FR3033_20210929_omb

Supporting Statement for the
Census of Finance Companies and Other Lenders and Survey of Finance Companies
(FR 3033p and FR 3033s; OMB No. 7100-0277)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Census of Finance Companies and Other Lenders and Survey of Finance
Companies (FR 3033p and FR 3033s; OMB No. 7100-0277). These voluntary information
collections (the quinquennial) consist of the Census of Finance Companies and Other Lenders
(FR 3033p), which the Board last revised in 2020, as well as the Survey of Finance Companies
(FR 3033s), which the Board has revised as part of this clearance.
The FR 3033p is the first part of a two-stage survey series, which has been conducted at
regular five-year intervals since 1955. It is a census survey designed to identify the universe of
finance companies eligible for potential inclusion in the FR 3033s. It gathers limited information
including total assets, areas of specialization, and information on the corporate structure of such
companies. The second part of these information collections, the FR 3033s, collects balance
sheet data on major categories of consumer and business credit receivables and major liabilities,
along with income and expenses, and is used to gather information on the scope of a company’s
operations and loan and lease servicing activities. In addition, additional questions were added to
collect lending information related to the COVID-19 impacts. From the universe of finance
companies identified by the FR 3033p, a stratified random sample of 3,000 finance companies
will be drawn for the FR 3033s. This survey will be sent in September 2021, and collect
information as of June 30, 2021. The data collected from this voluntary survey will be used for
two purposes: to benchmark the consumer and business finance series collected on the Board’s
monthly Domestic Finance Company Report of Consolidated Assets and Liabilities (FR 2248;
OMB No. 7100-0005) and to increase the Federal Reserve’s understanding of an important part
of the financial system.
The Board revised the FR 3033s to improve clarity, simplify the form overall, and collect
additional information on the COVID-19 impacts on lending activities. The Board did not adopt
any revisions to the FR 3033p as part of this clearance.
The current estimated total annual burden for the FR 3033p and FR 3033s is 6,024 hours,
and would decrease to 5,124 hours. The revisions would result in a decrease of 900 hours. The
survey form and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/default.aspx.
Background and Justification
Since June 1955, the Board has surveyed the assets and liabilities of finance companies in
five-year intervals. For purposes of this survey, finance companies were defined as companies
whose largest portion of assets is made up of consumer or business loan s or leases excluding
commercial banks, cooperative banks, investment banks, savings banks, savings and loan

institutions and industrial loan corporations or their subsidiaries. Through 1975, all known U.S.
finance companies were surveyed. To reduce reporting burden, in 1980 the survey was split into
two parts: (1) an extremely brief screening survey, which has been sent to all likely finance
companies that operate in the United States and its territories and possessions, and (2) a longer
survey, which has been sent to a stratified random sample of identified finance companies. In
2005, the definition of finance company was revised to include companies whose largest portion
of assets was made up of real estate loans; as a result, mortgage companies became eligible to
participate in the survey. In addition, the survey was revised to instruct finance companies to
include the assets and liabilities of their mortgage company subsidiaries.
In 2010, the quinquennial underwent a major revision. The title of the FR 3033p was
changed to “Census of Finance Companies” to stress that every response is important. Several
questions on the census were modified to allow the Board to make the determination of whether
a company is a finance company rather than asking whether it meets the definition. Similarly, the
title of the FR 3033s was changed to “Survey of Finance Companies.” Revisions to the FR 3033s
included reordering assets and liability data items from most liquid to least liquid, asking
additional detail on assets and liabilities, adding a section to gather information on servicing
activities and geographic distribution of the company’s activities, and creating a clearer
distinction among the broad balance sheet data items, detailed loan and lease data items, and offbalance-sheet securitization data items. The respondent panel sizes for both questionnaires were
increased, and the Board implemented a web-based survey option.
The Board has used the quinquennial data to benchmark monthly data series on major
assets and quarterly data series on liabilities of finance companies developed from the monthly
Domestic Finance Company Report of Consolidated Assets and Liabilities (FR 2248; OMB No.
7100-0005), which is collected from a smaller sample of companies. These data are used in
internal analysis and are reported to the public in two monthly statistical releases, the Finance
Companies (G.20) and the Consumer Credit (G.19), as well as the quarterly Financial Accounts
of the United States (Z.1) release. As with many data series based on a fixed sample, errors of
estimation tend to increase over time and thus require periodic correction. These errors reflect
the evolution in the financial markets as new companies enter the market and market shares
change and the deterioration of the monthly sample panel as respondents close, merge or
otherwise leave the panel.
In addition to benchmarking the Flow of Funds data, information from the quinquennial
also provides the Board with an opportunity to learn about an important part of the financial
system. It is the only statistically reliable source of information on the types of finance
companies and the size of the industry. There is no other comprehensive source of data on the
activities of such companies. Finance companies are a key supplier of credit to households and
businesses, holding or managing about 13 percent of total consumer credit outstanding and a
significant share of the short- and intermediate-term business finance market. The business and
consumer credit holdings of finance companies are key elements of domestic nonfinancial debt,
which is monitored by the Board and the Federal Open Market Committee (FOMC) in the
implementation of monetary policy.

