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pdfFFIEC 009 Country Exposure Report
Draft Reporting Form and Instructions for Revisions
Effective Date as of the December 31, 2022, Report Date
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The following draft reporting form and draft instructions, both of which are subject to change,
present the pages from the FFIEC 009 Country Exposure Report as they are proposed to be
revised as of the December 31, 2022, report date, subject to final approval by the U.S. Office of
Management and Budget (OMB). These proposed revisions are described in the federal banking
agencies’ initial 60-day Paperwork Reduction Act (PRA) Federal Register notice published in the
Federal Register on January 20, 2022. As discussed in the agencies’ final 30-day PRA Federal
Register notice published in the Federal Register on August 11, 2022, the agencies are
proceeding with the proposed revisions to the FFIEC 009 Report, but with certain modifications.
The initial and final PRA Federal Register notices are available on the FFIEC’s webpage for the
FFIEC 009 Report.
Draft as of August 11, 2022
Table of Contents
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1. Draft FFIEC 009 Report Form……………………..Page 3 to Page 21
2. Draft FFIEC 009 Instructions……………………….Page 22 to Page 60
2
Board of Governors of the Federal Reserve System OMB Number 7100-0035
Federal Deposit Insurance Corporation
OMB Number 3064-0017
Office of the Comptroller of the Currency
OMB Number 1557-0100
Approval expires October 31, 2022
Page 1 of 34
2025
Federal Financial Institutions Examination Council
Country Exposure Report—FFIEC 009
Report at the close of business
Month / Day / Year
All FFIEC 009 respondents must submit their completed report via the Federal
Reserve System's Reporting Central application within 45 days of the reporting
date for March 31, June 30, and September 30, and within 50 calendar days of the
December 31 reporting date. Any FFIEC 009 respondent who needs guidance on
Reporting Central is encouraged to visit the Federal Reserve System website
http://www.frbservices.org/centralbank/reportingcentral/index.html, for additional
information.
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This report is required to be filed pursuant to authority contained in the
following statutes: 12 U.S.C. §§ 161 and 1817 (national banks), 12 U.S.C. § 1464
(federal savings associations), 12 U.S.C. §§ 248(a), 1844(c), and 3906 (state
member banks and bank holding companies); 12 U.S.C. §§ 1467a(b)(2) and
5412 (savings and loan holding companies); 12 U.S.C. 5365(a) (intermediate
holding companies); and 12 U.S.C. §§ 1817 and 1820 (insured state
nonmember commercial and savings banks and insured state savings
associations).
Name, title, and phone number of the person to whom inquiries regarding this
report may be directed:
Name (FCEX 8901)
Title (FCEX C496)
Area Code / Phone Number (FCEX 8902)
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Each report submitted should be signed and certified by an executive officer
of the reporting institution. "Executive Officer" is defined in 12 C.F.R. § 215.2
(e)(1). To fulfill the signature and attestation requirement for the Country
Exposure Report for this report date, attach a signed copy of this page (or a
photocopy or a computer-generated version of this page) to the paper-copy
record of the completed report that the respondent places in its files.
The Board of Governors of the Federal Reserve System, the Office of the
Comptroller of the Currency, and the Federal Deposit Insurance Corporation
are of the view that individual respondent information reported on this form is
exempt from public disclosure under Section (b)(8) of the Freedom of
Information Act (5 U.S.C. § 552 (b)(8)). Accordingly, individual respondent
information reported on this form will be considered confidential and will not be
voluntarily disclosed by the Office of the Comptroller of the Currency, the
Federal Reserve System, or the Federal Deposit Insurance Corporation.
,
I,
Name (FCEX C490)
, an authorized officer
Title (FCEX C491)
of the reporting institution named above, hereby certify on the
day of
Day (FCEX FT23)
Reporting Institution (FCEX 9017)
report has been examined by me and is true and complete to the best of my
knowledge and belief.
City (FCEX 9130)
State (FCEX 9200)
Month (FCEX FT24)
, that this
Charter Number (National Banks Only) (FCEX 9055)
Year (FCEX FT25)
Signature (FCEX H321)
Legal Entity Identifier (LEI) of the Reporting Institution (Report only if the reporting institution already
has an LEI.) (FCEX 9224)
135
Public reporting burden for this collection of information is estimated to average 131 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. A federal agency may not conduct or sponsor, and
an organization (or a person) is not required to respond to a collection of information, unless it displays a currently valid OMB control number. Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden should be directed to the Office of Information and Regulatory Affairs, Office of Management
and Budget, Paperwork Reduction Project, Washington, DC 20503, and to one of the following: Secretary, Board of Governors of the Federal Reserve System, 20th and C Streets, NW, Washington, DC 20551; Assistant Executive Secretary, Federal Deposit Insurance Corporation, Washington, DC 20429; and Legislative and Regulatory
Analysis Division, Office of the Comptroller of the Currency, Washington, DC 20219.
10/2019
12/2022
3
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 2 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
4
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12/2022
Europe
Albania
15105
Andorra
Armenia
10103
Austria
10189
Azerbaijan
Bank of International Settlements
16527
Belarus
16209
Belgium
Bosnia and Herzegovina
Bulgaria
10251
Croatia
Cyprus
Czech Republic
14214
Denmark
10502
Estonia
European Central Bank
15407
Faroe Islands
Finland
France
Georgia
10618
Germany
Gibraltar
Greece
Greenland
Guernsey
Holy See
Hungary
Iceland
Ireland
11002
14109
15202
10405
15288
13501
10707
D
R
13307
AF
T
16519
10804
16535
11088
11207
10545
13006
13102
15504
11304
11401
Isle of Man
13008
Italy
Jersey
13007
11509
Schedule C, Part I: Claims on an Immediate Risk- Counterparty Basis
FFIEC 009
Page 3 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
Europe—Continued
Kazakhstan
16543
Kosovo
Kyrgyzstan
13471
Latvia
Liechtenstein
Lithuania
Luxembourg
15601
Macedonia
Malta
14419
Moldova
16306
Monaco
Montenegro
Netherlands
Norway
12009
Poland
Portugal
Romania
15768
Russia
San Marino
Serbia
Slovakia
16101
Slovenia
Spain
Sweden
14338
Switzerland
Tajikistan
Turkey
12688
Turkmenistan
Ukraine
United Kingdom
16616
Uzbekistan
16705
TOTAL EUROPE
19992
11703
11819
13625
12106
12203
12319
15806
D
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11606
15709
AF
T
16551
12408
13218
15318
12505
12602
16578
12807
16403
13005
5
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12/2022
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 4 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
30104
Belize
35718
Bolivia
Brazil
30201
Chile
Colombia
30406
Costa Rica
30589
Ecuador
El Salvador
Falkland Islands
31003
French Guiana
36404
Guatemala
31208
Guyana
31305
Honduras
31488
Mexico
31704
Nicaragua
Panama
Paraguay
31801
Peru
32204
Suriname
37702
Uruguay
32603
Venezuela
32719
TOTAL LATIN AMERICA
39942
30309
30503
31089
36307
31887
D
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Argentina
AF
T
Latin America
32107
Caribbean
Anguilla
30228
Antigua and Barbuda
Aruba
Bahamas
35203
Barbados
30155
Bermuda
35602
35254
35319
6
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12/2013
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 5 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
36161
Cayman Islands
36137
Cuba
Curacao
Dominica
30708
Dominican Republic
Eastern Caribbean Central Bank
30805
Grenada
Guadeloupe (and smaller French islands)
36706
Haiti
31402
Jamaica
Martinique
Montserrat
St. Martin and St. Barthelemy
St. Kitts and Nevis
St. Lucia
St. Maarten
St. Vincent and the Grenadines
31607
Trinidad and Tobago
Turks and Caicos Islands
32409
Virgin Islands, British
35807
TOTAL CARIBBEAN
34401
36188
36218
35416
36803
37001
37109
36471
37303
37508
36196
D
R
Bonaire, St. Eustatius and Saba
AF
T
Caribbean—Continued
37605
37818
Asia
Afghanistan
40401
Bahrain
Bangladesh
40703
Bhutan
Brunei
Burma
40819
Cambodia
41203
40746
41009
41106
7
12/2013
12/2022
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 6 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
41408
East Timor
45004
Hong Kong
India
Indonesia
42005
Iran
Iraq
Israel
42307
Japan
Jordan
Korea, North
42609
Korea, South
Kuwait
Laos
43001
Lebanon
43419
Macau
Malaysia
Maldives
43508
Mongolia
Nepal
43818
Oman
Pakistan
Philippines
44105
Qatar
Saudi Arabia
Singapore
45101
Sri Lanka
Syria
41319
Taiwan
Thailand
46302
United Arab Emirates
46604
42102
42218
42404
42501
42706
44407
43109
43303
43605
D
R
China: Mainland
AF
T
Asia—Continued
43702
44202
44709
44806
45608
46019
46205
46418
8
12/2013
12/2022
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 7 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
Asia—Continued
Vietnam
46906
West Bank and Gaza
Yemen
47201
TOTAL ASIA
49999
50105
Angola
Bank of Central African States (BEAC)
50202
Benin
51802
Botswana
Burkina Faso
50504
Burundi
50806
Cameroon
Cape Verde
Central African Republic
Central Bank of West African States (BCEAO)
51004
Chad
Comoros
Congo (Brazzaville)
51403
Congo (Kinshasa)
Cote d'Ivoire (Ivory Coast)
Djibouti
Egypt
51705
Equatorial Guinea
Eritrea
51942
Ethiopia
Gabon
Gambia, The
52108
Ghana
Guinea
52604
50318
57118
51209
51306
50644
D
R
Africa
Algeria
AF
T
47104
51519
51608
53007
52302
57002
52019
52418
52507
52701
9
12/2013
12/2022
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 8 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
Africa—Continued
Guinea-Bissau
54402
Kenya
Lesotho
53104
Liberia
Libya
Madagascar
53201
Malawi
Mali
Mauritania
53503
Mauritius
Mayotte
53805
Morocco
54003
Mozambique
54089
Namibia
Niger
Nigeria
54127
Reunion
Rwanda
Saint Helena
Sao Tome and Principe
54607
Senegal
Seychelles
Sierra Leone
55301
Somalia
South Africa
South Sudan
55603
Sudan
56103
Swaziland
Tanzania
Togo
Tunisia
56219
53406
53589
53708
54518
54208
54305
D
R
53309
AF
T
53155
55018
55107
55204
55409
55506
55719
53392
56405
56502
56707
10
12/2013
12/2022
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 9 of 34
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Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
Africa—Continued
Uganda
Western Sahara
56804
Zambia
57207
Zimbabwe
54704
TOTAL AFRICA
59994
Other Countries
Australia
60089
60208
Fiji
60607
French Polynesia
60704
Kiribati
60526
Marshall Islands
61204
Micronesia, Federated States of
60305
Nauru
61301
New Caledonia
New Zealand
Niue
61409
Palau
Papua New Guinea
Pitcairn Islands
St. Pierre and Miquelon
Samoa
Solomon Islands
Tokelau Islands
62502
Tonga
Tuvalu
62448
Vanuatu
61603
Wallis and Futuna
TOTAL OTHER COUNTRIES
69906
60402
D
R
British Indian Ocean Territory
Cook Islands
AF
T
56006
61689
61808
61751
62103
62219
62618
62308
62405
60518
60119
11
12/2022
12/2013
Schedule C, Part I: Claims on an Immediate Risk - Counterparty Basis
FFIEC 009
Page 10 of 34
As of
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Name of Reporting Institution
Outward Claims with Guarantors in
Other Sectors or Jurisdictions
Immediate-Counterparty Basis
Cross-Border Claims
U.S. Dollar Amounts in Millions
FCEX
9151
Country (a)
Canada
Breakdown
of Total of
Columns
1 through 10
Claims on Local
Residents in Non-Local Currency
Remaining
Maturity Up
to and
Including
1 Year
Households
Month / Day / Year
Redistribution of Claims to Adjust for Ultimate Risk
Outward Risk Transfers of Claims
Reported in Columns 1 through 10
and 12 or on U.S. residents
Guarantor Basis
Inward Risk Transfers of Claims
Reported in Columns 13 through 17
Claims on
Local
Residents
in
Local
Currency
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Claims on
Banks
Claims on
Public
Claims on
NBFIs
Claims on
Corporate
Claims on
Households
Inward Claims with Guarantors in Other
Sectors or Jurisdictions
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
9207
C915
C916
M851
M852
M853
C918
C919
M854
M855
M856
C921
C922
C923
C924
M857
M858
M859
C926
C927
M860
M861
M862
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)
(22)
29998
72907
European
73903
Latin American
74918
Caribbean
74942
Asian
African
Middle Eastern
75906
TOTAL INT'L & REGIONAL ORGANIZATIONS
79995
TOTAL FOREIGN COUNTRIES
69995
United States
01007
GRAND TOTAL
99996
76902
77909
D
R
International
AF
T
International & Regional Organizations
12
12/2013
12/2022
Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 11 of 34
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Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Trading
Repurchase
Assets
Agreements
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
Europe
Albania
15105
Andorra
Armenia
10103
Austria
Azerbaijan
Bank of International Settlements
10189
Belarus
16209
Belgium
Bosnia and Herzegovina
Bulgaria
10251
Croatia
Cyprus
Czech Republic
14214
Denmark
10502
Estonia
European Central Bank
15407
Faroe Islands
Finland
France
Georgia
10618
Germany
Gibraltar
Greece
Greenland
Guernsey
Holy See
Hungary
Iceland
Ireland
Isle of Man
Italy
Jersey
11002
13307
14109
15202
10405
15288
13501
10707
NEW Column
NEW Column
D
R
16527
AF
T
16519
Of Which,
U.S.
M87X
(16)
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
10804
16535
11088
11207
10545
13006
13102
15504
11304
11401
13008
11509
13007
13
12/2013
12/2022
Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 12 of 34
As of
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Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
Europe—Continued
Kazakhstan
16543
Kosovo
Kyrgyzstan
13471
Latvia
Liechtenstein
Lithuania
Luxembourg
15601
Macedonia
Malta
14419
Moldova
16306
Monaco
Montenegro
Netherlands
Norway
12009
Poland
Portugal
Romania
15768
Russia
San Marino
Serbia
Slovakia
16101
Slovenia
Spain
Sweden
14338
Switzerland
Tajikistan
Turkey
12688
Turkmenistan
Ukraine
United Kingdom
16616
Uzbekistan
16705
TOTAL EUROPE
19992
15709
11703
11819
13625
12106
12203
12319
15806
NEW Column
NEW Column
D
R
11606
AF
T
16551
Of Which,
U.S.
