FR3075_20220225_omb

Supporting Statement for the
Policy Impact Survey
(FR 3075; OMB No. 7100-0362)
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 Policy Impact Survey (FR 3075; OMB No. 7100-0362). The FR 3075
collects information from certain types of institutions regulated by the Board in order to assess
the effects of proposed, pending, or recently adopted policy changes at the domestic and
international levels.1 The Board uses the survey to collect information used for certain
quantitative impact studies (QISs)2 sponsored by financial stability bodies such as the Basel
Committee on Banking Supervision (BCBS) and the Financial Stability Board (FSB). Recent
collections have included the Basel III monitoring exercise, which monitors the global impact of
the Basel III framework,3 the global systemically important bank (G-SIB) exercise, which
assesses firms’ systemic risk profiles,4 and a survey of the domestic systemic risk footprint of
large foreign banking organizations. Since the collected data may change from survey to survey,
there is no fixed reporting form.
The surveys are conducted on a voluntary basis. The number of respondents per survey
and the number of surveys conducted per year fluctuate. Based on past use of the FR 3075, the
Board estimates that the surveys will be conducted approximately 7 times per year, with an
average of 14 respondents per survey. The total annual burden for the FR 3075 remains capped
at 68,600 hours.
Background and Justification
As an active participant in a number of international prudential standard-setting and
financial stability bodies, such as the BCBS and FSB, the Board frequently participates in
surveys sponsored by these and other similar bodies that are designed to test, calibrate, or
monitor new and potential changes to regulatory policy so that the impact of policy changes on
domestic institutions can be appropriately evaluated prior to their proposal. These QISs cover a
wide range of topics and can involve one-time ad hoc collections or repetitive iterations of the
same or similar collections for the purposes of constructing a time series. Recent QISs have
captured data related to capital, leverage, liquidity, counterparty credit risk, securitization, large
exposures, and systemic risk.

1

Respondents may include bank holding companies (BHCs), savings and loan holding companies (SLHCs),
nonbank financial companies that the Financial Stability Oversight Council has determined should be supervised by
the Board, and the combined domestic operations of foreign banking organizations.
2
A QIS is a survey of financial institutions that allows supervisors to assess the quantitative impact of policy
changes.
3
For more information on the Basel III monitoring exercise, including recent examples of QIS surveys sponsored by
BCBS and conducted by the Board, see https://www.bis.org/bcbs/qis/.
4
For more information on the G-SIB exercise, see https://www.bis.org/bcbs/gsib/.

Due to the speed with which the surveys must be conducted, there is not enough time to
incorporate them into the standardized regulatory reporting framework. In fact, some collections
have had a planning timeframe as short as two weeks. Moreover, due to their transient nature, the
collections are not strong candidates for permanent adoption into the regulatory reporting
framework.
The Board implemented the FR 3075 information collection in September 2014. The
FR 3075 has been used to collect a range of information, including data on the Basel III
international capital accord, systemic risk profiles of financial institutions, insurance
underwriting, and trading book securitization.
The information collected by the FR 3075 is not available from other sources. The
collected information is important to the Board’s supervisory mission, and without the
information, the Board would be less equipped to evaluate the potential impact that proposed
policy changes would have on supervised institutions.
Description of Information Collection
The FR 3075 allows the Board to collect information regarding the impact of potential
changes in regulation. The principal value of the FR 3075 is the flexibility it provides the Board
to participate in multilateral data collection efforts related to rapidly evolving economic
developments and global financial stability. Because these initiatives are often urgent and reflect
the most current policy variants being considered, the number, type, and content of specific data
items cannot be predicted far in advance.
Written qualitative questions or questionnaires may include categorical questions, yes-no
questions, ordinal questions, and open-ended questions. Written quantitative surveys may request
dollar amounts, percentages, numbers of items, interest rates, and other similar information . In
soliciting participation, the Board explains to respondents the purpose of the survey and how the
data would be used. Following a survey, the Board makes each survey instrument publicly
available on the Board’s OMB Public Docket.
Respondent Panel
The FR 3075 respondent panel consists of BHCs, SLHCs, any nonbank financial
company that the Financial Stability Oversight Council has determined should be supervised by
the Board, and the combined domestic operations of foreign banking organizations.
Time Schedule for Information Collection
The data submission timeline for each survey is determined prior to the distribution of the
survey materials.

