FR2034_20220712_omb

Supporting Statement for the
Senior Credit Officer Opinion Survey on Dealer Financing Terms
(FR 2034; OMB No. 7100-0325)
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 Credit Officer Opinion Survey on Dealer Financing Terms (SCOOS)
(FR 2034; OMB No. 7100-0325). This partially ad hoc survey 1 collects qualitative and limited
quantitative information from senior credit officers at responding financial institutions on
(1) stringency of credit terms, (2) credit availability and demand across the entire range of
securities financing and over-the-counter derivatives transactions, and (3) the evolution of
market conditions and conventions applicable to such activities. The FR 2034 survey will be
conducted quarterly, along with the Senior Loan Officer Opinion Survey on Bank Lending
Practices (FR 2018; OMB No. 7100-0058). The survey contains 79 core questions divided into
three broad sections, as well as additional questions on topics of timely interest.
The estimated total annual burden for the FR 2034 is 500 hours.
Background and Justification
The FR 2034 survey is modeled after the long-established Senior Loan Officer Opinion
Survey on Bank Lending Practices (FR 2018), which provides qualitative information on
changes in the supply of, and demand for, bank loans to businesses and households. The
information obtained from the FR 2018, which has been conducted in different forms since 1964,
provides valuable insights on developments in the credit market and banking developments and
informs the formulation of monetary policy.
This information has been particularly valuable in recent years because it has provided
the Board with insight into the effects of financial conditions on the availability of credit to
households and businesses. However, the global financial crisis highlighted that a significant
volume of credit intermediation has moved outside of the traditional banking sector, which is the
primary focus of the FR 2018. In addition, some of the instruments that are commonly used in
connection with such intermediation (including for the financing of securities positions and overthe-counter derivatives) may have functioned as transmission mechanisms for financial distress
during the crisis by connecting seemingly separate parts of the financial system.
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 a detailed justification of the effective and efficient statistical survey methodology (if
applicable), and (9) 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.
1

The Board therefore decided to expand the collection of qualitative information on the
availability of credit and leverage beyond the traditional banking sector to the extension of credit
by dealers. In 2010, the Federal Reserve implemented the FR 2034 to facilitate the regular
collection and analysis of information representing the informed judgment of market participants
on these additional forms of credit extension. Unlike the large domestically-chartered
commercial banks and branches and agencies of foreign banks that are respondents to the
FR 2018, the FR 2034 targets respondents representing activities not conducted solely in a bank,
but rather in several different legal entities, focused on the consolidated entity.
Given the Board’s interest in financial stability, the information this survey collects is
critical to the monitoring of credit markets and capital market activity. Information from the
survey is also considered by the Federal Open Market Committee (FOMC) as it sets monetary
policy.
Description of Information Collection
The questions on the SCOOS are mainly qualitative in nature. They are intended to elicit
useful information without imposing an undue reporting burden and do not request information
that is collected through other means. To understand certain market conventions and practices,
however, the Board may occasionally need to ask specific quantitative questions. When
quantitative information is requested in response to special questions, respondents may be asked
to provide approximate or rough estimates.
The survey contains 79 core questions divided into three broad sections. The first section
focuses on credit terms applicable to counterparties of different types, spanning a variety of
different transactions. The second section contains credit terms applicable to over-the-counter
derivatives counterparties, distinguishing among contracts referencing different underlying
assets. The third section deals with information about the financing terms provided for certain
security positions. In addition, a small number of non-recurring questions relating to current
developments in credit and capital markets are generally asked. The survey is conducted through
a web interface designed and maintained by the Statistics Function of the Federal Reserve Bank
of New York, with follow-up as necessary via telephone. The primary contact at each responding
institution is a senior credit officer who has perspective on all relevant activities conducted by
the institution.
Respondent Panel
The FR 2034 panel consists of up to 25 U.S. banking institutions and U.S. branches and
agencies of foreign banks, the majority of which are affiliated with a Primary Government
Securities Dealer;2 however, other types of respondents, such as other depository institutions,
bank holding companies, or other financial entities, may be surveyed when appropriate. With
respect to respondents that are primary dealers, the panel includes each primary dealer’s
consolidated entity, rather than the dealer itself. Respondents may also include institutions that,
while not primary dealers, play a significant role in over-the-counter derivatives or securities
2

A list of the current Primary Dealers in Government Securities is available at
https://www.newyorkfed.org/markets/primarydealers.html.

2

financing activities.
Time Schedule for Information Collection and Publication
The survey is conducted once each quarter by the Statistics Function of the Federal
Reserve Bank of New York. The Statistics Function electronically transmits the survey responses
to the Board.
Public Availability of Data
The Board tabulates and summarizes the data in a public release, which is made available
on the Board’s website. 3 In addition, selected aggregate survey results may be discussed in
Governor’s speeches, and may be published in Federal Reserve Bulletin articles and in the
annual Monetary Policy Report to Congress.
Legal Status
The FR 2034 is authorized by 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
(FOMC) 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).
Section 12A of the FRA further 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). The Board and FOMC use the information obtained through the
FR 2034 to discharge these responsibilities. Responding to the FR 2034 is voluntary.
The information contained in responses to the core questions of the FR 2034 is nonpublic
commercial or financial information, which is both customarily and actually treated as private
by the respondent. The Board therefore keeps such information confidential pursuant to
exemption 4 of the Freedom of Information Act (FOIA) (5 U.S.C. § 552(b)(4)). Supplemental
questions asked on each survey may vary, and the Board’s ability to keep confidential responses
to such questions must therefore be determined on a case-by-case basis. Responses to
supplemental questions may contain nonpublic commercial information that would be kept
confidential by the Board pursuant to exemption 4 of the FOIA. Some such responses may also
contain information contained in or related to an examination of a financial institution, which
would be kept confidential under exemption 8 of the FOIA (5 U.S.C. § 552(b)(8)).
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.

3

See https://www.federalreserve.gov/data/scoos.htm.

3

Public Comments
On December 3, 2021, the Board published an initial notice in the Federal Register (86
FR 68666) requesting public comment for 60 days on the extension, without revision, of the
FR 2034. The comment period for this notice expired on February 1, 2022. The Board did not
receive any comments. The Board adopted the extension, without revision, of the FR 2034 as
originally proposed. On June 23, 2022, the Board published a final notice in the Federal Register
(87 FR 37513).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2034 is 500
hours. Actual respondent burden for this survey would likely vary depending on how many of
the authorized surveys are actually carried out and on the specific content of each questionnaire .4
These reporting requirements represent less than 1 percent of the Board’s total paperwork
burden.

FR 2034
Current

Estimated
Estimated
Estimated
Annual
number of
average hours annual burden
frequency
respondents5
per response
hours
25

4

5

500

The estimated total annual cost to the public for the FR 2034 is $30,225.6
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 estimated cost to the Federal Reserve System for collecting and processing this
survey is $76,600.

4

Actual burden underlying the average assumed five hour response time 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.
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-sizestandards.
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 $21, 45% Financial Managers at
$74, 15% Lawyers at $71, and 10% Chief Executives at $102). 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 2021, published March 31, 2022, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

4