M87X
(16)
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
12408
13218
15318
12505
12602
16578
12807
16403
13005
14
12/2013
12/2022
Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 13 of 34
As of
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Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
30104
Belize
35718
Bolivia
Brazil
30201
Chile
Colombia
30406
Costa Rica
30589
Ecuador
El Salvador
Falkland Islands
31003
French Guiana
36404
Guatemala
31208
Guyana
31305
Honduras
31488
Mexico
31704
Nicaragua
Panama
Paraguay
31801
Peru
32204
Suriname
37702
Uruguay
32603
Venezuela
32719
TOTAL LATIN AMERICA
39942
30309
30503
31089
36307
31887
Of Which,
U.S.
M87X
(16)
NEW Column
NEW Column
D
R
Argentina
AF
T
Latin America
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
32107
Caribbean
Anguilla
30228
Antigua and Barbuda
Aruba
Bahamas
35203
Barbados
30155
Bermuda
35602
35254
35319
15
12/2013
12/2022
Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 14 of 34
As of
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Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
36161
Cayman Islands
36137
Cuba
Curacao
Dominica
30708
Dominican Republic
Eastern Caribbean Central Bank
30805
Grenada
Guadeloupe (and smaller French islands)
36706
Haiti
31402
Jamaica
Martinique
Montserrat
St. Martin and St. Barthelemy
St. Kitts and Nevis
St. Lucia
St. Maarten
St. Vincent and the Grenadines
31607
Trinidad and Tobago
Turks and Caicos Islands
32409
Virgin Islands, British
35807
TOTAL CARIBBEAN
34401
36188
36218
35416
36803
37001
37109
36471
37303
37508
36196
Of Which,
U.S.
M87X
(16)
NEW Column
NEW Column
D
R
Bonaire, St. Eustatius and Saba
AF
T
Caribbean—Continued
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
37605
37818
Asia
Afghanistan
40401
Bahrain
Bangladesh
40703
Bhutan
Brunei
Burma
40819
Cambodia
41203
40746
41009
41106
16
12/2022
12/2013
Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 15 of 34
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Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
41408
East Timor
45004
Hong Kong
India
Indonesia
42005
Iran
Iraq
Israel
42307
Japan
Jordan
Korea, North
42609
Korea, South
Kuwait
Laos
43001
Lebanon
43419
Macau
Malaysia
Maldives
43508
Mongolia
Nepal
43818
Oman
Pakistan
Philippines
44105
Qatar
Saudi Arabia
Singapore
45101
Sri Lanka
Syria
41319
Taiwan
Thailand
46302
United Arab Emirates
46604
42102
42218
42404
42501
42706
44407
43109
43303
43605
Of Which,
U.S.
M87X
(16)
NEW Column
NEW Column
D
R
China: Mainland
AF
T
Asia—Continued
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
43702
44202
44709
44806
45608
46019
46205
46418
17
12/2013
12/2022
Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 16 of 34
As of
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Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
Asia—Continued
TOTAL ASIA
47201
47104
49999
Africa
Algeria
50105
Angola
Bank of Central African States (BEAC)
50202
Benin
51802
Botswana
Burkina Faso
50504
Burundi
50806
Cameroon
Cape Verde
Central African Republic
Central Bank of West African States (BCEAO)
51004
Chad
Comoros
Congo (Brazzaville)
51403
Congo (Kinshasa)
Cote d'Ivoire (Ivory Coast)
Djibouti
Egypt
51705
Equatorial Guinea
Eritrea
51942
Ethiopia
Gabon
Gambia, The
52108
Ghana
Guinea
52604
50318
57118
51209
51306
50644
AF
T
West Bank and Gaza
Yemen
46906
Of Which,
U.S.
M87X
(16)
NEW Column
NEW Column
D
R
Vietnam
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
51519
51608
53007
52302
57002
52019
52418
52507
52701
18
12/2013
12/2022
Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 17 of 34
As of
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Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
Africa—Continued
Guinea-Bissau
54402
Kenya
Lesotho
53104
Liberia
Libya
Madagascar
53201
Malawi
Mali
Mauritania
53503
Mauritius
Mayotte
53805
Morocco
54003
Mozambique
54089
Namibia
Niger
Nigeria
54127
Reunion
Rwanda
Saint Helena
Sao Tome and Principe
54607
Senegal
Seychelles
Sierra Leone
55301
Somalia
South Africa
South Sudan
55603
Sudan
56103
Swaziland
Tanzania
Togo
Tunisia
56219
53406
53589
53708
54518
54208
54305
NEW Column
NEW Column
D
R
53309
AF
T
53155
Of Which,
U.S.
M87X
(16)
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
55018
55107
55204
55409
55506
55719
53392
56405
56502
56707
19
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Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 18 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
Africa—Continued
Uganda
Western Sahara
56804
Zambia
57207
Zimbabwe
54704
TOTAL AFRICA
59994
60208
Fiji
60607
French Polynesia
60704
Kiribati
60526
Marshall Islands
61204
Micronesia, Federated States of
60305
Nauru
61301
New Caledonia
New Zealand
Niue
61409
Palau
Papua New Guinea
Pitcairn Islands
62502
St. Pierre and Miquelon
Samoa
Solomon Islands
Tokelau Islands
62219
Tonga
Tuvalu
62448
Vanuatu
61603
Wallis and Futuna
TOTAL OTHER COUNTRIES
69906
60402
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60089
British Indian Ocean Territory
Cook Islands
Of Which,
U.S.
M87X
(16)
NEW Column
(19)
(20)
NEW Column
D
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Other Countries
Australia
(17)
56006
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
61689
61808
61751
62103
62618
62308
62405
60518
60119
20
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Schedule C, Part II: Claims on an Ultimate Risk Guarantor Basis and Memorandum Items
FFIEC 009
Page 19 of 34
As of
Before completing this form, please read carefully the instructions and definitions for preparation of this report.
Name of Reporting Institution
Ultimate-Risk Guarantor Basis
Cross-Border Claims
Memorandum
Collateral Held Against Claims With No Risk Transfer
(Reported in Columns 1 through 10—By Counterparty)
Claims on Local Residents
Breakdown Breakdown
of Total of
of Total of
Columns
Columns
6 through 10 1 through 10
9151
Country (a)
Canada
Securities
(HTM and
AFS)
Total
Collateral
Of Which,
Cash
Of Which,
Same
Country
Trading Assets
Of Which,
Resale and
Reverse
Repurchase
Trading
Agreements
Assets
and Securities (Reported in Offsetting
Lending
Columns Positions for
(Counterparty) 1 through 10) Trading Book
Banks
Public
NBFIs
Corporate
Households
Banks
Public
NBFIs
Corporate
Households
Claims in
Non-Local
Currency
9207
C929
C930
M863
M864
M865
C932
C933
M866
M867
M868
C935
M869
M870
M871
M872
M873
M956
M874
Code (b)
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(17)
(19)
(20)
U.S. Dollar Amounts in Millions
FCEX
Month / Day / Year
29998
72907
European
73903
Latin American
74918
Caribbean
74942
Asian
African
Middle Eastern
75906
TOTAL INT'L & REGIONAL ORGANIZATIONS
79995
TOTAL FOREIGN COUNTRIES
69995
United States
01007
GRAND TOTAL
99996
76902
77909
Of Which,
U.S.
M87X
(16)
NEW Column
NEW Column
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International
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International & Regional Organizations
Of Which,
Resale and
Reverse
Repurchase
Agreements
and Securities
Lending
(Collateral)
M87X
(18)
21
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12/2022
Federal Financial Institutions Examination Council
Instructions for the Preparation of
Country Exposure Report
Reporting Form FFIEC 009
Effective September 2019
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December 2022
22
Contents
General Instructions for the Preparation of the Country Exposure Report
........................................................................................................................ GEN-1
A. Introduction and Purpose .............................................................................................................. GEN-1
B. Summary Description of this Report .............................................................................................. GEN-1
C. Administrative Issues ..................................................................................................................... GEN-2
D. Who Must Report ......................................................................................................................... GEN-2
E. Accounting Issues .......................................................................................................................... GEN-4
F. Submission of Reports ................................................................................................................... GEN-4
G. Legal Entity Identifier (LEI) .......................................................................................................... GEN-5
II. Reporting Definitions ..................................................................................................................... GEN-5
A. Claims .......................................................................................................................................... GEN-5
Guarantor Basis
B. Liabilities ......................................................................................................................................
GEN-5
C. “Immediate-Counterparty” and “Ultimate-Risk” Claims ................................................................. GEN-6
D. Sector Definitions ......................................................................................................................... GEN-6
E. Cross-Border Claims and Claims on Local Residents ....................................................................... GEN-7
F. Required Risk Transfers ................................................................................................................. GEN-8
G. Netting and Offsetting ................................................................................................................... GEN-9
H. Reporting Credit Derivatives ........................................................................................................ GEN-10
III. Specific Instructions for Allocating Claims to the Rows .................................................................. GEN-11
A. The United States ........................................................................................................................ GEN-11
B. Foreign Countries ........................................................................................................................ GEN-11
C. International and Regional Organizations ..................................................................................... GEN-12
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I. General Instructions
Line Item Instructions for the Preparation of the Country Exposure Report
................................................................................................................................ C-1
Schedule L—Foreign-Office Liabilities ...................................................................................................... L-1
Schedule O—Off-Balance-Sheet Items ...................................................................................................... O-1
Schedule D—Claims from Positions in Derivative Contracts ...................................................................... D-1
Appendix A—Summary of Reporting Bases by Schedule and Column ................................................ App A-1
Schedule C—Claims
CONTENTS-1
FFIEC 009
September 2019
December 2022
23
INSTRUCTIONS FOR PREPARATION OF THE
Country Exposure Report
I. General Instructions
and the purchase of credit protection as defined in
guarantor
Sections II.F and II.H.
A. Introduction and Purpose
Schedule C, Part II, collects information on the reporter’s claims on an ultimate-risk basis and memorandum
items providing additional details related to those
claims. Claims on an ultimate-risk basis are shown in
Columns 1 through 11 of Schedule C, Part II. Schedule C, Part II, also contains memorandum items relating to claims reported on an ultimate-risk basis. Column 12 shows the amounts reported in Columns 1 guarantor
through 10 of Schedule C, Part II, that are held-tomaturity and available-for-sale securities. Columns 13
through 16 collect information on collateral mitigants
19
that do not meet the criteria for the purposes of risk
transfers of claims as defined in this report. Column 17
shows the amount of claims, on an ultimate-risk basis
(reported in Columns 1 through 10 of Part II), that are 20
held for trading. Column 18 provides any offsetting
positions held for the trading book, where an effective
offset exists (see Section II.G for a discussion of effective netting and offsetting).
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The FFIEC 009 provides information on the distribution, by country, of claims on, and liabilities to, the
United States (U.S.) and foreign residents held by U.S.
reporting entities. The data collected are used to determine the presence of credit and related risks, including
transfer and country risk. These data are also aggre18
gated and released to the public. Aggregate data are
provided to the Bank for International Settlements
(BIS), as part of an international cooperative effort to
compile and publish global data on claims on local and
foreign residents. The aggregated data, along with
applicable individual data reported on the FFIEC
009a, are available electronically through the E.16 Statistical Release (http://www.ffiec.gov/E16.htm).
B. Summary Description of this Report
The FFIEC 009 consists of four schedules (with one,
Schedule C, containing two parts).
Schedule C, Part I, collects information on the claims
on an “immediate-counterparty” basis, i.e., on the
basis of the country of residence of the borrower Guarantor
(except claims resulting from the fair value of derivative contracts). Part I also includes the redistribution of
immediate-counterparty claims to an “ultimate-risk”
basis, i.e., on the basis of the country of residence of
the guarantor or collateral provided (i.e., the “ultimate
obligor”). In Columns 1 through 12 of Part I, data are
collected on an immediate-counterparty basis. In
Columns 13 through 22 of Part I, the inward and outward redistribution of claims from an immediatecounterparty basis to an ultimate-risk basis is guarantor
shown. These redistributions arise from arrangements
such as formal guarantees, the provision of collateral,
Schedule L collects information on foreign-office
liabilities. Columns 1 and 2 show, by country and currency, foreign-office liabilities for which no payment is
guaranteed at locations outside the country of the
office, reported by the country of the foreign office.
Column 3 shows all liabilities booked at foreign offices
by the country of the creditor. Column 4 shows the net
positions of the foreign office with related offices in
other countries. These net positions are not reported
elsewhere on this report, due to the consolidation rules.
Schedule O collects information on off-balance-sheet
exposures from commitments, guarantees, and credit
derivatives. Column 1 collects any unused or undrawn
commitments, on an ultimate-risk basis, by country of
the ultimate obligor of the commitment. In Column 2,
the amount of all legally binding guarantees provided,
guarantor
GEN-1
FFIEC 009
March 2019
December 2022
24
General Instructions
except credit derivatives written, are reported by country of the counterparty to whom the guarantee is being
provided. Columns 3 through 6 provide a breakdown
of the notional amount of credit derivatives positions
purchased and sold (by country of the reference
entity), on a gross gross and gross-net basis (see Section II.H for definitions of these terms). Credit derivatives purchased that result in a risk transfer on Schedule C, Parts I and II, are excluded from this schedule. guarantor
Column 7 shows the claims, on an ultimate-risk basis
(reported in Columns 1 through 10 of Schedule C,
Part II, and Columns 1 and 2 of Schedule O), that are
trade finance related.
2. Confidentiality
The individual FFIEC 009 reports are given confidential treatment under 5 U.S.C. 552(b)(4) and (b)(8).
However, aggregated data that do not reveal the activities of individual reporting entities do not receive confidential treatment and are made public. Portions of
the aggregated data are also reported to the Bank for
International Settlements as part of an international
cooperative effort to compile and publish worldwide
data on cross-border claims.
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Schedule D collects information on the fair value of
derivative contracts of the reporter by country of
counterparty (including the United States). A sector
distribution and the total are collected in Columns 1
through 5. In Column 6, claims on bank branches that
are not formally and legally guaranteed by the head
office are reported in the country rows corresponding
to the country in which the branch is located (instead
of the country of the head office). These claims represent risk that could potentially remain in the countries
in which the branches are located.