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Public Availability of Data
The Board will choose whether to publish survey data that it obtains from respondents
and will inform the respondents beforehand if the data are to be published on an individualinstitution basis. Depending upon the nature of the data collection, the survey data may be
confidential. Aggregate survey information may be cited in published material such as Board
studies or working papers, proposed or final rules, professional journals, the Federal Reserve
Bulletin, testimony and reports to the Congress, or other external and internal publications.
Legal Status
Information collected under the FR 3075 is authorized by the Board’s reporting
authorities, which are located in section 5(c) of the Bank Holding Company Act of 1956 for
BHCs and their subsidiaries (12 U.S.C. § 1844(c)), section 10(b)(2) of the Home Owners’ Loan
Act for SLHCs and their subsidiaries (12 U.S.C. § 1467a(b)(2)), section 161(a) of the DoddFrank Wall Street Reform and Consumer Protection Act for nonbank financial companies
supervised by the Board (12 U.S.C. § 5361(a)), section 8(a) of the International Banking Act of
1978 (12 U.S.C. § 3106(a)) and section 5(c) of the Bank Holding Company Act (12 U.S.C. §
1844(c)) for the combined domestic operations of certain foreign banking organizations, section
9 of the Federal Reserve Act for state member banks (12 U.S.C. § 324), sections 25 and 25A of
the Federal Reserve Act for Edge and agreement corporations (12 U.S.C. §§ 602 and 625), and
section 7(c)(2) of the International Banking Act of 1978 (12 U.S.C. § 3105(c)(2)) and section
7(a) of the Federal Deposit Insurance Act (12 U.S.C. § 1817(a)) for U.S. branches and agencies
of foreign banks. Response to the FR 3075 is voluntary.
The questions asked on each survey will vary. The Board’s ability to keep confidential
responses to the FR 3075 must therefore be determined on a case-by-case basis. To the extent
responses include nonpublic commercial or financial information, which is both customarily and
actually treated as private by the respondent, such information may be kept confidential pursuant
to exemption 4 of the Freedom of Information Act (FOIA) (5 U.S.C. § 552(b)(4)). Some survey
responses may also contain information contained in or related to an examination of a financial
institution, which may be kept confidential under exemption 8 of FOIA (5 U.S.C. § 552(b)(8)).
To the extent a respondent submits personal, medical, or similar files, the disclosure of which
would constitute an unwarranted invasion of privacy, the respondent may request confidential
treatment pursuant to exemption 6 of the FOIA (5 U.S.C. § 552(b)(6)).
Aggregate survey information from the FR 3075 is not considered confidential and may
be cited in published material such as Board studies or working papers, proposed or final rules,
professional journals, the Federal Reserve Bulletin, testimony and reports to the Congress, or
other vehicles.
Consultation Outside the Agency
Surveys conducted under the FR 3075 may include data collections sponsored by bodies
such as the BCBS and the FSB. There has been no consultation outside the Federal Reserve
System regarding the extension, without revision, of the FR 3075.

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Public Comment
On May 26, 2021, the Board published an initial notice in the Federal Register (86 FR
28345) requesting public comment for 60 days on the extension, without revision, of the
FR 3075. The comment period for this notice expired on July 26, 2021. The Board did not
receive any comments. The Board adopted the extension, without revision, of the FR 3075 as
originally proposed. On October 5, 2021, the Board published a final notice in the Federal
Register (86 FR 54973).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3075 is capped
at 68,600 hours. The number of respondents is based on the average number of responses
anticipated per survey conducted. Because the number of surveys will fluctuate depending on the
number and types of policies being developed, it is not possible to predict exactly how many will
be conducted in a given year. The Board estimates the survey will be conducted up to 7 times per
year, and the average time per response will be about 700 hours. These reporting requirements
represent less than 1 percent of the Board’s total paperwork burden.

FR 3075

Estimated
number of
respondents5

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

Current

14

7

700

68,600

The estimated total annual cost to the public for the FR 3075 is $4,057,690.6
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 cost of the surveys depends on the size of the sample, the number of questions asked,
the type and complexity of the questions asked, and the frequency of the surveys. The estimated
cost to the Federal Reserve System for the FR 3075 is $200,000.

5

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.
6
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $20, 45% Financial Managers at
$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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