FFIEC 009a

Federal Financial Institutions Examination Council

Instructions for the Preparation of

Country Exposure Information Report
Reporting Form FFIEC 009a
Effective September 2019

INSTRUCTIONS FOR PREPARATION OF

Country Exposure Information Report

General Instructions
This report is a supplement to the Country Exposure
Report (Form FFIEC 009) filed with the banking regulatory agencies for bank examination purposes. The
purpose of the Country Exposure Information Report
is to provide public disclosure of significant country
exposures of U.S. banking institutions. Copies of the
report are available to the public by accessing the following website http:/www.ffiec.gov/E16.htm.

Who Must Report
This report must be filed by every institution that submits Form FFIEC 009 and that has exposure meeting
the reporting requirements for Form FFIEC 009a as
defined in these instructions.
This supplemental disclosure report (Form
FFIEC 009a) has two parts: Part A and Part B. Part A
will be completed when exposure, as defined for Column 4, Part A, to a single country, excluding the
United States, exceeds one percent of the banking
institution’s total assets or exceeds 20 percent of the
banking institution’s total capital, whichever is less. All
columns included in Part A should only be completed
for the countries that exceed these thresholds. Part B
will be used to report the names of the countries where
the amount of exposure exceeds 0.75 percent but does
not exceed 1 percent of the banking institution’s total
assets or is between 15 percent and 20 percent of the
banking institution’s total capital, whichever is less.
The banking institution must only list the names of the
countries and the aggregate amount of exposure for all
countries listed under Part B. For the purposes of
meeting these criteria, exposure is defined as the
amount of total claims computed in accordance with
the instructions to Column 4, Part A.

Total assets of reporting banks are those submitted on
the Report of Condition to the federal bank supervisors as of the same date. For bank holding companies
total assets are those submitted on the most recent
Form FR Y-9C.
Total capital is as defined in the agencies’ guidelines on
capital adequacy and consists of Tier 1 plus Tier 2
capital.

Public Release of Country Exposure
Information Reports
The individual FFIEC 009a reports are made publicly
available.
A reporting institution may request confidential treatment for some or all of the portions of the
FFIEC 009a if the institution is of the opinion that
disclosure of specific commercial or financial information in the report would likely cause substantial harm
to its competitive position. In certain limited circumstances, the reporting institution’s primary federal
supervisor may approve confidential treatment of
some or all of the items for which such treatment has
been requested if the institution has clearly provided a
compelling justification for the request. A request for
confidential treatment must be submitted in writing
prior to the electronic submission of the report. The
written request must identify the specific items for
which confidential treatment is requested, provide justification for the confidential treatment requested for
the identified items, and demonstrate the specific
nature of the harm that would result from public
release of the information. Merely stating that competitive harm would result is not sufficient. Information for which confidential treatment is requested may
subsequently be released by the reporting institution’s
primary federal supervisor in accordance with the
terms of 12 CFR 4.16 (OCC), 12 CFR 261.16 (Board),
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12 CFR 309.6 (FDIC), or as otherwise provided
by law.

Filing of Reports
The report is to be prepared quarterly, as of the last
calendar day of March, June, September, and December. All respondents should submit their completed
report, each quarter they meet the reporting requirements, to the Federal Reserve Bank of New York
(FRBNY), via the Federal Reserve System’s Reporting
Central system, within 45 calendar days after the
March 31, June 30, and September 30 as-of date. The
submission deadline is 50 calendar days after the
December 31 as-of date.
Any FFIEC 009a respondent who needs filing guidance is encouraged to visit the Federal Reserve System
Website https://www.frbservices.org/central-bank/
reporting-central/index.html for additional information
on Reporting Central. The Website also includes a link
that respondents may use to contact the Federal
Reserve Bank of New York.

Rounding
Round all amounts reported on this form to the nearest
million dollars.

