FRTT_20220809_omb

Supporting Statement for the
Reporting Requirements Associated with Regulation TT
(FR TT; OMB No. 7100-0369)
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 Reporting Requirements Associated with Regulation TT (FR TT; OMB No.
7100-0369). The Board’s Regulation TT - Supervision and Regulation Assessments of Fees
(12 CFR Part 246) implements the second section 11(s) of the Federal Reserve Act (FRA),1
which directs the Board to collect assessments, fees, or other charges (collectively, assessments)
from bank holding companies (BHCs) and savings and loan holding companies (SLHCs) that
meet a size threshold and from all nonbank financial companies designated for Board
supervision by the Financial Stability Oversight Council (FSOC) (collectively, assessed
companies) in an amount equal to the total expenses the Board estimates are necessary or
appropriate to carry out its supervisory and regulatory responsibilities with respect to such
companies. Pursuant to Regulation TT, the Board issues an annual notice of assessment to each
assessed company. As described below, assessed companies may file a written appeal with the
Board regarding the assessment.2
The estimated total annual burden for the FR TT is 120 hours. There is no formal
reporting form for this information collection.
Background and Justification
The second section 11(s) of the FRA directs the Board to collect assessments from
assessed companies equal to the expenses the Board estimates are necessary or appropriate to
carry out its supervision and regulation of those companies. Each calendar year is an assessment
period. A BHC or SLHC is an assessed company for an assessment period if it has total
consolidated assets of $100 billion or more, and all nonbank financial companies designated for
Board supervision by the FSOC are assessed companies. Regulation TT provides that the Board
must notify assessed companies of the amount of their assessment no later than June 30 of the
year following each assessment period, and assessed companies may file a written appeal with
the Board regarding the assessment.
This information submitted as part of an appeal is not available from other sources. This
information collection is necessary in order for the Board to provide BHCs, SLHCs, and Boardsupervised nonbank financial companies an opportunity to appeal their assessment as provided in
Regulation TT.

1

12 U.S.C. § 248(s). The second section 11(s) of the Federal Reserve Act was added by section 318 of the DoddFrank Wall Street Reform and Consumer Protection Act. There are two subsections of section 11 of the Federal
Reserve Act designated as (s). The provision relating to assessments is described as the “second” subsection (s) as it
was enacted later in time.
2
12 CFR 246.5(b).

Description of Information Collection
Section 246.5(b), Notice of Assessment and Appeal. Each assessed company has
30 calendar days from June 30 to submit a written statement to appeal the Board’s determination
that the company is an assessed company or its determination of the company’s total assessable
assets.
Respondent Panel
The FR TT panel comprises BHCs and SLHCs that meet a size threshold ($100 billion or
more in total consolidated assets) and all nonbank financial companies designated for Board
supervision by the FSOC. Pursuant to Regulation TT, the total consolidated assets of a BHC and
SLHC are determined based on the average of the bank holding company’s total consolidated
assets reported for the assessment period, and a nonbank financial company is considered to be
an assessed company if it is a Board-supervised nonbank financial company on December 31 of
the assessment period.
Time Schedule for Information Collection
This information collection is event-generated. An assessed company electing to appeal
the Board’s assessment determination has 30 calendar days from June 30 to submit a written
appeal.
Public Availability of Data
There is no data related to this information collection available to the public.
Legal Status
The FR TT is authorized pursuant to the second section 11(s) of the FRA, which requires
the Board to collect the assessments, as described above, and section 11(i) of the FRA (12 U.S.C.
§ 248(i)), which provides that the Board shall make all rules and regulations necessary to enable
the Board to effectively perform the duties, functions, or services specified in the FRA. The
FR TT reporting requirements are required to obtain a benefit.
An assessed company may request confidential treatment of information contained in its
appeal pursuant to exemption 4 of the Freedom of Information Act (FOIA), which protects
nonpublic commercial or financial information, which is both customarily and actually treated as
private by the respondent (5 U.S.C. § 552(b)(4)). Determinations of confidentiality based on
FOIA exemption 4 would be made on a case-by-case basis.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.

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Public Comments
On December 10, 2021, the Board published an initial notice in the Federal Register (86
FR 70498) requesting public comment for 60 days on the extension, without revision, of the
FR TT. The comment period for this notice expired on February 8, 2022. The Board did not
receive any comments. The Board adopted the extension, without revision, of the FR TT as
originally proposed. On April 6, 2022, the Board published a final notice in the Federal Register
(87 FR 19929).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR TT is 120
hours. The estimated average hours per request is 40 hours. These reporting requirements
represent less than 1 percent of the Board’s total paperwork burden.

FR TT
Section 246.5(b)

Estimated
number of
respondents3

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

3

1

40

120

The estimated total annual cost to the public for the FR TT is $7,254.4
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 this information is
negligible.

3

Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $750 million in total assets), https://www.sba.gov/document/support--table-size-standards.
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 $21, 4 5% 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/.

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