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Description of Information Collection
FR 3033p
The FR 3033p is a voluntary census survey designed to identify the universe of finance
companies eligible for potential inclusion in the FR 3033s and to enable the stratification of the
sample for more statistically efficient estimation. The FR 3033p is currently composed of 7
questions to assess the company’s asset size, level of loan and lease activity, company structure,
and licensing authority.
FR 3033s
From the universe of finance companies identified by the FR 3033p, a sample of finance
companies will be invited, on a voluntary basis, to fill out FR 3033s. From these finance
companies, the FR 3033s survey collects balance sheet data on major categories of consumer and
business credit receivables and major liabilities. In addition, the survey may be used to gather
information on topics that are pertinent to increasing the Federal Reserve’s understanding of the
finance companies.
Respondent Panel
Currently, the Board is conducting the FR 3033p, which was launched in early October
2020. For the FR 3033s collection, the Board will survey up to 3,000 companies which, based on
experience with 2015 survey, may be sufficient. The survey sample would likely include all the
FR 3033p respondents identified as finance companies. The response rate for the upcoming
information collection is estimated to be around 40 percent. In 2015, The Board sent out
approximately 2,300 surveys via mail. Excluding those forms that were returned by the post
office as undeliverable, the overall response rate was 40.8 percent.
The Board plans to mail out survey forms to companies in September 2021 and conduct
additional mailings and postcard reminders to bolster response rates. The adoption of a webbased survey, which was inaugurated in 2010, is also expected to have positive e ffects on
response rates.
To cope with the expected level of nonresponse to the survey, the Board also intends to
follow up with all the nonrespondents with phone calls or emails. The follow-up study would
include questions related to, but not necessarily identical to, the survey questions. Select Reserve
Banks would assist with the nonresponse follow-up activities.
Revisions to the FR 3033s
The Board revised the FR 3033s to improve clarity, simplify the form overall, and collect
additional information on the COVID-19 impacts on lending activities. The FR 3033s revisions,
which are effective for the September 2021 survey date, include:

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A. Removals:
• Removing the off-balance-sheet securitizations column on the balance sheet, which
encompasses 20 items.
• Removing question 7.C (non-recourse debt associated with financing activities).
• Removing questions 12.A-12.D, as they were special topic questions added for the 2015
survey.
• Removing the question soliciting comments or explanations from the respondents.
B.
•
•
•
•
•

Revisions:
Revising general survey instructions and item descriptions for clarity.
Revising the benchmark date to June 30, 2021.
Renumbering items 7.E-7.G to items 7.D-7.F.
Revising question 7.D to “Notes, Bonds, Debentures, and Other Debt” and renumbering
it to 7.C. This is to be consistent with the information collected on the FR 2248.
Revising question 11.B to “Total number of accounts for domestic business and real
estate receivables.”

C. Additions:
• Adding an item for “Student Loans” in section 3.B. as question 3.B.3 and renumber
“Other Consumer Loans” as question 3.B.4. This is to closer align the information
collected on the FR 3033s with the FR 2248.
• Adding a Question 12 to collect detailed information on types of consumer credit that
finance companies offer. This question is useful to assess the extent of offerings of
consumer credit products by the finance company industry. This also makes it feasible to
identify specialty finance companies and facilitate analysis of profitability at such
companies.
12. Does your company offer any of the following types of consumer credit or financing?
❖
❖
❖
❖
•

Installment cash loans
Motor vehicle title loans
Pawn loans
Payday loans

[ ] Yes
[ ] Yes
[ ] Yes
[ ] Yes

[ ] No
[ ] No
[ ] No
[ ] No

Adding a Question 13 with 3 sub-items to collect lending information related to the
COVID-19 impacts. Given that the Survey of Finance Companies and Other Lenders
falls during the time in which the United States economy has been impacted by the
effects of the COVID-19 pandemic, it is useful to collect lending information related to
this unforeseen event. The need for economic relief has been at the forefront of this
pandemic. Many financial firms have already been approved and are participating in the
SBA’s Paycheck Protection Program (PPP) to lend to small businesses in need and have
been doing so. Additionally, some of these firms are actively advertising their lending
relief options to the public. There may be value in assessing any relief lending associated
with the COVID event by these firms.
13. COVID-19 pandemic relief
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13.A. During the COVID-19 pandemic, did your company provide financial relief in the
form of loans or leases OR accommodations to customers?
[ ] Yes. Please complete 13.B & 13.C below