Legal Entity Identifier (LEI)
The LEI is a 20-digit alpha-numeric code that uniquely
identifies entities that engage in financial transactions.
A reporting institution must provide its LEI on the
cover page of this report only if it already has an LEI.
The LEI must be a currently issued, maintained, and
valid LEI, not an LEI that has lapsed. If a reporting
institution does not have an LEI, it is not required to
obtain one for purposes of reporting it on this report.

Part A
Country
The countries listed in Part A should be those where
exposure, as defined for Column 4, Part A, exceeds
1 percent of total assets or 20 percent of total capital,
whichever is less. The names of the countries reported
should be as they appear on Form FFIEC 009. The
United States should be excluded from this report.

Column 1—Amount of Cross-border Claims
Outstanding After Mandated Adjustments for
Transfer of Exposure (excluding derivative
products)
For each country line reportable on the
FFIEC 009a report, report in Column 1 the sum of
Columns 1 through 5 from Schedule C, Part II, of the
FFIEC 009 report.

Column 2—Amount of Foreign–Office Claims
on Local Residents (excluding derivative
products)
For each country line reportable on the
FFIEC 009a report, report in Column 2 the sum of
Columns 6 through 10 from Schedule C, Part II, of the
FFIEC 009 report.

Column 3—Amount of Gross Claims
Outstanding from Derivative Products after
Mandated Adjustments for Transfer of
Exposure
List the total amount of claims from derivative products: From the FFIEC 009 report, Column 5 of Schedule D.

Column 4—Total Amount of Cross-Border
Claims and Foreign–Office Claims on Local
Residents
Total of Columns 1 through 3.

Column 5—Gross Foreign-Office Liabilities
List the total amount of gross foreign-office liabilities
as reported on the FFIEC 009 report, Columns 1 and 2
of Schedule L. Note that Columns 1 and 2 of Schedule L include foreign-office liabilities to both local and
non-local residents.

Columns 6 to 14: Distribution of Amounts
Outstanding in Columns 1 and 2 (except
Column 13)
Column 6—Banks
Report the amounts included in Columns 1 and 2 of
this report where the counterparties are banks, as

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defined in Section II.D.1 of the FFIEC 009 instructions. These amounts are included on
FFIEC 009 report on Schedule C, Part II, Columns 1
and 6, and Schedule D, Column 1.

Column 7—Public
Report the amounts included in Columns 1 and 2 of
this report where the counterparties are public organizations, as defined in Section II.D.2 of the
FFIEC 009 instructions. These amounts are included
on FFIEC 009 report on Schedule C, Part II, Columns
2 and 7, and Schedule D, Column 2.

Column 8—Non-Bank Financial Institutions
(NBFIs)
Report the amounts included in Columns 1 and 2 of
this report where the counterparties are NBFIs, as
defined in Section II.D.3 of the FFIEC 009 instructions. These amounts are included on
FFIEC 009 report on Schedule C, Part II, Columns 3
and 8, and Schedule D, Column 3.

Column 9—Other
Report the amounts included in Columns 1 and 2 of
this report where the counterparties cannot be classified as Banks, Public or NBFIs (see Section II.D.6 of
the FFIEC 009 instructions). These amounts are
included on the FFIEC 009 report on Schedule C,
Part II, Columns 4, 5, 9 and 10, and Schedule D, Column 4.

Columns 10 and 11—By Maturity
For each country, distribute the amounts reported in
Columns 1 and 2 according to time remaining to maturity as defined in Section IV.A of the
FFIEC 009 instructions: One Year and Under (Column 10) and Over One Year (Column 11).
In completing Columns 10 and 11, estimates may be
used.

Columns 12 and 13—Trading Assets
For each country, distribute the amounts reported in
Columns 1 and 2 that are claims classified as held for
trading. The amounts are included on the
FFIEC 009 report on Schedule C, Part II, Column 17.

In Column 13, report amounts included on the
FFIEC 009 report on Schedule C, Part II, Column 18
that represent short positions in the same securities, at
the issuer (on a legal entity basis) and instrument level
(i.e., debt versus debt and equity versus equity) as the
long positions reported in Column 12 of this report.