• Federal Deposit Insurance Corporation – Sections 7
and 10 of the Federal Deposit Insurance Act
(12 U.S.C. 1817 and 1820)
C. Administrative Issues
1. Authority
This report is required to be filed by national banks,
federal savings associations, state member banks, Edge
and/or Agreement corporations, bank holding companies, savings and loan holding companies, intermediate
holding companies, insured state nonmember commercial and savings banks, and insured state savings associations pursuant to authority contained in the following statutes:
• Board of Governors of the Federal Reserve System –
Section 11a of the Federal Reserve Act (12 U.S.C.
248a), Section 5c of the Bank Holding Company Act
(12 U.S.C. 1844c), and Section 907 of the International Lending Supervision Act of 1983 (12 U.S.C.
3906), and Section 165(a) of the Dodd-Frank Act
(12 U.S.C. 5365(a)); and
• Office of the Comptroller of the Currency – the
National Bank Act, as amended (12 U.S.C. 161) and
Home Owners Loan Act (12 U.S.C. 1464);
D. Who Must Report
Reporting Entities
The Country Exposure Report (FFIEC 009) is
required to be filed quarterly by banks, savings associations, Edge and/or Agreement corporations, bank
holding companies, intermediate holding companies,
and savings and loan holding companies meeting the
criteria listed below:
Schedules C, L, and O must be completed by:
(1) Every U.S. chartered insured bank or savings
association in the 50 States of the United States,
the District of Columbia, Puerto Rico, and U.S.
territories and possessions, that has, on a fully
consolidated basis, total outstanding claims on
residents of foreign countries exceeding $30 million in the aggregate, and has at least one of the
following:
• A branch in a foreign country;
• A consolidated subsidiary in a foreign
country;
• An Edge or Agreement subsidiary;
• A branch in Puerto Rico or in any U.S. territory or possession (except that a bank or savings association with its head office in Puerto
Rico or any U.S. territory or possession need
not report if it meets only this criterion); or
• An International Banking Facility (IBF).
GEN-2
March 2019
December 2022
FFIEC 009
25
General Instructions
All references to “bank(s)” are inclusive of
“savings association(s),” unless otherwise
noted.
(2) Every Edge and/or Agreement corporation that
has total outstanding claims on residents of foreign countries exceeding $30 million, unless it is
majority owned by a bank or savings association
that is required to file a report.
(3) Every institution that meets the Schedule D
reporting requirements (see below).
(5) Every savings and loan holding company and
intermediate holding company that meets the criteria for banks in (1) above. All references to
“bank holding company(s)” are inclusive of “savings and loan holding company(s),” and “intermediate holding company(s)” unless otherwise
noted.1
D
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However, to reduce reporting burden:
Column 3 of Schedule L—Total Liabilities Booked at
Foreign Offices (by country of creditor)—is required
to be reported only by those reporters that have one or
more branches or subsidiaries located outside the fifty
states of the United States, the District of Columbia,
or a U.S. military facility (regardless of where located)
that meet the following criteria:
• Branches filing the Foreign Branch Report of Condition (FFIEC 030) that report total assets of
$500 million or more (denominated in all currencies)
on Line Item 11 on a report date,
• Subsidiaries filing the quarterly Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314) that have a banking charter and
engage in banking business, and that report $2 billion or more in total assets in Schedule BS, item 10,
and $10 million or more in total deposits in Schedule BS-M, item 6.
AF
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(4) Every U.S. bank holding company that is
required to file the FR Y-6 report (Bank Holding
Company Annual Report) and has a subsidiary
bank that is required to file this report.
ers, the holding company need not file a separate
report.
(1) If a bank holding company has only one subsidiary bank that meets the reporting requirements
and that subsidiary bank accounts for 90 percent
or more of the consolidated holding company’s
total claims on foreigners, either the holding company or the bank (but not both) should prepare a
report. However, if the only subsidiary bank that
is required to report accounts for less than 90 percent of the consolidated holding company’s
claims, only the holding company should prepare
a (consolidated) report
(2) If a bank holding company has two or more subsidiary banks that meet the reporting requirements and these subsidiary banks, together,
account for 90 percent or more of the consolidated holding company’s total claims on foreign-
1. Savings and loan holding companies (SLHCs) do not include any
trust (other than a pension, profit-sharing, stockholders’ voting, or
business trust) which controls a savings association if such trust by its
terms must terminate within 25 years or not later than 21 years and
10 months after the death of individuals living on the effective date of
the trust, and (a) was in existence and in control of a savings association
on June 26, 1967, or, (b) is a testamentary trust.
The total assets test defined above applies to the total
of the foreign branch’s or subsidiary’s international
and local assets, regardless of the currency in which the
assets are payable. If any foreign office of a reporter
exceeds the reporting threshold, then column 3 should
be completed for the reporter’s entire organization and
not just for the offices exceeding the threshold.
A Schedule D must be completed by every institution
whose FFIEC 031 or FR Y-9C (or for Edge and/or
Agreement corporations the FR 2886b) as of December 31 of the previous year shows:
(1) Total gross notional values of derivative contracts
(the sum of items 7.a.(1) through 7.a.(4), Columns A and B, and items 12.a. through 12e., Columns A through D, on Schedule RC-L of the FFIEC 031
or the sum of items 7.a.(1) through 7.a.(4), Columns A and B, and items 11.a. through 11.e.,
Columns A through D, on Schedule HC-L of the
FR Y-9C) in excess of $10 billion.
or
(2) Total gross fair values of derivative contracts (the
sum of items 7.b.(1) and 7.b.(2), Columns A and
B and items 15.a. and 15.b., Columns A through
D, on Schedule RC-L of the FFIEC 031 or the
sum of items 7.b.(1) and 7.b.(2), Columns A and
GEN-3
FFIEC 009
March 2019
26
General Instructions
B, and items 14.a. and 14.b., Columns A through
D, on Schedule HC-L of the FR Y-9C) in an
amount greater than 5 percent of their total
assets.
In addition, the bank regulatory authorities may specifically require a report (or any specific schedule
therein) to be filed by other banking organizations that
the authorities deem to have significant country
exposures.
Consolidation Rules
1. Differences between FFIEC 009 Reporting
and U.S. GAAP
The differences in accounting treatment between the
FFIEC 009 and U.S. GAAP are as follows:
Reporting Item
U.S. GAAP
FFIEC 009
Netting of Derivative Contracts
Offsetting of positive
and negative fair values are permitted
when a “right of setoff ” exists under
ASC Subtopic 21020, Balance SheetOffsetting (formerly
FASB Interpretation
No. 39, Offsetting of
Amounts Related to
Certain Contracts).
Although there is no
official FASB pronouncement, it is
industry practice to
net trading assets
against trading
liabilities in the same
security (i.e., with the
same CUSIP or
ISIN).
Offsetting of positive
and negative fair values
is permitted, consistent
with U.S. GAAP. However, only net positive
fair values are reported
on the FFIEC 009.
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The information should be reported on a fully consolidated basis. For reports from banks, the scope of coverage and the consolidation of information should be
in accordance with the procedures and tests of significance set forth in the instructions for preparation of
the FFIEC 031. For reports from bank holding companies, the information should be consolidated in
accordance with the principles set forth in the instructions for the preparation of the FR Y-9C. For Edge
and/or Agreement corporations, the information
should be consolidated in accordance with the principles set forth in the instructions for the preparation of
the FR 2886b.
Round all amounts reported on this form to the nearest
million dollars. Negative amounts are only permissible
in Column 4 of Schedule L.
As a best practice, the data reported on the
FFIEC 009 can be reconciled to the FR Y-9C (or Call
Report). However, there are no requirements to perform such a reconciliation.
Netting of Trading
Assets
CUSIP netting is
allowed for the
FFIEC 009 report. In
addition, short positions in the same issuer
and asset class of the
trading asset may be
reported as an offsetting position on Schedule C, Part II, Column 18.
E. Accounting Issues
F. Submission of Reports
All amounts should be reported in U.S. dollars regardless of the currencies in which the balances are denominated. The translations should be made on the same
basis used to prepare its (or its subsidiary bank’s)
FFIEC 031 and the FR Y-9C.
The FFIEC 009 report is to be prepared quarterly, as
of the last calendar day of March, June, September,
and December. For each quarter the reporting requirements are met (according to Section I.D), all reporting
entities must use the Federal Reserve System’s Reporting Central system to submit their completed report to
the Federal Reserve Bank of New York (FRBNY). The
submission deadline is 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.
Claims, liabilities, and unused commitments should be
reported using the same accounting basis as used on
the FFIEC 031 and FR Y-9C, unless stated otherwise
in these instructions.
Edge and/or Agreement corporations should reference
the instructions for the preparation of the
FFIEC 031 for further information on reporting definitions and generally accepted accounting principles.
If the submission deadline falls on a weekend or holiday, the report must be received on the first business
day after the Saturday, Sunday, or holiday.
GEN-4
March 2019
FFIEC 009
27
General Instructions
The Federal Reserve System Website (https://
www.frbservices.org/central-bank/reporting-central/
index.html ) provides additional information on
Reporting Central. The Website also includes a link
that reporters may use to contact FRBNY for technical
assistance.
Each reporting entity should keep a copy of each
report. This copy should be signed and certified by an
Executive Officer (as defined in 12 CFR 215.2(e)(1)) of
the reporting entity.
G. Legal Entity Identifier (LEI)
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II. Reporting Definitions
• Positive fair value of interest rate, foreign exchange,
equity, commodity and other derivative contracts
(reported in Schedule D)
• Customers’ liability on acceptances outstanding
• Accrued income receivables (including interest, commissions and income earned or accrued and applicable to current or prior periods, but not yet
collected)
• Resale agreements and other financing agreements
(reported net if permitted under ASC Topic 210-20,
previously FIN 41)
• Asset sales with recourse
AF
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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.
• Investments in unconsolidated subsidiaries and associated companies
For the September 30, 2019, and the December 31,
2019, report dates, reporting entities may report
“claims” and “liabilities” using either the definitions as
they have been revised as of September 30, 2019, or the
previously existing definitions.
A. Claims
The term “claims” follows the definition for assets in
the instructions for preparation of the FFIEC 031 and
FR Y-9C and includes, but is not limited to, the following types of assets:
• Vault Cash
• Deposit balances, both interest bearing and noninterest bearing, held at banks
• Balances with central banks and official institutions
• Participations and syndications of loans
• Deferred tax assets
Exclude:
Premises, right-of-use assets, other real estate owned,
bank-owned life insurance, company-owned life insurance, physical commodities held in inventory, pension
assets, goodwill, and other intangible assets.
B. Liabilities
The term “liabilities” follows the definition in the
instructions for preparation of the FFIEC 031 and
FR Y-9C and includes, but is not limited to, the following types of liabilities:
• Deposit balances, both interest bearing and noninterest bearing.
• Brokerage balances
• Debt securities
• Borrowings
• Short sales
• Federal funds sold
• Repurchase agreements and other financing agreements (reported net if permitted under ASC Topic
210-20, previously FIN 41)
• Loans
• Lease liabilities for finance and operating leases
• Holdings of acceptances of banks
• Trade date payables
• Direct lease financing
• Deferred tax liabilities
• Securities
GEN-5
FFIEC 009
September 2019
28
General Instructions
Guarantor Basis
C. “Immediate-Counterparty” and
“Ultimate-Risk” Claims
Claims are to be reported on an “immediatecounterparty” basis in Columns 1 through 12 of guarantor
Schedule C, Part I, and on an “ultimate-risk” basis in
Columns 1 through 10 of Schedule C, Part II. The obligor on an immediate-counterparty basis is the entity
that issued the security or otherwise incurred the liability. The obligor of a claim on an ultimate-risk basis is
any person, business, institution, or instrument that
provides any of the types of credit protection described
in Section II.F, “Required Risk Transfers” and Section II.H “Reporting Credit Derivatives.”
• Those government owned banks, including development banks, that perform as an important part of
their activities, the functions of a treasury, central
bank, exchange control office, or stabilization fund
• International or regional organizations or subordinate or affiliated agencies thereof, created by treaty
or convention between sovereign states, including the
International Monetary Fund, the International
Bank for Reconstruction and Development (World
Bank), the Bank for International Settlements, the
Inter-American Development Bank, and the United
Nations
D. Sector Definitions
AF
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3. Non-Bank Financial Institutions (NBFIs)
Reporting sectors are determined based on the legal
entity of the counterparty. The following sector definitions are used for all columns of this report that require
sector distinctions:
1. Banks
D
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The definition of banks encompasses all institutions
included in “Banks, U.S. and Foreign” in the Report of
Condition as well as savings banks, savings associations, discount houses, and other similar depository
institutions. Banks also include banking institutions
owned by foreign governments, unless such institutions
function as central banks or banks of issue, in which
case they are treated as “public” institutions.
Exposures to banks are to be reported in Columns 1, 6,
13, and 18 of Schedule C, Part I; Columns 1 and 6 of
Schedule C, Part II; and Column 1 of Schedule D.
2. Public
The definition of the public sector is similar to “Foreign Governments and Official Institutions” in the
Report of Condition, but also includes public sector
institutions in the U.S. Public sector institutions
include:
• Central, state, provincial and local governments and
their departments, and agencies
• Treasuries, ministries of finance, central banks, stabilization funds, exchange authorities, and diplomatic
establishments
Non-bank financial institutions are defined as businesses and institutions other than “banks” and “public,” as defined above, that are primarily engaged in
proprietary investments and/or in the provision of
financial services to other organizations and households. These services include, but are not limited to,
financial intermediation services whose functions are
predominantly: the extension of credit for business
purposes, brokerage services (engaged in the brokering
of securities, commodities or other financial instruments), underwriting services, financial management
services, credit origination services, credit card services,
insurance services, and pension services. Types of nonbank financial organizations include, but are not limited to:
• Securities firms
• Bank holding companies (BHCs)
• Insurance firms
• Money market funds
• Pension funds
• Investment banks
• Private equity companies
• Credit card issuers
• Hedge funds
• Trusts
• Finance companies
• Mortgage companies
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General Instructions
• Factors and other financial intermediaries who
extend short-term business credit to finance inventories or carry accounts receivable
This sector excludes federal, state, and local governments; however, it includes agencies and instrumentalities of governments such as pension funds and insurance companies that provide nonbank financial
services that are not directly governmental in nature.
Exposures to NBFIs are to be reported in Columns 3,
8, 15, and 20 of Schedule C, Part I; Columns 3 and 8 of
Schedule C, Part II; and Column 3 of Schedule D.