[ ] No. Please stop

13.B. What type of relief did your company provide?
Loans or leases
Deferred payments
Waiving late fees
Waiving interest fees
Interest rate modifications
Other

[
[
[
[
[
[

] Yes
] Yes
] Yes
] Yes
] Yes
] Yes

[
[
[
[
[
[

] No
] No
] No
] No
] No
] No

13.C. What was the TOTAL dollar amount of loans and leases? Please include both the
loans and leases originated that were specifically related to pandemic relief AND those
that were existing but offered accommodations. Mark one.
[
[
[
[
[

]
]
]
]
]

Less than $1 million
$1 million — less than $10 million
$10 million — less than $100 million
$100 million — less than $1 billion
$1 billion or more

Time Schedule for Information Collection
The FR 3033s survey is scheduled to be sent out to the respondents identified in the
FR 3033p in September 2021. Respondents will be directed to either complete the survey online
or mail paper responses back. Before commencement of the FR 3033s, postcards would be
mailed to respondents to thank them for taking part in the FR 3033p and to encourage their
participation in the FR 3033s as well. Follow-up mailings and postcard reminders would be sent
to companies that do not respond after the initial mailing. Nonresponse follow-up calls and
emails would be conducted by Reserve Banks. Ultimately data collected from the FR 3033p and
FR 3033s will be used to benchmark the monthly FR 2248.
Public Availability of Data
The Board has used the quinquennial data to benchmark monthly data series on major
assets and quarterly data series on liabilities of finance companies developed from the FR 2248,
which is collected from a smaller sample of companies. Examples of analysis are published in
the Federal Reserve Bulletin 1 and the FEDS Note.2 These data are also reported in aggregate
format to the public in two monthly statistical releases, the Finance Companies (G.20) and the
1

https://www.federalreserve.gov/publications/2018-june-survey-of-finance-companies-2015.htm.
https://www.federalreserve.gov/econres/notes/feds-notes/the-cost-structure-of-consumer-finance-companies-andits-implications-for-interest-rates-20200812.htm.
2

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Consumer Credit (G.19), as well as the quarterly Financial Accounts of the United States (Z.1)
release. Individual survey responses are not made publicly available.
Legal Status
The FR 3033p and FR 3033s are authorized pursuant to sections 2A and 12A of the
Federal Reserve Act (FRA). Section 2A of the FRA requires that the Board and the Federal Open
Market Committee 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). Under section 12A of the FRA, the Federal Open Market Committee is
required 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). Information collected
from the FR 3033p and FR 3033s is used to fulfill these obligations. The FR 3033p and
FR 3033s are voluntary.
The information collected pursuant to the FR 3033p and FR 3033s may be treated as
confidential pursuant to exemption 4 of the Freedom of Information Act (5 U.S.C. § 552(b)(4)),
which protects information that is both customarily and actually treated as private by the
respondent.
Consultation Outside the Agency
For the renewal of the FR 3033p in 2020, the Board consulted with OpenCorporates,
Competiscan, Zoominfo, Melissa Data, and Infogroup to identify companies as potential
respondents for the census. There has been no consultation outside the Federal Reserve for
renewing the FR 3033s.
Public Comments
On May 25, 2021, the Board published an initial notice in the Federal Register (86 FR
28105) requesting public comment for 60 days on the extension, with revision, of the FR 3033p
and FR 3033s. The comment period for this notice expired on July 26, 2021. The Board did not
receive any comments. On September 1, 2021, the Board published a final notice in the Federal
Register (86 FR 49031).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3033p and
FR 3033s is 6,024 hours, and would decrease to 5,124 hours with the revisions. The estimated
burden for the FR 3033s would be reduced by 900 hours, based on a reduced estimated number
of respondents and a shorter estimated average hours per response. These reporting requirements
represent less than 1 percent of the Board’s total paperwork burden.

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Estimated
Estimated
Estimated
Annual
number of
average hours annual burden
frequency
respondents3
per response
hours

FR 3033
Current
FR 3033p
FR 3033s

12,800
1,200

1
1

0.33
1.5

4,224
1,800
6,024

12,800
900

1
1

0.33
1

Proposed Total

4,224
900
5,124

Change

(900)

Current Total
Proposed
FR 3033p
FR 3033s

The estimated total annual cost to the public for the FR 3033p and FR 3033s is $356,320,
and would decrease to $303,085 with the revisions.4
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 this
information collection is $226,400.

3

Of these respondents, it is anticipated that 6,100 FR 3033p respondents and 850 FR 3033s respondents would be
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
$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, 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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