Column 14—Securities (HTM and AFS)
For each country, distribute the amounts reported in
Columns 1 and 2 that represent securities that the
reporter owns and that are classified as held-tomaturity or available-for-sale. These amounts are
included on the FFIEC 009 report on Schedule C,
Part II, Column 12.

Columns 15 to 18: Collateral Held Against
Claims with No Risk Transfers
Columns 15 through 18 below are to be reported based
on the location of the counterparty and are not
mutually-exclusive.
In Column 15, report for each country claims included
in Columns 1 and 2 that represent claims for which the
obligor provided collateral that did not meet the definition of collateral for risk-transfers of claims, namely
through resale agreements, securities lending arrangements and other similar financing agreements. This
amount is included on the FFIEC 009 report on
Schedule C, Part II, Column 13.
In Column 16, report for each country the amounts
included in Column 15 of this report where the collateral provided was cash. This amount is included on the
FFIEC 009 report on Schedule C, Part II, Column 14.
In Column 17, report for each country the amounts
included in Column 15 where the holder of the cash
collateral or the issuer of the securities provided for
collateral are in the same country as the counterparty
to the transaction. This amount is included on the
FFIEC 009 report on Schedule C, Part II, Column 15.
In Column 18, report for each country the amounts
included in Column 15 that represent claims resulting
from resale agreements, securities lending transaction,
or similar financing agreements. This amount is
included on the FFIEC 009 report on Schedule C,
Part II, Column 16.
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Columns 19 and 20: Cross-Border and
Foreign-Office Commitments and
Guarantees

FFIEC 009 instructions. The amounts are included on
the FFIEC 009 report on Schedule O, Columns 5
and 6.

Column 19—Unused Commitments

Part B

Report for each country the amounts included on the
FFIEC 009 report on Schedule O, Column 1, that represent unused commitments. See Section VII.A of the
FFIEC 009 instructions for additional details.

Provide the name of each country not listed in Part A
where the institution has exposure, as defined for Column 4 of Part A, which exceeds 0.75 percent but does
not exceed 1 percent of the reporting institution’s
assets or is between 15 percent and 20 percent of its
total capital, whichever is less. In the box provided, give
the total amount of exposure to all of the countries
listed in Part B.

Column 20—Guarantees (Excluding Credit
Derivatives Sold)
Report for each country the amounts included on the
FFIEC 009 report on Schedule O, Column 2, that represent legally binding guarantees and insurance contracts issued by the reporter’s U.S. or foreign offices for
which the ultimate obligor is not a U.S. resident,
excluding credit derivatives sold. Reporting should be
done based on the location of the ultimate obligor.

Columns 21 through 24: Credit Derivatives
(By Reference Entity)
Columns 21 and 22—Gross-Gross
Report in Column 21, by country of the underlying
reference asset, the notional value of total credit
derivatives purchased. The amounts are included on
the FFIEC 009 report on Schedule O, Column 3.
Report in Column 22, by country of the underlying
reference asset, the notional value of total credit
derivatives sold. The amounts are included on the
FFIEC 009 report on Schedule O, Column 4.

Columns 23 and 24—Gross-Net
Report in Columns 23 and 24, as appropriate, the consolidated net position of credit derivative contracts
included in Columns 21 and 22. Netting should be
done as specified in Section VII.C.2 of the

Optional Management Statement
Concerning the Country Risk Information
Reported On the FFIEC 009a
The management of the reporting institution may, if it
wishes, submit a brief statement concerning the data
submitted on this report. This statement may be used
by management to explain any differences between the
information contained in this report and information
filed with the Securities and Exchange Commission
pursuant to U.S. securities laws, or to provide any other
information concerning the data that management
believes would further public understanding of the
reporting institution’s country exposure. All information in the narrative statement must be accurate and
not misleading. Appropriate efforts shall be taken by
the filing institution to ensure the statement’s accuracy.
As this optional statement will be made available to the
public as submitted, institutions choosing to submit it
should ensure that the statement does not contain
information that they are not willing to have made
public or that would compromise the privacy of their
customers.
The optional statement should be entered in the
remarks section of the Reporting Central application.

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