6. Other
The “Other” sector applies only for reporting on
Schedule D and the FFIEC 009a “Country Exposure
Information Report.” The “Other” sector refers to
those counterparties classified as Corporate or Households, as defined above.
E. Cross-Border Claims and Claims on
Local Residents
1. Cross-Border Claims
Cross-border claims of each reporter cover:
• All claims of its U.S. offices (including IBFs, Edge
and Agreement corporations, and offices in Puerto
Rico and U.S. territories and possessions) with residents of foreign countries, regardless of the currency
in which the claim is denominated; and,
AF
T
4. Corporate
D
R
The corporate sector is defined as any organization,
including a non-profit, that is principally engaged in
producing goods or non-financial services. This sector
excludes federal, state, and local governments; however, it includes agencies and instrumentalities of governments such as utilities that produce goods or nonfinancial services that are not strictly governmental in
nature.
Report as Corporate any organization that cannot be
classified as “Bank,” “Public,” “NBFI,” or
“Household.”
Exposures to corporate counterparties are to be
reported in Columns 4, 9, 16 and 21 of Schedule C,
Part I; Columns 4 and 9 of Schedule C, Part II; and
Column 4 (under “Other”) of Schedule D.
5. Households
Include in the household sector all claims on households, families, and individuals for personal expenditures (using the same definition of households as used
in the FR Y-9C, Schedule HC-C, item 6, “Loans to
individuals for household, family, and other personal
expenditures”). Therefore, any reportable claims on
households should be reported, regardless of the product type (e.g., loans and consumer leases).
Exposures to households would be reported in Columns 5, 10, 17, and 22 of Schedule C, Part I; Columns
5 and 10 of Schedule C, Part II; and Column 4 (under
“Other”) of Schedule D.
• All claims of each of its offices in a foreign country
with residents of other countries (i.e., countries other
than the country in which the office is located,
including the United States), regardless of the currency in which the claim is denominated.
Since the reports are on a fully consolidated bank (or
bank holding company) basis, cross-border claims
exclude any claims against those branches or subsidiaries that are part of the consolidated bank (or bank
holding company). However, claims on unconsolidated
subsidiaries or associated companies of the reporter
should be reported. Thus, a banking subsidiary that
submits an FFIEC 009 report should include claims on
subsidiaries of the bank’s parent holding company.
2. Claims on Local Residents
Claims on local residents are all claims of the institu- guarantor
tion’s offices, regardless of location (including the
U.S.), on residents of the country in which the office is
located. The definition of “cross-border claims” and
“claims on local residents” is the same on an
“immediate-counterparty” basis and an “ultimaterisk” basis. However, some claims may be categorized
differently, or be placed in different sectors or country
rows, because the sector or country of residence of the
immediate obligor may differ from that of the ultimate
obligor.
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General Instructions
Claims of the institution’s U.S. office(s) on a resident
of the United States should be reported as a claim on a
local resident, while claims of the institution’s foreign
office(s) on a resident of the United States should be
reported as a cross-border claim.
3. “Local” vs. “Non-Local” Currency
claims with guarantors in other sectors
and jurisdictions
F. Required Risk Transfers
guarantor
The outward and inward redistribution of claims from
an “immediate-counterparty” basis to an “ultimaterisk” basis is reported in Columns 13 through 22 of
Schedule C, Part I. Outward risk transfers are reported
in Columns 13 through 17, and inward risk transfers
are reported in Columns 18 through 22.
D
R
guarantor
Guarantees providing protection to the reporter
should result in the reallocation of the claim from the
sector and country row of the immediate borrower (in
Columns 13 through 17 of Schedule C, Part I) to the
sector and country row of the provider of the guarantee (in Columns 18 through 22 of Schedule C, Part I).
Conversely, if the reporter provides a guarantee on a
foreign credit, the amount of the guarantee should be
reported in Column 2 of Schedule O, “Guarantees
(Excluding Credit Derivatives Sold).”
See Section II.F.5 for treatment of guarantees provided
in the form of cash and debt or equity securities held as
collateral. See Section II.H.1 for treatment of guarantees in the form of purchased credit derivatives.
AF
T
A currency is considered to be a “local” currency of a
country only if the country, directly or through a currency union, has the authority to issue that currency.
Thus, U.S. dollars would not be considered to be the
local currency of any country other than the United
States, whereas euros would be considered to be the
local currency of any country that is a member of the
European Monetary Union, but of no other country.
Guarantees provided by the reporter’s head office or
other consolidated units of the reporter should not be
considered guarantees for the purposes of this report.
guarantor
If full credit protection is provided by more than one
source, e.g., from multiple guarantors or multiple
forms of collateral, the ultimate-risk claim should be
determined by the sector and residence of the highest
rated credit enhancer (using the reporter’s internal rating system). For instance, for a claim on a bank branch
for which eligible collateral is posted, it should be
determined whether the counterparty’s parent bank or
the collateral has a higher credit rating. The claim
should then be reported, accordingly, on an ultimaterisk basis.
Ownership of fund shares in an unconsolidated investment entity should be reported on an immediate and
ultimate risk basis according to the country and sector
of the investment entity. The underlying assets of the
investment fund do not provide an effective guarantee
for purposes of the FFIEC 009 report.
2. Insurance Policies
Insurance policies that guarantee payment of a claim if
the borrower defaults or if non-convertibility occurs
should be reallocated to the non-bank sector of the
country of residence of the entity providing the insurance. However, limited purpose policies, such as
“political risk insurance” policies should not be used as
a basis for reallocation. Conversely, if a reporter issues
an insurance policy guaranteeing the payment of a
claim if a foreign borrower defaults, the amount of the
protection sold should be reported in Column 2 of
Schedule O, “Guarantees (Excluding Credit Derivatives Sold).”
1. Guarantees
Guarantees are legally binding commitments by a third
party to repay a debt if the direct obligor fails to do so.
Guarantees include financial and performance standby
letters of credit and acceptances (for the amount of the
participation sold). Documents that do not establish
legal obligations, such as “comfort” letters, letters of
awareness, or letters of intent, are not guarantees for
the purpose of this report.
3. Head Offices
For the purposes of this report, claims on a bank
branch (but not on a subsidiary) of a banking organization are considered to be guaranteed by the head
office of the organization, even without a legally binding agreement. Therefore, claims on bank branches
should be reallocated to the bank sector in the country
in which the parent institution is chartered.
GEN-8
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General Instructions
4. Credit Derivatives
guarantor basis
See Section II.H.
5. Collateralized Claims
Eligible collateral for risk transfers on the
FFIEC 009 includes collateral that is:
(1) Liquid and readily realizable, and
(2) Is realizable outside of the country of residence of
the borrower.
Eligible collateral includes:
Cash
Debt and Equity Securities
Collateral provided by obligors to offset positive fair
value positions of derivative contracts should be
reported in Schedule D, using the same methodology
for reporting securities and cash collateral as stated
above. If the reporter has a derivative contract with a
positive fair value, and cash (or securities) collateral is
provided, the collateralized portion of the fair value
should be reported on Schedule D according to the
sector and country of the institution holding (or issuing) the collateral, and the uncollateralized portion
should be reported according to the sector and country
of the counterparty.
AF
T
If collateral is in the form of cash, the sector and country of the “guaranteeing” party is the sector and country of residence of the legal entity where the cash is
held (i.e., the legal entity that has the liability for the
cash collateral). Cash collateral posted to the same sector and country as the immediate claim should result in
no risk transfer.
should only be risk-transferred up to the amount of
the underlying claim (see Example 22 of Section V.C).
The ultimate-risk claim should be reported by the sector and country of the highest rated credit enhancer(s) (using the reporter’s internal rating system).
D
R
If collateral is in the form of investment grade debt or
marketable equity securities, the sector and country of
the “guaranteeing” party is the sector and country of
residence of the party issuing the security.
However, in the case of resale agreements, securities
lending arrangements, and other similar financing agreements, the claims should be allocated based on the counterparty, not the underlying collateral (i.e., no risktransfer should be made). These should be reported at
the value of the outstanding claim, regardless of the
amount of collateral provided. Resale agreements should
also be reported by country of the counterparty in the
memorandum section of Schedule C, Part II. (See Section V.B.2.)
If the collateral consists of a basket of convertible currencies or investment grade securities of different
countries in an amount equal to the immediate claim,
break out the underlying exposures on a pro-rata basis
and report opposite the appropriate country and
sector.
Assets such as real estate are not liquid or readily realizable and thus cannot be used for a risk transfer.
6. Risk Participations
Loans and acceptances, where the reporting bank has
sold a legally binding risk participation, are considered
to be guaranteed by the purchaser of the participation
for the amount of the participation sold.
G. Netting and Offsetting
Netting and offsetting of long and short positions is
not permitted on the FFIEC 009 report with the exception of the following:
(1) “CUSIP netting”2 may be conducted and
reported on Schedule C, Parts I and II, or Schedule L, as appropriate. CUSIP netting should only
be applied when the office of the reporter with
the position, the country of the issuer of the
underlying security, and the counterparty to a
short position are in the same country.
20
(2) On Schedule C, Part II, report in Column 18 positions entered into for the purpose of offsetting the
trading positions reported in Column 17, “Trading Assets.” See Section V.B.3.
19
Collateral provided in the form of cash or securities in
excess of the amount of the outstanding claim (e.g., a
margin loan collateralized by securities with a fair
value that exceeds the amount of the margin loan)
2. “CUSIP netting” refers to the industry practice where trading
assets and trading liabilities in the same exact security (based on its
security identifier) may be reported on a net basis.
in Column 17. The same collateral should be allocated based on the
underlying collateral in Column 18.
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General Instructions
(3) On Schedule O, report in Columns 5 and 6, as
appropriate, the net notional value of credit
derivative contracts purchased from and sold to
the same counterparty and on the same underlying reference entity. See Section VII.C.2.
an effective guarantee, even in the case of a maturity
mismatch, prohibit clauses that reduce the effectiveness
of the guarantee in the case of default, contain effectual events of default, and reference the same legal
entity as the obligor.
(4) On Schedule D, the positive fair values of derivative contracts may be offset against negative fair
values of derivatives contracts if, and only if, the
positions were executed with the same counterparty under a legally enforceable master netting
agreement and the offsetting meets the ASC Subtopic 210-20 criteria. Otherwise, positive fair values must be reported gross.
Claims for which credit derivatives form an effective
risk transfer should be reallocated to the sector and
country of residence of the entity that is providing the
protection.
D
R
AF
T
In addition, reverse repurchase agreements may
be offset by repurchase agreements if, and only if,
the transactions were executed with the same
counterparty under a legally enforceable master
repurchase agreement (including multijurisdictional and multi-branch master netting
agreements) and the offsetting meets the criteria
in ASC Subtopic 210-20, Balance Sheet—
Offsetting. When repurchase agreements are covered by master repurchase agreements, net claim
positions should be reported on Schedule C, Parts
I and II. In addition, for purposes of the
FFIEC 009, net claims resulting from repurchase
agreements under multi-jurisdictional and/or
multi-branch master repurchase agreements are
considered guaranteed by counterparty’s head
office, or the designated office (“the counterparty”) subject to the agreement, and should be
reported in the country of the counterparty on
both an immediate and ultimate risk basis.
guarantor
Credit protection purchased to guarantee a claim
reported on an immediate counterparty basis should
only be reported on Schedule C, Parts I and II. Credit
protection purchased to hedge or offset credit protection
sold, or for trading purposes, should be excluded from
Schedule C and reported in Columns 3 and 5 of Schedule O, as appropriate.
H. Reporting Credit Derivatives
1. Risk Transfers
Reporters should report credit derivative contracts
purchased, (including, but not limited to, credit default
swaps and options, total return swaps and sovereign
risk options), as guarantees for purposes of this report,
provided the institution considers the arrangement to
be an effective credit risk mitigant based on its internal
criteria and provided the contract contains provisions
to pass the credit risk to the counterparty. A reporter’s
internal criteria should, at a minimum, include provisions that ensure the terms of credit derivatives provide
If the notional amount of the credit protection purchased is less than the amount of the immediate claim,
the notional amount of the guaranteed portion should
be reallocated to the sector and country of the credit
protection seller, and the non-guaranteed portion
should be reported opposite the sector and country of
the immediate obligor in Columns 1 through 10 of
Schedule C, Part II.
If the notional amount of the credit protection purchased exceeds the value of the immediate claim, the
immediate claim should be reported in Columns 13
through 17 and reallocated, at the same amount of the
immediate claim, to the sector and country of the seller
of the credit derivative in Columns 18 through 22 of
Schedule C, Part I, and in Columns 1 through 10 of
Schedule C, Part II. The excess or residual amount (the
full notional amount minus the amount risktransferred) should be reported in Column 3 of Schedule O (and in Column 5, if appropriate).
Contracts with a positive fair value should be reported
on Schedule D. For contracts with variable notional
principal amounts, report the notional principal
amounts as-of the report date.
2. Treatment of Multi-Name Credit Derivatives
Purchases and sales of credit derivatives guaranteeing
multiple underlying reference entities (i.e., multi-name
instruments, including portfolio or basket credit
default swaps (CDS), CDS indexes, and “tranched”
CDS contracts) should be reported on the
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General Instructions
FFIEC 009. However, only non-tranche index and
single name CDS contracts may be used to risk transfer an immediate claim on Schedule C, Parts I and II.
Contracts purchased and sold which cannot be used
for risk transfer purposes as noted above are to be
reported in Columns 3 and 4 of Schedule O, according
to the country of residence of the underlying reference
entities. Do not report on Schedule O according to the
counterparty to the contract or the location of the
company that establishes the index.
(2) The contracts are with the same counterparty,
(3) The contracts are subject to a legally enforceable
master netting agreement.
Contracts that do not qualify to be netted should be
reported gross.
III. Specific Instructions for Allocating
Claims to the Rows
This report form contains rows for: (a) the United
States; (b) individual foreign countries; and (c) international or regional organizations. Subtotals for each
region (e.g., Total Europe, Total Asia) are to be
reported, in addition to the Total Foreign Countries
row which captures the sum of all data reported,
excluding the United States. Data should be allocated
to the rows as described below.
AF
T
Regardless of whether reported on Schedule C or
Schedule O, if the underlying basket is composed of
reference entities located in one country, report the full
notional amount of the contract opposite the country
of the reference entity. If the underlying basket is composed of several securities from several countries, the
underlying reference entities should be reported on a
pro-rata basis.
