury securities.
Description of Information Collection
The questions on the FR 2018 survey are generally qualitative. They are drafted with the
intent to elicit useful information without imposing undue reporting burden. To understand
certain banking practices, however, the Federal Reserve occasionally needs to ask quantitative
questions. The Federal Reserve has sought to limit the difficulty and quantitative content of
survey questions, insofar as an adequate understanding of the subject matter allows. When
quantitative information is requested, respondents generally are asked to provide approximate or
rough estimates, usually in terms of percentages rather than dollar amounts. A respondent may
decline to answer a particular question when answering would entail excessive burden.
Experience has shown that only a small number of respondents decline to answer any particular
question. Response rates overall have been high and resulted in adequate and informative
answers.
For a number of years the survey has included approximately 25 questions designed to
measure changes in credit standards and terms on bank loans and perceived changes in the
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Examples of academic research include William F. Bassett III, Mary Beth Chosak, John C. Driscoll, and Egon
Zakrajsek (2014). “Changes in Bank Lending Standards and the Macroeconomy,” Journal of Monetary Economics,
62(1), pp. 23-40, and Jose M. Berrospide and Rochelle M. Edge (2011). “The Effects of Bank Capital on Lending:
What Do We Know, and What Does it Mean?” International Journal of Central Banking, 6(4), pp. 5-54.
6
Examples of Basel III research include BIS (2010). “Assessing the Macroeconomic Impact of the Transition to
Stronger Capital and Liquidity Requirements,” Macroeconomic Assessment Group. Basel, Switzerland: Bank for
International Settlements, and Angela Maddaloni and Jose-Luis Peydro (2011). “Bank Risk-Taking, Securitization,
Supervision, and Low Interest Rates: Evidence from U.S. and Euro Area Lending Standards,” Review of Financial
Studies, 24(6), pp. 2121-2165 (https://academic.oup.com/rfs/article/24/6/2121/1587432).

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demand for bank credit. The survey has also normally included a number of special questions
about developments in banking practices. The Federal Reserve distributes two versions of the
survey, one to domestically chartered institutions and one to U.S. branches and agencies of
foreign banks. The survey tailored to the branches and agencies of foreign banks contains fewer
questions. Specifically, it omits both the recurring and the special questions on residential
mortgage and consumer lending because the branches and agencies typically make few, if any,
loans to households.
The FR 2018 survey also includes an ad hoc portion to conduct special surveys from a
selection of respondents, should the need arise to collect additional information on bank lending
conditions and practices.
The survey is generally completed through an electronic submission via an online survey
tool. In some cases, Federal Reserve Banks may conduct telephone interviews to help collect or
verify a respondent’s information; email or telephone follow-up may be needed at times with
institutions that did not respond or in cases in which further information is needed to process the
responses. Staff at the Federal Reserve banks review the survey responses and staff at the Board
review and summarize the aggregated survey results in internal memos and public reports.
Respondent Panel
The FR 2018 panel comprises domestically chartered commercial banks and U.S.
branches and agencies of foreign banks. In addition, the Federal Reserve has the option to survey
other types of respondents (such as other depository institutions, bank holding companies, or
other financial entities) in addition to the current panel.
Domestically Chartered Commercial Banks. Since 2012, the Federal Reserve has tried
to maintain a panel of 80 such banks, the authorized size (from 1981 to 2012, the Federal
Reserve tried to maintain a panel of 60 insured, domestically chartered commercial banks). To
ensure adequate geographic coverage, the survey panel of domestic banks spans all Federal
Reserve Districts, while balancing the need to keep it heavily weighted toward the largest banks.
When the largest banks in a District are not among its respondents, it is generally because the
banks are specialized (for example, credit card banks) or because they are part of a holding
company that is already represented in another District. The presence of the largest banks in the
survey is critical, as they play an important role in developing and practicing new banking
techniques. However, the panel also includes a fair number of large and medium-size regional
banks, which allows for a greater diversity of responses and provides a broader view of the
banking system.
As of March 31, 2020, the panel of domestic respondents contained 77 banks, 32 of
which had assets of $50 billion or more. The assets of the panel banks totaled $14.2 trillion and
accounted for about 71 percent of the $19.9 trillion in total assets of all domestically chartered
institutions.
Selection Criteria for the Domestic Bank Panel. In selecting the panel, the Federal
Reserve generally imposes three constraints. The first is size: Banks that have less than $2 billion
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of total assets or for which commercial and industrial (C&I) loans are less than 5 percent of total
assets are eliminated from consideration, with a few exceptions. 7 The second is geographic
diversity: Between four and eleven banks are included from each District. 8 The third is mutual
independence: With some exceptions, a bank is eliminated from consideration if it is a subsidiary
of a bank holding company that is already represented in the panel, because its responses would
likely not be independent of those of the related bank already providing responses. 9
U.S. Branches and Agencies of Foreign Banks. The Federal Reserve tries to maintain a
panel size of 24, the authorized size. As of March 2020, the panel included 22 institutions, 21 of
which are located in the New York District. In March 2020, the share of C&I loans held by
respondent U.S. branches and agencies of foreign banks ($280.2 billion) relative to that held by
the universe of such institutions ($408.4 billion) was 69 percent, up from 66 percent in June
2017. To keep the panel representative with respect to the parent banks’ countries of origin going
forward, branches and agencies would continue to be added to the panel based on the location of
the parent bank as well as size.
Optional Panel. The panels of large domestically chartered commercial banks and U.S.
branches and agencies of foreign banks would be appropriate for most survey topics. In some
situations, however, panels based on alternative criteria may be more appropriate or may provide
useful additional information. Consequently, the Federal Reserve has the option to survey other
types of respondents (such as other depository institutions, bank holding companies, or other
financial entities) in addition to the current panel. For example, it may be useful to survey
institutional loan investors to gain a better understanding of how that part of the syndicated loan
market works. This option enhances the potential scope and utility of the survey and is consistent
with the FR 2023. Also consistent with the FR 2023, the surveys of optional panels would be
conducted either by Federal Reserve Bank staff or Board staff, as appropriate.
Time Schedule for Information Collection
This survey is conducted as needed up to six times a year.
Public Availability of Data
The aggregated survey results are available in a public release, which is made available
on the Board’s website. 10 Aggregate data series from the survey are also available to the public
through the Board’s data download program. 11

