FFIEC 030 and FFIEC 030S 18 Question Format OMB Supporting Statement

Supporting Statement for the
Foreign Branch Report of Condition
(FFIEC 030 and FFIEC 030S; OMB No. 7100-0071)
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, without revision, the
Federal Financial Institutions Examination Council (FFIEC) Foreign Branch Report of Condition
(FFIEC 030 and FFIEC 030S; OMB No. 7100-0071). Insured domestically chartered
commercial banks and savings associations (U.S. banks) that have one or more branch offices in
a foreign country are required to report balance sheet information for each of their foreign
branches on either the FFIEC 030 or FFIEC 030S. The FFIEC 030 is collected annually as of
December 31 or quarterly for significant branches as of the last day of each calendar quarter; the
FFIEC 030S is an abbreviated reporting form filed annually by smaller institutions.
The Federal Reserve receives reports for all foreign branches of U.S. banks, regardless of
charter type, on behalf of the U.S. banks’ primary federal bank regulatory agency (Board,
Federal Deposit Insurance Corporation (FDIC), or Office of the Comptroller of the Currency
(OCC) (collectively, the agencies)). The agencies use the FFIEC 030 and FFIEC 030S reports to
fulfill their statutory obligation to supervise foreign operations of domestic banks. Each of the
agencies separately clears the reports pursuant to the Paperwork Reduction Act, including with
regard to estimating respondent burden, for U.S. banks under their supervision. The FDIC and
OCC have also submitted similar requests for OMB review for U.S. banks under their
supervision.
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 FFIEC 030 and FFIEC 030S collect information on the structure and geographic
distribution of foreign branch assets and liabilities. The agencies use this information to plan
examinations and to analyze the foreign operations of U.S. banks, in connection with the
agencies’ statutory responsibility to assess the safety and soundness of the U.S. banks that they
supervise. The information collected by the FFIEC 030 and FFIEC 030S allows the agencies to
measure growth trends by bank, by country, and by bank within country. Additionally, aggregate
data that is publicly released by the agencies are a useful source of information on U.S. bank
activities for the general public. This series of data collected by these reports is the oldest
statistical series that exists for foreign branches of U.S. banks and is an important source for
measuring the growth of these offices.
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.

Reporting branches that wish to submit the FFIEC 030 or the FFIEC 030S report
electronically using the Federal Reserve’s Reporting Central application should contact their
Reporting and Reserves District Contact (https:// www.frbservices.org/contacts/index.jsp#RR)
for instructions. If the FFIEC 030 or FFIEC 030S report is filed electronically, the completed and
signed original report need not be filed with the appropriate Federal Reserve District Bank.
However, the parent U.S. institution must maintain the completed and signed original report in
its files.
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.
The FFIEC 030 is the only report through which the agencies collect balance sheet
information on foreign branches of U.S. banks. The Board uses another report, the Quarterly
Report of Assets and Liabilities of Large Foreign Offices of U.S. Banks (FR 2502q; OMB No.
7100-0079), to collect less detailed balance sheet information from parent institutions of foreign
branches or subsidiaries (specifically, those with total assets of $500 million or more). The
FR 2502q collects only gross assets and liabilities by the country of the principal address of the
customer, rather than the type of assets and liabilities of the branch. Although the FR 2502q does
not provide comparable information, the Board may check the FFIEC 030 to verify that
individual branches that report total assets greater than or equal to $500 million also report on the
FR 2502q.
5.

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

Of these respondents, 6 for the FFIEC 030 Annual; 1 for the FFIEC 030 Quarterly; and 7
for the FFIEC 030S are considered small entities as defined by the Small Business
Administration (i.e., entities with less than $600 million in total assets),
https://www.sba.gov/document/support--table-size-standards.
The FFIEC 030S is an abbreviated reporting form containing five data items that U.S.
banks must file with regard to foreign branches with total assets between $50 million and $250
million file annually. These data items are the minimum information needed to serve as
indicators of higher business volume, risk, and complexity in small-sized foreign branches. The
reported information also is used to monitor potential developments that may pose risks to the
overall operations of the parent bank. U.S. banks do not have to file an FFIEC 030 or 030S with
respect to any foreign branch with total assets of less than $50 million and that do not otherwise
meet the requirements to file the FFIEC 030 quarterly.
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.

If this collection were conducted less frequently than the present annual collection, the
agencies would have insufficient information regarding U.S. bank activity in the Eurocurrency

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markets and at specific foreign locations on which to base informed policy decisions, reports to
Congress, and foreign branch examinations. Quarterly reporting by the largest foreign branches
permits agencies to monitor foreign currency markets in a timely manner while minimizing
burden on the respondents as a whole.
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 August 13, 2021, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (86 FR 44768) requesting public comment for 60 days on the
extension, without revision, of the FFIEC 030 and FFIEC 030S. The comment period for this
notice expired on October 12, 2021. The agencies received one comment from a financial
institution. The commenter asked the agencies to clarify how to report equity securities with
readily determinable fair values not held for trading in the FFIEC 030. The commenter stated
that reporting these securities in line 4(b), “Other securities (debt and equity)” would align the
FFIEC 030 with the Call Report classification. The agencies agree with the commenter’s
suggestions and will clarify the FFIEC 030 instructions accordingly. On November 10, 2021, the
agencies, under the auspices of the FFIEC, published a final notice in the Federal Register (86
FR 62599) requesting public comment for 30 days on the extension, without revision, of the
FFIEC 030 and FFIEC 030S. The comment period for this notice expires on December 10, 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.

The information that is required to be provided on the FFIEC 030 and FFIEC 030S is
collected as part of the Board’s supervisory process. Accordingly, such information is afforded
confidential treatment under exemption 8 of the Freedom of Information Act (FOIA), which
protects information from disclosure that is contained in or related to the examination or
supervision of a financial institution (5 U.S.C. § 552(b)(8)). In addition, the FFIEC 030 and
FFIEC 030S are likely to contain nonpublic commercial or financial information, which is both
customarily and actually treated as private by the respondent. Accordingly, such information
may be withheld under exemption 4 of the FOIA (5 U.S.C. § 552(b)(4)). In limited
circumstances, aggregate data for multiple respondents, which does not reveal the identity of
any individual respondent, may be released to the public.
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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 FFIEC 030 and
FFIEC 030S with respect to banks supervised by the Board is 317 hours. These reporting
requirements represent less than 1 percent of the Board’s total paperwork burden.

FFIEC 030 and FFIEC 030S
FFIEC 030
Annual
Quarterly
FFIEC 030S

Estimated
number of
respondents

Annual
frequency

12
20
7

1
4
1

Estimated
Estimated
average hours annual burden
per response
hours
3.4
3.4
0.5

Total

41
272
4
317

The estimated total annual cost to the public for the FFIEC 030 and FFIEC 030S is
$18,751.
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/.
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 030 and FFIEC 030S is $35,200. The Federal Reserve System collects and processes the
data for all three of the agencies.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
There are no program changes or adjustments.

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16.

Provide information regarding plans for publication of data.

Aggregate data are published in the Federal Reserve Annual Report and the Department
of Commerce’s Annual Statistical Digest.
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.

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