(1) There are offsetting purchased and sold positions on the same reference entity (on a legal
entity basis),
D
R
CDS tranches, and bespoke CDS such as Nth-todefault contracts, and similar credit derivative contracts, should be reported on Schedule O. For these
types of contracts, if the underlying reference entities
are domiciled in multiple countries and payments to
the protection buyer are not triggered by a credit event
in a particular reference entity, but are triggered by a
default past a predetermined threshold, the notional
value of the contract should be reported in the “Unallocated” row.
A. The United States
The “United States” is defined as the 50 states of the
United States, the District of Columbia, the Commonwealth of Puerto Rico, as well as U.S. territories and
possessions.3
3. Gross-Gross and Gross-Net Reporting
B. Foreign Countries
Purchases and sales of credit derivatives are reported
on a “gross-gross” and “gross-net” basis on Schedule O (excluding the portion included as a hedge on
Schedule C, Parts I and II) by country of the reference
entity. The residual notional amount of credit derivatives purchased to hedge a claim reported in Schedule C, Part I that is in excess of the underlying hedged
claim should be reported on Schedule O.
guarantor
A foreign country is any country other than the United
States as defined above. For claims reported on an
immediate-counterparty basis, report claims for the
corresponding country of legal residence (i.e., the
country of incorporation or charter, or, for a bank
branch, the country where the branch is licensed) of
the immediate counterparty. For claims reported on an
ultimate-risk basis, report claims in the row corresponding to the country of legal residence (i.e., the
country of incorporation or, for a bank branch, the
country where the parent bank is chartered) of the ultimate obligor. (See Section II.C for definitions of
immediate counterparty and ultimate obligor.)
The gross notional value of credit derivatives purchased and sold should be reported on Schedule O,
Columns 3 and 4, as appropriate.
Report in Columns 5 and 6, as appropriate, the net
position of credit derivative contracts included in Column 3 and 4 where netting may be done only when all
the following apply:
3. For purposes of the FFIEC 009 report, IBFs are considered a U.S.
entity.
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General Instructions
The “Unallocated” row of Schedule L should only be
used for negotiable securities issued by the reporter,
where the country of the holder is unknown on the
report as-of date. The “Unallocated” row of Schedule O should only be used for credit default contracts
such as guarantees provided by selling protection on
“tranched” credit default swaps in which the ultimate
obligors of the referenced credits do not all reside in
the same country and the complexity of the product
makes allocating the countries of the reference credits
on a pro-rata basis, as could be done with index products, an inaccurate measure of the likely geographic
distribution of the guarantee.
C. International and Regional
Organizations
Claims on international and regional organizations,
even if located in the United States, should be reported
opposite the appropriate region: (a) International;
(b) European; (c) Latin American; (d) Caribbean
(e) Asian; (f) African; or (g) Middle Eastern. The
“International” entry covers most organizations of a
global character, such as the International Monetary
Fund and the World Bank. The regional entries cover
organizations that are regional in scope such as the
European Coal and Steel Community (European), the
Inter-American Development Bank (Latin American)
or the Asian Development Bank (Asian).
AF
T
Exposures on NBFIs should be reported for the country where the institution is incorporated, or otherwise
chartered. Institutions such as hedge funds and Special
Purpose Vehicles (SPV) should be reported according
to the country of legal residence (country of incorporation) of the fund/vehicle, not according to the loca-
tion of the fund managers or beneficial owners of the
fund/vehicle.
D
R
All international and regional institutions are considered to be “public” sector organizations.
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SPECIFIC INSTRUCTIONS FOR PREPARATION OF
Claims
Schedule C
The claims that are reflected in Column 12
should be included in the total claims reported in
Columns 1 and 2 of the FFIEC 009a.
IV. Specific Instructions for Schedule C,
Part I—Claims on an Immediate Risk
- Counterparty
Basis
All data in Columns 1 through 12 should be based only
upon the immediate obligor; do not consider any guarantees or other risk transfers.
Claims by Sector
Claims on Local Residents in the Local
Currency
AF
T
A. Immediate-Counterparty Claims
(Columns 1 through 12)
Debt securities held for trading should be reported as
maturing in less than one year. All other debt securities
should be reported according to the remaining
maturity.
D
R
In Columns 1 through 5 report all cross-border claims,
as defined in Section II.E.1, denominated in any
currency.
In Columns 6 through 10 report all claims on local residents in currencies other than the official currency of
the country in which the local office exists, as defined
in Sections II.E.2 and II.E.3.
In Column 12, report all claims on local residents in the
official currency of the country in which the local office
exists (see Sections II.E.2 and II.E.3).
All claims on residents of another country and claims
in a non-local currency on residents of the same country as the office holding the claim should be reported in
Columns 1 through 10 and excluded from this column.
Examples for Columns 1 through 12 only:
(1) The London branch of the respondent has a
claim of $10 million, denominated in Brazilian
reais, and another claim of $20 million, denominated in U.S. dollars, on a bank located in Brazil.
The claims mature in 8 months. Entries would be:
For Columns 1 through 12, allocate the claims to each
sector (see Section II.D) and each country row (see
Section III) based upon the country of residence and
sector of the direct obligor.
Part I
Brazil
Remaining Maturity of One Year or Less
In Column 11, show all claims reported in Columns 1
through 10 that have a remaining contractual maturity
of one year or less except as described below. The definition of “one year” should be consistent with the definition used in the FFIEC 031 and the FR Y-9C.
Marketable equity investments, both trading and
available-for-sale, should be reported as maturing in
less than one year.
Column 1 Banks
Column 11 Rem Maturity
30
30
(2) The Brazilian branch of the respondent has a
claim worth $10 million, denominated in a currency other than reais, on a bank located in Brazil. Entries would be:
Part I
Col. 6 - Banks
Brazil
10
C-1
FFIEC 009
March 2019
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Schedule C
In Column 17, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 5, 10 and 12 from households located in
that country.
(3) The Brazilian branch of the respondent issued a
loan worth $10 million, denominated in Brazilian
reais, to a bank located in Brazil. Entries
would be:
Part I
Brazil
2. Inward Risk Transfers
Column 6 Banks
Column 12 Cl Lcl Cur
---
10
Report in Columns 18 through 22 required risk transfers as defined in Section II.F by country and sector of
the ultimate obligor—i.e., of the guarantor or issuer/
holder of collateral.
claims with guarantors in other sectors
and jurisdictions
In Column 18, show, for each country row, all required
risk transfers of claims reported in Columns 13
through 17 to banks located in that country.
B. Redistribution of Claims for Required
Risk Transfers (Columns 13 through 22)
In Column 19, show, for each country row, all required
transfers of claimsreported in Columns 13 through
17 to the public sector located in that country.
The sum of the outward required risk transfers (in Columns 13 through 17) on a grand-total basis should
equal the sum of the inward required risk transfers (in
Columns 18 through 22), because all transfers from a
sector or country must also be transfers to another sector or country.
In Column 21, show, for each country, all required
transfers of claims reported in Columns 13 through
17 to non-financial corporations located in that
country.
AF
T
Redistribute all claims subject to a required risk transfer (see Sections II.F and II.H) from the sector and
country of the immediate counterparty and to the sector and country of the ultimate obligor. Show the
required risk transfers between different countries or
between different sectors in the same country. Exclude
risk transfers within the same country and sector.
D
R
In Column 20, show, for each country row, all required
transfers of claims reported in Columns 13 through
17 to NBFIs located in that country.
In Column 22, show, for each country, all required
transfers of claims reported in Columns 13 through
17 to individuals located in that country.
1. Outward Risk Transfers
In Column 13, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 1, 6, and 12 from banks located in that
country.
V. Specific Instructions for Schedule C,
Part II—Claims on an Ultimate Risk
Basis and Memorandum Items
Guarantor
Guarantor Basis
In Column 14, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 2, 7, and 12 from the public sector located
in that country.
In Column 15, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 3, 8, and 12 from NBFIs located in that
country.
guarantor
In Column 16, show (as a positive number), for each
country, all required risk transfers of claims reported
in Columns 4, 9 and 12 from non-financial corporations located in that country.
A. Ultimate-Risk Claims (Columns 1
through 11)
1. Cross-border Claims
In Columns 1 through 5, report all claims that, on an
ultimate-risk basis, are cross-border claims, i.e., claims
for which the ultimate obligor, after required risk transfers, is a resident of a country other than the country of
the office that holds the claim.
The claims should be allocated to each column based
upon the sector of the ultimate obligor (see Section II.C)
C-2
March 2019
December 2022
FFIEC 009
37
Schedule C
and to each row based upon the country in which the
ultimate obligor is located (see Section III).
2. Claims on Local Residents
In Columns 6 through 10, report all claims that, on an
ultimate-risk basis, are claims on local residents, i.e.,
claims for which the ultimate obligor, after required
risk transfers, is a resident of the country in which the
reporter’s office is located.
The claims should be allocated to each column based
upon the sector of the ultimate obligor and to each row
based upon the country in which the ultimate obligor is
located.
In Column 14, report, by country of the counterparty,
claims (regardless of whether cross-border or on local
residents, or currency denomination) where cash collateral was provided and held as part of a securities
lending arrangement or other similar financing
agreement.
In Column 15, report claims held where the country of
the ultimate obligor (i.e., the issuer of the collateral or,
for cash collateral, the legal entity where the cash is
held, which is the legal entity with the liability for the
cash collateral) is the same as the country of the immediate counterparty. Also include in this column claims
where collateral was provided as part of a resale or
securities lending agreement where the country of
issuer of the collateral is the same as the country of the
counterparty to the agreement. If multiple securities
are provided as collateral, only include in Column 15
the amount attributable to the same country.
AF
T
3. Claims on Local Residents in Non-Local
Currencies
In Column 11, show all claims reported in Columns 6
through 10 that are claims in currencies other than the
official currency (see Section II.E.3) of the country in
which the office is located.
B. Memorandum Items for Schedule C,
Part II
D
R
guarantor
agreements, securities lending arrangements and other
similar financing agreements. Reverse repurchase
agreements and securities borrowed may be reported
net, consistent with ASC Topic 210-20. Also include
any other collateralized claims that do not result in a
risk transfer of claims. Collateral in the form of real
estate should be excluded from this report.
1. Securities (HTM and AFS) (Column 12)
Report in Column 12, by country of issuer, securities
the reporter owns and reports in Columns 1 through 10
of Schedule C, Part II, that are classified as held-tomaturity or available-for-sale. Held-to-maturity securities should be reported at amortized cost and availablefor-sale securities should be reported at fair value.
2. Collateral Held Against Claims with No Risk
Transfers (Columns 13 through 16) 18
In Columns
18 of
C, PartC,
II,Part
reportII,claims
In
Column13
13through
through
16Schedule
of Schedule
includedclaims
in Columns
1 through
10 of Schedule
C, Part10
II, of
that
report
included
in Columns
1 through
are not subject
to risk
and for
the obligor
Schedule
C, Part
II,transfer
for which
thewhich
obligor
provided
provided collateral
didmeet
not meet
the definitionofofcollateral
collateral
collateral
that didthat
not
the definition
for the risk-transfers of claims (See Section II.F)
for the risk-transfers of claims (See Section II.F). See
Section V.C “Examples for Schedule C, Parts I and II.”
In Column 13, report total claims, by country of the
counterparty, included in Columns 1 through 10 of
Schedule C, Part II, for which the obligor provided
collateral that did not meet the definition of collateral
for the risk-transfers of claims, namely through resale
FFIEC 009
In
16,16,
report
claims
where of
thethe
country
of the ultimate
InColumn
Column
report
byheld
country
counterparty,
obligor
(i.e.,
the
issuer
of
the
collateral,
or
for
cash
collateral,
claims reported in Columns 1 through 10 of Sched- the
legal entity where the cash is held, which is the legal entity with the
ule C, Part II, that arise from resale agreements, securiliability for the cash collateral) is the U.S. Also include in this
ties lending transaction, or similar financing agreecolumn claims where U.S.-issued collateral was provided as part of
These
claims
should
be reported
both
on an are
aments.
resale or
securities
lending
agreement.
If multiple
securities
immediate
and
ultimate
risk
basis,
based
on
the
counprovided as collateral, only include in Column 16 the amount
terparty, not
theU.S.
underlying
collateral
(see
Section
II.F.5).
attributable
to the
18
Columns 14 through 16 are not mutually exclusive (i.e.,
the same claim may be reported in more than one of
these columns). If the value of the collateral exceeds
that of the underlying claim, report the amount of the
claim in Columns 13 through 16. If the claim is partially collateralized, only report the amount of the
claim that is collateralized.
18
19
3. Trading Assets (Columns 17 and 18)
19 and 20
In Column 17, report the fair value of the reporter’s
trading account assets that are included in Columns 1
through 10 of Schedule C, Part II. Exclude from this
column derivative claims, as these should be reported
on Schedule D. “CUSIP netting” is permissible if the
In both Columns 17 and 18 report claims reported in Columns 1 through 10 of Schedule C, Part II, that arise
from resale agreements, securities lending transactions, or similar financing agreements. These claims
C-3
should be reported on a guarantor basis. In Column 17, claims should be reported based on the country of the September 2016
counterparty, and in Column 18, claims should be reported based on the issuing country of the collateral. Do December 2022
not report claims secured by cash collateral in columns 17 and 18. The sum total of column 17 should equal
38
the sum total of column 18.
Schedule C
20
In addition, for each instrument type for each issuer, if
the short position in Column 18 exceeds the long positions in Column 17, report only up to the amount of
the long position reported in Column 17.
19
19
position was reported net on Schedule C, Part II, Columns 1 through 10. 20
In Column 18, report short positions in securities that
have the same issuer (on a legal entity basis) and broad
instrument type (i.e., debt versus debt and equity versus equity), as the long positions reported in Column 17.