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As of March 31, 2020, five banks had C&I loans that were less than 5 percent of total assets.
Two panel members have main offices in Federal Reserve Districts that are different from those t hat collect their
survey responses because in these cases the respondent bank (not the head office) is considered the primary lending
bank.
9
In cases where two banks under a common parent company are included in the panel, the Federal Reserve has
made efforts to determine that the banks’ responses to survey questions are independent.
10
For details see https://www.federalreserve.gov/data/sloos.htm.
11
For details see https://www.federalreserve.gov/datadownload/Choose.aspx?rel=sloos.
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Legal Status
Section 2A of the Federal Reserve Act (FRA) requires the Board and the Federal Open
Market Committee (FOMC) to maintain long run growth of the monetary and credit aggregates
commensurate with the economy’s long run potential to increase production, so as to promote
effectively the goals of maximum employment, stable prices, and moderate long-term interest
rates (12 U.S.C. § 225a) and section 12A of the FRA requires the FOMC to implement
regulations relating to the open market operations conducted by Federal Reserve Banks with a
view to accommodating commerce and business and with regard to their bearing upon the
general credit situation of the country (12 U.S.C. § 263). Because the Board and the FOMC use
the information obtained from the FR 2018 to fulfill these obligations, these statutory provisions
provide the legal authorization for the collection of information on the FR 2018. In addition,
section 11 of the FRA, which permits the Board to examine at its discretion the accounts, books,
and affairs of each Federal Reserve Bank and each member bank and to require such statements
and reports as it may deem necessary, authorizes the collection of information from depository
institutions (12 U.S.C. § 248(a)) and section 7 of the International Banking Act of 1978
authorizes the collection of information from branches and agencies o f foreign banks (12 U.S.C.
§ 3105(c)(2)). Survey submissions under the FR 2018 are voluntary.
Although the specific questions to be asked on each survey have not yet been formulated,
the questions are designed to obtain information that is customarily and actually treated as
private by the institution. Thus, the individual survey responses from each respondent may be
held confidential under exemption (4) of the Freedom of Information Act (5 U.S.C. § 552(b)(4)).
However, certain data from the survey is publicly reported in aggregate form, and the
information in aggregate form is made publicly available and not considered confidential.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On October 14, 2020, the Board published an initial notice in the Federal Register
(85 FR 65045) requesting public comment for 60 days on the extension, without revision, of the
FR 2018. The comment period for this notice expired on December 14, 2020. The Board did not
receive any comments. The Board adopted the extension, without revision of the FR 2018 as
originally proposed. On February 3, 2021, the Board published a final notice in the Federal
Register (86 FR 8012).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2018 is 1,248
hours. Actual respondent burden for this survey varies, depending on how many of the six
authorized surveys are actually carried out and on the specific content of each questionnaire.
Based on input from respondents and Reserve Banks as well as its own experience in
administering this survey, the Board estimates that, on average, a typical survey takes
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approximately two hours of a respondent’s time. 12 These reporting requirements represent less
than 1 percent of the Board’s total paperwork burden.
Estimated
number of
respondents13
104

FR 2018
FR 2018
Special surveys

104

Annual
frequency
4
2

Estimated
Estimated
average hours annual burden
per response
hours
2
832
2

Total

416
1,248

The estimated total annual cost to the public for the FR 2018 is $73,819.14
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
information collection is $132,600 per year.

12

Actual burden underlying the average two hour response rate varies considerably not only from survey to survey,
depending on the number and nature of the questions, but also among respondents for any one survey.
13
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.
14
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/.

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