19
C. Examples for Schedule C, Part II
(1) The respondent’s offices located outside of Hong Kong and Japan have $50 million in claims, denominated in
U.S. dollars, on a private manufacturer in Hong Kong that are guaranteed by a bank located in Japan. Entries
would be:
Part I
Hong Kong
Japan
Col. 16 - Outw
Corp
Col. 18 - Inw
Banks
Col. 1 - Banks
Col. 4 - Corp
50
---
--50
--50
-----
AF
T
Col. 4 - Corp
Part II
50
---
(2) The respondent’s offices in Japan have $50 million in claims, denominated in Hong Kong dollars, on a securities company in Hong Kong that are guaranteed by a bank located in Japan. Entries would be:
Part I
Hong Kong
Japan
Col. 15 - Cl on
NBFIs
Col. 18 - Cl on
Banks
Col. 1 - Banks
Col. 6 - Banks
Col. 11 - Cl NonLcl Curr
50
---
--50
-----
--50
--50
D
R
Col. 3 - NBFIs
Part II
50
---
(3) The reporter’s U.S. branch parent bank issues a $75 million loan (held for investment) to a construction company incorporated in Japan. The loan is denominated in Japanese yen. As collateral, the Japanese company
posts $50 million in Japanese government debt. Entries would be:
Part I
Part II
Col. 4 - Corp
Col. 16 - Outw
Corp
Col. 19 - Inw Public
Col. 2 - Public
Col. 4 - Corp
75
50
50
50
25
Japan
(4) The respondent’s offices located outside of Denmark and Greece have a total of $100 million in claims, all
denominated in U.S. dollars, on residents of Denmark, $70 million on banks, $20 million on public sector entities and $10 million on households. Of the claims on banks, $20 million is guaranteed (legally binding) by the
counterparties’ parent bank located in Greece. Entries would be:
Part I
Denmark
Greece
Part II
Col. 1 Banks
Col. 2 Public
Col. 5 Households
Col. 13 Outw
Banks
Col. 18 Inw Banks
Col. 1 Banks
Col. 2 Public
Col. 5 Households
70
--
20
--
10
--
20
--
-20
50
20
20
--
10
--
C-4
March 2019
FFIEC 009
December 2022
39
Schedule C
(5) The respondent’s offices located outside of the Bahamas and the United States have $10 million in claims, not
denominated in Bahamian dollars, on the Nassau, Bahamas branch of a U.S. bank. Entries would be:
Part I
Bahamas
United States
Part II
Col. 1 - Banks
Col. 13 - Outw Banks
Col. 18 - Inw Banks
Col. 1 - Banks
10
---
10
---
--10
--10
(6) The respondent’s office in Spain has $10 million in claims, not denominated in euros, on a manufacturing company in Spain, guaranteed by a bank located in Denmark. Entries would be:
Part I
Spain
Denmark
Col. 16 - Outw
Corp
Col. 18 - Inw
Banks
Col. 1 - Banks
Col. 9 - Corp
--10
-----
AF
T
Col. 9 - Corp
Part II
10
---
10
---
--10
(7) The respondent’s U.S. office has a $10 million claim, denominated in U.S. dollars, on a U.S. bank that has a
parent in the United Kingdom. The parent provides a legally binding guarantee of payment. Entries would be:
Part I
Col. 12 - Cl Lcl Cur
Col. 13 - Outw Banks
Col. 18 - Inw Banks
Col. 1 - Banks
--10
--10
10
---
10
---
D
R
United Kingdom
United States
Part II
(8) The respondent’s Italian office has a $10 million claim, not denominated in euros, on a U.S. branch of an Italian bank. Entries would be:
Part I
Italy
United States
Part II
Col. 1 - Banks
Col. 13 - Outw
Banks
Col. 18 - Inw
Banks
Col. 6 - Banks
Col. 11 - Cl Non-Lcl
Curr
--10
--10
10
---
10
---
10
---
(9) The respondent’s U.S. office has a $10 million claim, denominated in euros, on a household in France that is
fully guaranteed by collateral in the form of securities issued by a French bank. Entries would be:
Part I
France
Part II
Col. 5 - Households
Col. 17 - Outw Households
Col. 18 - Inw Banks
Col. 1 - Banks
10
10
10
10
C-5
FFIEC 009
March 2019
40
Schedule C
(10) The respondent’s Hong Kong office has a $10 million claim, denominated in Hong Kong dollars, on a bank in
Hong Kong that is a wholly-owned subsidiary of a Japanese bank. There is no legally-binding guarantee.
Entries would be:
Part I
Part II
Col. 12 - Cl Lcl Cur
Col. 13 - Outw Banks
Col. 18 - Inw Banks
Col. 6 - Banks
10
---
-----
-----
10
---
Hong Kong
Japan
(11) The respondent’s U.S. office has a $10 million claim, denominated in U.S. dollars, on a U.S. manufacturing
company that is guaranteed by a U.K. bank. Entries would be:
Part I
Part II
Col. 16 - Outw Corp
Col. 18 - Inw Banks
Col. 1 - Banks
--10
--10
10
---
10
---
United Kingdom
United States
AF
T
Col. 12 - Cl Lcl Cur
(12) The Brazilian branch of the respondent has a $10 million claim, not denominated in reais, on a Brazilian
manufacturer guaranteed by the United States Export-Import Bank. Entries would be:
Part I
Col. 9 - Corp
Col. 16 - Outw Corp
Col. 19 - Inw Public
Col. 2 - Public
10
---
10
---
--10
--10
D
R
Brazil
United States
Part II
(13) The Brazilian branch of the respondent has issued loans for $50 million, denominated in Brazilian reais, to a
Brazilian non-banking subsidiary of a Belgian financial services company. The counterparty’s parent provides
a legally binding guarantee for only $20 million of the claims. Entries would be:
Part I
Brazil
Belgium
Part II
Col. 12 - Cl Lcl
Cur
Col. 15 - Outw
NBFIs
Col. 20 - Inw
NBFIs
Col. 3 - NBFIs
Col. 8 - NBFIs
Col. 11 - Cl NonLcl Cur
50
---
20
---
--20
--20
30
---
-----
(14) The reporter’s Cayman Islands branch enters into an overnight reverse repurchase agreement (for $50 million,
denominated in U.S. dollars) with an NBFI domiciled in the U.K. The underlying collateral is U.K. corporate
debt securities. Entries would be:
Part I
United Kingdom
Part II
Col. 3 - NBFIs
Col. 11 - Rem
Maturity
Col. 3 - NBFIs
Col. 13 - Total
Coll
Col. 15 - Same
Country
Col. 16 - Resale
& Sec Lend
50
50
50
50
50
50
Insert A
C-6
March 2019
December 2022
FFIEC 009
41
INSERT A
(14) The reporter’s Cayman Islands branch enters into an overnight reverse repurchase agreement (for
$50 million, denominated in U.S. dollars) with an NBFI domiciled in the U.K. The underlying
collateral is U.K. corporate debt securities. Entries would be:
Part I
Part II
Col. 3 - NBFIs
Col. 11 - Rem
Maturity
Col. 3 - NBFIs
Col. 13 - Total
Coll
Col. 15 - Same
Country
Col. 17 - Resale
& Sec Lend
Col. 18 - Resale
& Sec.
Lending
(Country of
collateral)
50
50
50
50
50
50
50
United Kingdom
Part I
United Kingdom
AF
T
(15) The reporter’s Cayman Islands branch enters into an overnight reverse repurchase agreement (for
$50 million, denominated in U.S. dollars) with an NBFI domiciled in the U.K. The underlying
collateral is $25 million in U.K. corporate debt securities and $25 million in U.S. Treasuries.
Entries would be:
Part II
Col. 3 NBFIs
Col. 11 - Rem.
Maturity
Col. 3 NBFIs
Col. 13 Total
Collateral
Col. 15 Same
Country
Col. 16 U.S.
Col. 17 - Resale
& Sec. Lending
(Country of
counterparty)
Col. 18 - Resale
& Sec. Lending
(Country of
collateral)
50
50
50
50
25
25
50
25
25
D
R
United States
(16) The reporter enters into a securities lending transaction (for $100 million, denominated in U.S.
dollars) with an NBFI domiciled in the Cayman Islands. The underlying collateral is $25 million
in Singaporean corporate debt securities and $75 million in Japanese corporate debt securities.
Entries would be:
Part I
Cayman Islands
Part II
Col. 3 NBFIs
Col. 11 Rem.
Maturity
Col. 3 NBFIs
Col. 13 Total
Collateral
100
100
100
100
Col. 15 Same
Country
Col. 16 U.S.
Col. 17 Resale & Sec.
Lending
(Country of
counterparty)
Col. 18 Resale &
Sec. Lending
(Country of
collateral)
100
Singapore
25
Japan
75
December
422022
Schedule C
(17) (15) The respondent’s U.S. office has a $20 million claim, denominated in U.S. dollars, on a Malaysian financial
services company. The respondent purchased credit protection from a German bank against the risk of default
by the Malaysian obligor through a credit derivative. The credit derivative has a notional value of $20 million.
The arrangement is considered an effective risk transfer based on the respondent’s internal criteria. Entries
would be:
Part I
Part II
Col. 3 - NBFIs
Col. 15 - Outw NBFIs
Col. 18 - Inw Banks
Col. 1 - Banks
20
---
20
---
--20
--20
Malaysia
Germany
AF
T
(18) (16) The respondent’s U.S. office has a $20 million claim, denominated in Brazilian reais, on a Brazilian financial
company. The respondent purchased credit protection from a German bank against the risk of default by the
Brazilian financial company through a credit derivative. The credit derivative has a notional value of $30 million, exceeding the value of a guaranteed claim. The arrangement is considered an effective risk transfer based
on the respondent’s internal criteria. Entries would be:
Part I
Part II
Col. 3 - NBFIs
Col. 15 - Outw NBFIs
Col. 18 - Inw Banks
Col. 1 - Banks
20
---
20
---
--20
--20
Brazil
Germany
D
R
In addition, the excess $10 million (the difference between the $30 million notional amount and the $20 million
underlying claim) should be reported on Schedule O, Column 3, and, if appropriate after netting, in Column 5
against Germany.
19 and 20)
Note regarding Schedule D (applies to examples 15 and 16):
If the credit derivative has a positive fair value of $2 million, the positive fair value would be reported in Schedule D in the country row of the country of residence of the counterparty to the credit derivative contract.
Entries would be:
Schedule D
Germany
Col. 1 - Banks
Col. 5 - Total
2
2
(19) (17) The respondent’s Japanese office has a $100 million claim, denominated in Korean Won, on a Korean branch
of a Hong Kong bank. The Korean obligor provides $60 million in Japanese government bonds as collateral.
Entries would be:
Part I
Hong Kong
Korea
Japan
Part II
Col. 1 - Banks
Col. 13 - Outw
Banks
Col. 18 - Inw
Banks
Col. 19 - Inw
Public
Col. 1 - Banks
Col. 7 - Public
--100
---
--100
---
40
-----
----60
40
-----
----60
C-7
FFIEC 009
March 2019
December 2022
43
Schedule C
Insert B
(20) (18) The respondent’s German office engages in an overnight resale agreement with a hedge fund located in the
Cayman Islands for $50 million, denominated in U.S. dollars. $50 million in cash is exchanged for $52 million
in U.K. government securities. Entries would be:
Part I
Part II
Col. 3 - NBFIs
Col. 11 - Rem
Maturity
Col. 3 - NBFIs
Col. 13 - Total Coll
Col. 16 - Resale &
Sec Lend
50
50
50
50
50
Cayman Islands
(21) (19) The reporter’s branch in Brazil issues a mortgage for a private residence to an individual, also in Brazil. The
mortgage is for $2 million (denominated in Brazilian reais) and is secured by the residence. Entries would be:
Part I
Part II
Col. 12 - Cl Lcl Cur
Col. 10 - Households
2
2
AF
T
Brazil
Collateral in the form of real-estate is not considered eligible collateral (see Section II.F.5) for the purposes of
the FFIEC 009 and would not result in a risk transfer or be included as “Collateral Held Against Claims with
No Risk Transfer.”
D
R
(22) (20) The reporter’s Cayman Islands branch issues a (short-term) margin loan to an insurance company domiciled
in Switzerland. The loan is for $50 million (denominated in euros). For collateral, the insurance company posts
$10 million in cash (denominated in euros) that is held at a bank domiciled in Switzerland and $25 million in
German government debt (denominated in euros). Entries would be:
Part I
Switzerland
Germany
Part II
Col. 3 NBFIs
Col. 11 Rem
Maturity
Col. 15 Outw
NBFIs
Col. 18 Inw Banks
Col. 19 Inw Public
Col. 1 Banks
Col. 2 Public
Col. 3 NBFIs
50
--
50
--
35
--
10
--
-25
10
--
-25
15
--
(23) (21) The reporter’s Cayman Islands branch issues a (short-term) margin loan to a bank domiciled in the Bahamas.
The loan is for $50 million (denominated in euros). For collateral, $20 million in cash (denominated in euros) is
posted to a third-party bank domiciled in the Bahamas. Entries would be:
Part I
Bahamas
Part II
Col. 1 - Banks
Col. 11 - Rem Maturity
Col. 1 - Banks
50
50
50
C-8
March 2019
December 2022
FFIEC 009
44
Insert B
(20) The respondent’s German office engages in an overnight resale agreement with a hedge fund located in
the Cayman Islands for $50 million, denominated in U.S. dollars. $50 million in cash is exchanged for $52
million in U.K. government securities. Entries would be:
Part II
Part I
Cayman Islands
Col. 3 - NBFIs
Col. 11 - Rem
Maturity
Col. 3 - NBFIs
Col. 13 - Total
Coll
Col. 17 - Resale
& Sec Lend
50
50
50
50
50
50
D
R
AF
T
United Kingdom
Col. 18 - Resale
& Sec.
Lending
(Country of
collateral)
December 2022
45
Schedule C
(24) (22) The reporter’s U.K. office makes a short-term margin loan to a non-bank financial services client domiciled in
Germany for $50 million (denominated in euros). The client posts $55 million in U.K. government debt as collateral. Entries would be:
Part I
Col. 3 - NBFIs
Col. 11 - Rem
Maturity
Col. 15 - Outw
NBFIs
Col. 19 - Inw Public
Col. 7 - Public
50
---
50
---
50
---
--50
--50
D
R
AF
T
Germany
United Kingdom
Part II
C-9
FFIEC 009
March 2019
December 2022
46
SPECIFIC INSTRUCTIONS FOR PREPARATION OF
Foreign-Office Liabilities
Schedule L
A. Foreign-Office Liabilities by Country
of Foreign Office (Columns 1 and 2)
Short sales by a foreign office should be reported in
Column 3 opposite the country of the issuer of the
financial instrument that has been sold short until the
settlement date. For the September 30, 2019, and the
December 31, 2019, report dates, reporting entities
may report short sales by a foreign office using either
the short sale instructions as they have been revised as
of September 30, 2019, or the previously existing short
sale instructions.
AF
T
Report in Columns 1 and 2, the liabilities of the reporter’s foreign offices by country of each foreign office that
represent liabilities of the foreign offices to all creditors, regardless of location, for which no payment is
guaranteed at locations outside the country of the
office. Deposits of a foreign branch are assumed to be
the liabilities of the foreign branch, unless they are
explicitly redeemable outside the country in which the
branch is located. Exclude the negative fair value of
derivative contracts.
should be reported. Exclude the negative fair value of
derivative contracts.
D
R
In Column 1, report foreign-office liabilities that are in
a currency other than one which the country’s government has authority to issue. (See Section II.E.)
In Column 2, report foreign-office liabilities that are in
a currency which the country’s government has
authority to issue. (See Section II.E.)
B. Foreign-Office Liabilities by Country
of Creditor (Column 3)
Column 3—total liabilities booked at foreign
offices—is required to be reported only by those
reporters meeting certain conditions described in Section I.D of these instructions.
In Column 3, report by country of the creditor, all
liabilities that are booked at any of the reporter’s foreign offices, regardless of the currency and regardless
of whether payment is guaranteed at locations outside
the country of the office. Liabilities in Column 3
should be reported against the country where the counterparty is located (i.e., on an immediate-counterparty
basis) and not the location of the parent of the creditor. Liabilities to creditors located in the United States
If the country of the creditor cannot be determined—
because the customer was not known to the bank (as
would be the case with negotiable certificates of
deposit)—then these liabilities should be reported in
the “Unallocated” row.
In any row and on a grand-total basis, the amount in
Column 3 (which is by country of creditor) may not
equal the sum of amounts in Column 1 and 2 (which
are by country of foreign office).
C. Net Due To (or Due From) Own
Related Offices in Other Countries
(Column 4)
Report for each country in which the reporter has an
office or offices, that office’s (or those offices’) net
liabilities to (or claims on) all other offices of the
respondent that are located in other countries, including offices in the United States (e.g., the net amount a
German branch has “due to” or “due from” the head
office and all other consolidated non-German offices
of the parent). Only a single net figure should be
reported for all the offices of the reporter in a given
country. If the offices in a given country taken together
have a net “due to” position with all related offices in
all other countries combined, a positive figure should
L-1
FFIEC 009
September 2019
47
Schedule L
be reported; a net “due from” position should be indicated by a negative sign.
balance sheet items (e.g., loans, borrowings, derivative
contracts).
For the purposes of this report, the computation of net
due to or due from should include unremitted profits
and capital contribution accounts of branch offices
and the equity investment in consolidated subsidiaries.
Include all claims and liabilities that are reflected as
The amounts reported in Column 4 represent the internal position of offices within the consolidated bank or
the consolidated holding company. They are, therefore,
not reflected in any other columns of the report.
D. Examples for Schedule L
(1) The reporter’s branch located in the U.K. holds $10 million in interest-bearing deposits placed by a non-bank
financial company located in the U.K. (denominated in GBP). The funds are not payable outside the U.K.
Entries would be:
United Kingdom
AF
T
Schedule L
Col. 2 FO Liab Non-Lcl Cur
Col. 3 Total Liab at FO
10
10
(2) The reporter’s parent bank takes out a loan directly from a third-party bank domiciled in Japan. The amount
of the loan is $5 million and is denominated in U.S. dollars. Entries would be:
D
R
None. Only liabilities incurred by the reporter’s offices located outside the U.S. should be reported in Columns
1 through 3 of Schedule L.
(3) The reporter’s branch located in the U.K. holds $100 million in deposits (denominated in euros) placed by a
U.K. branch of a German bank. The funds are payable anywhere the reporter has an office. Entries would be:
Schedule L
Col. 3 Total Liab at FO
United Kingdom
100
Since the deposits are payable outside the country of the office, there are no foreign-office liabilities to report in
Columns 1 and 2 of Schedule L. However, the deposit should be reported in Column 3 against the country
where the (immediate) counterparty is located, regardless of whether payment can be made at locations outside
the country of the office (see Section VI.B).
(4) The reporter’s German securities broker subsidiary has a trade date payable for the purchase of $25 million of
U.K. sovereign debt, denominated in GBP, with an insurance company counterparty located in Switzerland.
Entries would be:
Schedule L
Germany
Switzerland
Col. 1 FO Liab Lcl Cur
Col. 3 Total Liab at FO
25
---
--25
L-2
March 2019
FFIEC 009
48
Schedule L
(5) The reporter’s Cayman Islands branch enters into a repurchase agreement for $2 million (denominated in U.S.
dollars) with a hedge fund counterparty located in the Bahamas. Entries would be:
Schedule L
Col. 1 FO Liab Lcl Cur
Col. 3 Total Liab at FO
2
---
--2
Cayman Islands
Bahamas
(6) The reporter’s U.K. branch enters into a securities lending arrangement (U.K. government securities were lent)
for $5 million (denominated in GBP) with a pension fund domiciled in the Netherlands. Entries would be:
Schedule L
Col. 3 Total Liab at FO
5
---
--5
AF
T
United Kingdom
Netherlands
Col. 2 Liab Non-Lcl Cur
(7) The reporter’s U.K. branch sold a put option on a German manufacturer’s equity securities. The counterparty
is a non-bank financial institution domiciled in Luxembourg. The notional value of the derivative is $100 million and has a negative fair value of $2 million, denominated in U.S. dollars. Entries would be:
D
R
No entries. Liabilities from derivative contracts are not reported on Schedule L of the FFIEC009 report.
(8) The reporter’s U.K. broker/dealer subsidiary receives an intracompany loan from the Cayman branch of the
reporter (for $10 million, denominated in euros). In addition, the U.K. branch of the reporter placed deposits
of $4 million (denominated in U.S. dollars) with the reporter. Entries would be:
Schedule L
Col. 4 Net Due to Own Rel Off
United Kingdom
Cayman Islands
United States
Grand Total
6
(10)
4
0
The U.K. offices have a combined net due to position of $6 million ($10 million due to the Cayman Islands and
a $4 million due from the U.S.). See Section VI.C.
(9) The reporter’s security subsidiary located in Germany sells short $20 million in U.K. government debt it does
not own to a fund manager domiciled in Luxembourg. Assume the settlement date is the day after the
FFIEC 009 report as-of date. Entries would be:
Schedule L
Germany
United Kingdom
Col. 1 FO Liab Lcl Cur
Col. 3 Total Liab at FO
20
---
--20
L-3
FFIEC 009
September 2019
49
Schedule L
D
R
AF
T
“Short sales” are to be reported opposite the country of the office entering into the short sale in Columns 1
and 2 (in this example, Germany), and in Column 3 opposite the country of the issuer of the securities that
have been sold short (in this example, the U.K.). Do not report according to the country of the counterparty to
whom delivery is owed. (See the instructions for reporting short sales on page L-1 for information on reporting
as of September 30, 2019, and December 31, 2019.)
L-4
September 2019
FFIEC 009
50
SPECIFIC INSTRUCTIONS FOR PREPARATION OF
Off-Balance-Sheet Items
Schedule O
A. Unused Commitments (Column 1)
Commitments of U.S. and foreign offices to local residents should be included.
B. Guarantees (Excluding Credit
Derivatives Sold) (Column 2)
guarantor
AF
T
guarantor
In Column 1, report, on an “ultimate-risk” basis (i.e.,
after risk transfers due to head offices of bank
branches or credit protection provided by third parties), the unused portions of all outstanding crossborder and local office commitments to provide credit,
by country of residence of the ultimate obligor if the
commitment were to be drawn. Include the unused
portion of all outstanding letters of credit and
amounts outstanding of purchases of risk
participations.
D
R
The definition of commitments is identical to that used
for Schedule HC-L of the FR Y-9C.
Exclude “best efforts” letters and letters in which the
pricing is indicative and not determined until launch
date, or for which the banking institution has no commitment to buy the assets for its own account. Exclude
cross- border commitments (such as those under commercial letters of credit) that can be cancelled, at the
option of the reporter, upon the occurrence of a sovereign event. Also exclude financial and performance
standby letters of credit. (Outstanding and unused
financial and performance standby letters of credit
should be reported as guarantees in Column 2.)
In cases of commitments for syndicated loans, the lead
underwriter should report only the underwriter’s proportional share of the unused commitment. Similarly,
contractual underwriting commitments (e.g., revolving
underwriting facilities) and other underwriting agreements may be shown net of firm commitments from
other parties to purchase the assets without recourse
within a short and specific period of time. Accordingly,
the reporter should also include its unused obligations
to participate in syndicated loans and underwritings
managed by other institutions.
In Column 2, report, on an ultimate-risk basis, all
legally binding guarantees and insurance contracts (see
Sections II.F.1 and II.F.2) issued by the reporter’s U.S.
or foreign offices, excluding credit derivatives sold. Do
not include guarantees which provide protection only
between consolidated units of the reporter. Include the
full amount of outstanding and unused financial and
performance standby letters of credit in Column 2.
Guarantees and insurance contracts of foreign offices
to local residents should also be included.
C. Credit Derivatives Purchased and Sold
(Columns 3 through 6)
Report in Columns 3 through 6, by country of the
underlying reference entity, the notional value of all
outstanding credit derivatives sold and of those credit
derivatives purchased that are not reported as a risk
transfer in Schedule C, Parts 1 and II (see Section II.H.1).
Credit protection purchased to hedge/offset credit protection sold, or for speculative purposes, should be
excluded as a risk transfer from Schedule C, Parts I and
II, and reported in Columns 3 and 5 of Schedule O, as
appropriate.
1. Gross-Gross (Columns 3 and 4)
Report in Columns 3 and 4 the gross notional value of
credit derivatives purchased and sold opposite the
country of the underlying reference entity.
O-1
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Schedule O
Report in Column 3, by country of the ultimate obligor of the reference credit, credit derivatives where the
reporter (or its consolidated offices) is a protection
purchaser (see Section II.H) and that were not used as
part of a risk transfer on Schedule C, Parts I and II.
Include in Column 3 any residual notional value of
credit derivatives purchased, in excess of the amount of
the underlying claim where the credit derivative was
used as part of a risk transfer on Schedule C, Parts I
and II.
(1) there are offsetting purchased and sold positions
on the same reference entity (on a legal entity
basis),
(2) the contracts are with the same counterparty,
(3) the contracts are subject to a legally enforceable
master netting agreement.
Contracts that do not meet all three conditions above
should be reported on a gross basis in Columns 5
and 6.
Report in Column 4, by country of the ultimate obligor of the reference credit, all credit derivatives where
the respondent is a protection seller (see Section II.H).
For example, if a reporter is a guarantor providing
credit risk protection to a U.K. bank for a claim on an
Argentine bank, by means of a credit derivative, the
reporter would report the notional amount in Column 4 in the row for Argentina.
D. Trade Finance (Column 7)
AF
T
2. Gross-Net (Columns 5 and 6)
In Column 7, report total extensions of credit with
maturities one year and under that are included in Columns 1 through 10 of Schedule C, Part II, or Columns
1 or 2 of Schedule O and that: (1) are directly related to
imports or exports and (2) will be liquidated through
the proceeds of international trade. Provided these two
conditions are met, such credit extensions may include
customers’ liability on acceptances outstanding, own
acceptances discounted, acceptances of other banks
purchased, pre-export financing where there is a firm
export sales order, commercial letters of credit, as well
as other loans and advances whenever such extensions
directly relate to international trade. Include credit
extensions for pre-export financing when there is a
firm export sales order and the proceeds of the order
will pay off indebtedness.
D
R
Report in Columns 5 and 6, as appropriate, the consolidated net position of credit derivative contracts
included in Column 3 and 4. Netting may be done only
when all the following apply:
E. Examples for Schedule O
(1) The respondent (through any office) issued a $10 million loan commitment, denominated in U.S. dollars, to a
manufacturing company located in Ireland. Entry would be:
Schedule O
Col. 1 - Unused Commitments
Ireland
10
(2) The respondent (through any office) has provided credit protection to a German bank, against the risk of
default by a French non-financial company through a credit derivative. The credit derivative has a notional
value of $10 million, denominated in euros. Entry would be:
Schedule O
France
Col. 4 - Gr - Gr Cred
Deriv Sold
Col. 6 - Gr - Net Cred
Deriv Sold
10
10
O-2
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FFIEC 009
52
Schedule O
Note regarding Schedule D:
If the credit derivative has a positive fair value of $1 million, the positive fair value would be reported in Schedule D in the country row of the country of residence of the counterparty to the credit derivative contract.
Entries would be:
Schedule D
Col. 1 - Banks
Col. 5 - Total
1
1
Germany
(3) The respondent’s U.S. office has provided a company in Brazil with a $20 million line of credit, denominated
in Brazilian reais, and has provided a bank in the United Kingdom with a $30 million (notional value) credit
derivative, denominated in GBP, based upon the credit of a German industrial company. Entries would be:
Schedule O
Note regarding Schedule D:
Col. 4 - Gr- Gr Cred
Deriv Sold
Col. 6 - Gr - Net Cred
Deriv Sold
20
-----
----30
----30
AF
T
Brazil
United Kingdom
Germany
Col. 1 - Unused
Comm
D
R
If the credit derivative has a negative fair value of $2 million, the fair value would not be reported on Schedule D.
(4) The Brazilian branch of the respondent has a loan commitment of $10 million, denominated in Brazilian reais,
to a Brazilian manufacturer. The United States Export-Import Bank has written a guarantee that would guarantee $7 million of the loan, should it be extended. Entries would be:
Schedule O
Col. 1 - Unused Comm
Brazil
United States
3
---
(5) The reporter purchases a CDS index (notional value of $150 million, denominated in U.S. dollars) with 15
equally-weighted reference entities, 5 in Germany, 5 in the U.K. and 5 in Japan. Assuming the reporter has no
other CDS contracts, entries would be:
Schedule O
Germany
United Kingdom
Japan
Col. 3 - Gr-Gr Cred
Deriv Purch
Col. 5 - Gr-Net Cred Deriv
Purch
50
50
50
50
50
50
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Schedule O
(6) The reporter enters into the following transactions with bank B (located in Germany) and bank C (located in
Spain). The reporter has legally enforceable master netting agreements with banks B and C and all contracts
are executed under the agreements as follows (all contracts denominated in U.S. dollars).
a. The reporter buys from bank B $100 million notional of CDS protection referencing sovereign debt issued
by Germany.
b. The reporter sells to bank B $90 million notional of CDS protection referencing sovereign debt issued by
Germany (different CUSIP from transaction 1).
c. The reporter buys from bank C $50 million of CDS protection referencing the debt of Company XYZ in
the U.K.
d. The reporter sells to bank C $70 million of CDS protection referencing the debt of Company XYZ in
the U.K.
AF
T
e. The reporter buys from bank C $30 million of CDS protection referencing sovereign debt issued by the
U.K. government.
These transactions would be reported as follows:
Col. 3 - Gr-Gr
Cred Deriv
Purch
Col. 4 - Gr- Gr
Cred Deriv Sold
Col. 5 - Gr-Net
Cred Deriv
Purch
Col. 6 - Gr - Net
Cred Deriv Sold
100
80
90
70
10
30
--20
D
R
Germany
United Kingdom
Schedule O
(7) The reporter enters into the following transactions with bank E (located in France), bank F (located in Germany) and a central counterparty located in the U.K. (Company G) as follows (all contracts denominated in
euros).
a. The reporter sells to bank E $50 million notional of CDS protection referencing the sovereign debt of
France and $100 million notional of CDS protection referencing corporate debt issued by Company ABC
domiciled in Ireland. The contracts are cleared through Company G.
b. The reporter purchases from bank F $30 million notional of CDS protection referencing the sovereign
debt of France. The contract is cleared through Company G.
These transactions would be reported as follows:
Schedule O
France
Ireland
Col. 3 - Gr-Gr
Cred Deriv
Purch
Col. 4 - Gr- Gr
Cred Deriv Sold
Col. 5 - Gr-Net
Cred Deriv
Purch
Col. 6 - Gr - Net
Cred Deriv Sold
30
---
50
100
-----
20
100
O-4
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FFIEC 009
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SPECIFIC INSTRUCTIONS FOR PREPARATION OF
Claims from Positions in Derivative
Contracts
Schedule D
transactions are executed under a legally enforceable
master netting agreement and the offsetting is in accordance with ASC Subtopics 815-10 and 210-20. For
derivative contracts executed under such a master netting agreement, only the net residual fair value, if positive, is reported in Schedule D according to the sector
and country of residence of the ultimate counterparty.
AF
T
Report by country of the counterparty, the positive
fair value of all derivative contracts. Positive fair values
can be offset against negative fair values if, and only if,
the transactions were executed with the same counterparty under a legally enforceable master netting agreement under ASC Subtopic 210-20, Balance Sheet—
Offsetting (formerly FASB Interpretation No. 39,
“Offsetting of Amounts Related to Certain Contracts”). When contracts are covered by master netting
agreements, the net residual amount, if positive, is
reported in the country of residence of the ultimate
counterparty.
guarantor
D
R
All claims reported on Schedule D are to be reported
on an ultimate-risk basis (see Section II.C). Therefore,
amounts that are guaranteed are reported in the sector
and country of the guarantor. Similarly, if cash collateral is held, amounts that are collateralized are
reported in the sector and country of the legal entity
where the cash collateral is held; when securities are
held as collateral, the exposure is reported in the sector
and country of the issuer of the securities (see Section II.F).
A. Positive Fair Value of Derivative
Contracts (Columns 1 through 5)
Report the positive fair value of derivative contracts by
sector (see Section II.D) in Columns 1 through 4, and
the total in Column 5. For Schedule D, sectors consist
of Banks, Public, NBFIs, and “Other.” “Other” consists of the residual claims which cannot be classified in
the other three categories.
Contracts not covered by a master netting agreement
must be reported gross.
The positive fair value of derivative contracts can be
offset against the negative fair value of derivative contracts and cash collateral held by the reporter if the
For contracts covered by a multi-branch or multijurisdiction master netting agreement, the net positive
residual amount (i.e., the larger of zero or the gross
positive fair value less the gross negative fair value of
those contracts covered by the same master netting
agreement) must be reported in Columns 1 through 4,
as appropriate, as well as in Column 5. (The term
multi-jurisdiction or multi-branch agreement refers to
a master netting agreement that covers the head office
and other offices of the reporter.)
For contracts covered by a single netting agreement (a
master netting agreement entered into by a single office
of the reporter with another party), the net positive
residual amount qualifies to be reported in Columns 1
through 5.
When a contract is entered into with a branch of a
commercial bank, a claim (i.e., positive fair value) is
reported in the country of the head office because
claims on a bank’s branches are assumed to have an
implicit credit guarantee of the head office. Claims on
(i.e., contracts having a positive fair value) U.S.
branches of foreign banks are reported in the country
of the head office. (Refer also to instructions for Column 6, which treats claims on bank branches
differently.)
B. Claims on Branches with No
Guarantee from Parent (Column 6)
In memorandum Column 6, reporters are asked to
identify claims on bank branches according to the
D-1
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Schedule D
country of residence of the branch in those instances in
which the claim is not formally and legally guaranteed
by the head office of the branch (and in which the
country of residence of the branch is different than the
country of residence of the head office). Amounts
reported in Column 6 are also reported in Columns 1
and 5 (although in Columns 1 and 5 they are reported
in the country row of the head office). If the claims on
a bank branch are formally and legally guaranteed by
the head office of the branch (or if the branch is
located in the same country as the head office) then the
claims are not reported in Column 6. Contracts covered by master netting agreements are deemed to carry
the legal guarantee of the head office and are therefore
not reported in Column 6.
C. Examples for Schedule D
Schedule D
Germany
United States
Col. 1 - Banks
Col. 5 - Total
Col. 6 - Cl With
No Guar
--100
--100
100
---
If parties to a multi-branch netting agreement specify
that transactions with branches in certain jurisdictions
are subject to transfer risk, any exposure in that jurisdiction is reported in memorandum Column 6 in order
to reflect the transfer risk in that location.
AF
T
For example, an unguaranteed claim on a branch of a
foreign bank would be reported in Columns 1 and 5 in
the country of the head office and in Column 6 in the
country of the branch.
For example, the German office of the respondent has
a contract with a positive fair value of $100 million
with the German branch of a U.S. bank.
D
R
(1) The reporter’s U.K. securities broker subsidiary has a portfolio of OTC derivative trades with a notional value
of $1 billion and a positive fair value of $150 million with the U.K. securities broker subsidiary of a bank
domiciled in Germany. The German bank posts $120 million in cash as collateral which is held by a thirdparty bank domiciled in the U.K. Assuming there is no master netting agreement in place, the entries
would be:
Schedule D
Germany
United Kingdom
Col. 1 - Banks
Col. 5 - Total
30
120
30
120
(2) The same fact pattern as Example 1, except the reporter and the German bank have a multi-jurisdiction master
netting agreement encompassing all the subsidiaries and branches of the two counterparties.
Schedule D
Germany
Col. 1 - Banks
Col. 5 - NBFIs
Col. 4 - Total
30
---
30
The amount in Column 1 against Germany represents the uncollateralized portion of the positive fair value
position against the parent bank under the master netting agreement. Because a master netting agreement is in
place, the positive fair value can be netted with the cash collateral.
(3) The reporter’s U.K. securities broker subsidiary has a foreign exchange swap contract with a notional value of
$500 billion and a positive fair value of $100 million with the Cayman Islands nonbank subsidiary of a bank
domiciled in the U.K. The reporter and the U.K. bank have a multi-jurisdiction master netting agreement
D-2
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FFIEC 009
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Schedule D
encompassing all the subsidiaries and branches of the two counterparties. For collateral, the Cayman Islands
subsidiary posts $50 million in U.K. sovereign debt and $20 million in cash as collateral which is held directly
by the reporter’s U.K. subsidiary. Entries would be:
Schedule D
Col. 1 - Banks
Col. 2 - Public
Col. 3 - NBFIs
Col. 5 - Total
30
50
---
80
United Kingdom
The amount in Column 2 represents the sovereign debt posted as collateral (collateral in the form of securities
are reported opposite the country and sector of the issuer). The amount in Column 1 represents the uncollateralized portion of the positive fair value position against the parent bank of the counterparty under the master
netting agreement. The cash collateral held by the reporter’s U.K. subsidiary is not reportable since a multijurisdiction master agreement is in place and the cash is held directly by the reporter.
Assume the following fact pattern for Examples 4 through 6:
Gross Positive
Fair Value
Gross Negative
Fair Value
Net by Location
15
45
60
120
11
75
40
126
4
-30
20
-6
-6
190
79
67
336
70
41
34
145
120
38
33
191
191
57
10
41
108
75
85
40
200
-18
-75
1
-92
-92
115
75
15
144
349
913
225
25
100
64
414
885
-110
50
-85
80
-65
-65
D
R
U.S. Bank - Hong Kong branch with:
Japan Bank - Hong Kong branch
Japan Bank - London branch
Japan Bank - Tokyo branch
Total
U.S. Bank - London branch with:
Japan Bank - Hong Kong branch
Japan Bank - London branch
Japan Bank - Tokyo branch
Total
U.S. Bank - New York branch with:
Japan Bank - London branch
Japan Bank - New York branch
Japan Bank - Tokyo branch
Total
U.S. Bank - Tokyo branch with:
Japan Bank - Hong Kong branch
Japan Bank - London branch
Japan Bank - New York branch
Japan Bank - Tokyo branch
Total
Grand Total
Total Net Aggregate Residual
AF
T
The respondent (U.S. Bank), and its consolidated U.S. and foreign offices, enters into various derivative contracts with a counterparty (Japan Bank and its various branches). The balances with the various branches of
Japan Bank on the books of U.S. Bank’s various locations as of the reporting date are shown below, in millions
of dollars:
Net Aggregate
Residual Amount
28
D-3
FFIEC 009
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57
Schedule D
(4) Assuming the respondent has no master netting agreement and that claims on bank branches are not formally
and legally guaranteed by the head office. Entries would be:
Schedule D
Col. 1 - Banks
Col. 5 - Total
Col. 6 - Cl With No
Guar
913
-------
913
-------
--320
256
25
Japan
Hong Kong
United Kingdom
United States
(5) Assuming the respondent has a master netting agreement and with Japan Bank. Entries would be:
Schedule D
Japan
Hong Kong
United Kingdom
United States
AF
T
Col. 1 - Banks
28
-------
Col. 5 - Total
Col. 6 - Cl With No
Guar
28
-------
---------
Japan
Hong Kong
United Kingdom
United States
D
R
(6) Assuming the same fact pattern as Example 5, but that the parties have also agreed to a bilateral collateralization agreement under which exposures greater than $10 million are collateralized with cash or liquid U.K. government securities. Assume that collateral is pledged in minimum incremental amounts of $5 million and that
U.K. government securities were pledged. Entries would be:
Schedule D
Col. 1 - Banks
Col. 2 - Public
Col. 5 - Total
Col. 6 - Cl With
No Guar
8
-------
----20
---
8
--20
---
---------
Assume the following fact pattern for Examples 7 and 8 for Schedule D:
The respondent, and its consolidated U.S. and foreign offices, enters into various derivative contracts with foreign corporate customers and banks. Assume the corporate customers are non-financial companies. The balances with these parties on the books of the respondent’s various locations as of the reporting date are shown
below, in millions of dollars:
D-4
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FFIEC 009
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Schedule D
Gross Positive
Fair Value
Gross Negative
Fair Value
Net by Location
15
45
60
120
11
75
40
126
4
-30
20
-6
-6
190
79
269
70
41
111
120
38
158
158
57
10
67
456
75
85
160
397
-18
-75
-93
-93
U.S. Bank - Hong Kong branch with:
Hong Kong Corporate
Singapore Corporate
U.K. Bank - Hong Kong branch
Total
U.S. Bank - London branch with:
U.K. Corporate
Hong Kong Bank - London branch
Total
U.S. Bank - New York branch with:
Argentine Corporate
Venezuela Bank
Total
Grand Total
Total Net Aggregate Residual
Net Aggregate
Residual Amount
AF
T
59
(7) Assuming the respondent has no master netting agreement and claims on bank branches are not formally and
legally guaranteed by the head office.
Col. 1 - Banks
Col. 4 - Other
Col. 5 - Total
Col. 6 - Cl With
No Guar
60
--10
79
---
190
57
--15
45
250
57
10
94
45
79
----60
---
D
R
United Kingdom
Argentina
Venezuela
Hong Kong
Singapore
Schedule D
(8) Assuming the respondent has no master netting agreement but that claims on bank branches are formally and
legally guaranteed by the head office. Also assume that the liabilities of the Argentine corporate customer are
legally guaranteed by its U.S. parent. Entries would be:
Schedule D
United Kingdom
Argentina
Venezuela
Hong Kong
Singapore
Col. 1 - Banks
Col. 4 - Other
Col. 5 - Total
60
--10
79
---
190
----15
57
250
--10
94
57
D-5
FFIEC 009
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59
Summary of Reporting Bases by
Schedule and Column
Appendix A
claims with guarantors in other sectors and jurisdictions
Column/s
Schedule O
5, 6
Schedule O
Schedule D
Schedule D
7
1 through 5
6
Schedule C, Part II 18
Reporting Basis
Country/sector of obligor
Country/Sector of outward risk transfer
Country/Sector of inward risk transfer
Country/sector of ultimate obligor/issuer of guarantee
Country of issuer of HTM and AFS securities
Location of counterparty
Location of issuer of trading assets
Issuer of offsetting position for trading book
Location of foreign-office obligor
Location of creditor
Location of affiliated counterparty
Location of party (after risk transfers) receiving commitment
Country of issuer of obligor for guarantees/insurance contracts
Gross position of credit derivatives purchased and sold (by country of reference
entity)
Net position of offsetting credit derivatives purchased and sold (by country of reference entity)
Location of recipient of trade financing
Location of counterparty or issuer of collateral
Location of branch if not guaranteed by parent
Immediate
Immediate
Ultimate Guarantor
Ultimate Guarantor
Ultimate Guarantor
Ultimate Guarantor
Ultimate Guarantor
Ultimate Guarantor
Ultimate Guarantor
Immediate
Immediate
Ultimate Guarantor
Ultimate Guarantor
Ultimate Guarantor
Location of collateral
Guarantor
D
R
Schedule C, Part I
1 through 12
Schedule C, Part I
13 through 17
Schedule C, Part I
18 through 22
Schedule C, Part II
1 through 11
Schedule C, Part II
12
Schedule C, Part II
13 through 16 17
Schedule C, Part II
17 19
Schedule C, Part II 20 18
Schedule L
1, 2
Schedule L
3
Schedule L
4
Schedule O
1
Schedule O
2
Schedule O
3, 4
Reporting Criteria
AF
T
Schedule
Ultimate Guarantor
Ultimate Guarantor
Ultimate Guarantor
Immediate
APP A-1
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| File Type | application/pdf |
| File Modified | 2022-08-15 |
| File Created | 2021-11-16 |