FFIEC 009a

FFIEC 009a Country Exposure Information 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 009a Country Exposure Information 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 009a Report, but with certain
modifications. The initial and final PRA Federal Register notices are available on the FFIEC’s
webpage for the FFIEC 009a Report.

Draft as of August 11, 2022

Table of Contents

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1. Draft FFIEC 009a Report Form……………………..Page 3 to Page 7
2. Draft FFIEC 009a Instructions……………………….Page 8 to Page 14

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Board of Governors of the Federal Reserve System
Federal Deposit Insurance Corporation
Office of the Comptroller of the Currency

OMB Number 7100-0035
OMB Number 3064-0017
OMB Number 1557-0100
Approval expires October 31, 2022
Page 1 of 2
2025

Federal Financial Institutions Examination Council

Country Exposure Information Report—FFIEC 009a
Report at the close of business
Month / Day / Year

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).

All FFIEC 009a 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 009a 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.

Reporting Institution (CEXA 9017)

City (CEXA 9130)

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Name, title, and phone number of the person to whom inquiries
regarding this report may be directed:

State (CEXA 9200)

Name (CEXA 8901)

Title (CEXA C496)

Legal Entity Identifier (LEI) of the Reporting Institution
(Report only if the reporting institution already has an LEI.) (CEXA 9224)

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Area Code / Phone Number (CEXA 8902)

A copy of this report will be made available to the public at http://www.ffiec.gov/e16.htm.
6.5
Public reporting burden for this collection of information is estimated to average 6 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.
12/2022

3

10/2019

Distribution of Amounts in Columns 3 and 4 (Guarantor Basis,
Except Column 19)

Country Exposure Information Report

FFIEC 009a
Page 2 of 2

Distribution of Amounts in Column 6 (Guarantor Basis
includes derivative products)

Part A

Information on exposure (as defined for Column 46) to any country that exceeds 1 .75 percent of the reporting institution's total assets or 20 15 percent of its total capital, whichever is less.
3 and 4

Guarantor Basis

U.S. Dollar Amounts in Millions
Country

CEX59209

CEXA

5215

Cross-Border and ForeignCollateral Held Against Claims With No Risk Transfer Office Commitments and
(Reported in Columns 1 and 2—By Counterparty)
Guarantees

Distribution of Amounts in Columns 1 and 2 (Guarantor Basis, Except Column 19 13)
Total of
Columns
(3)
Plus (4)
Plus (5)

By Type of Borrower

Total of
Columns (1)
Plus (2)
Plus (3)

Gross
ForeignOffice
Liabilities

Banks

Public

NBFIs

M883
(5)

M884
(6)

M885
(7)

M886
(8)

(7)

(12)

(13)

M882

(1)

M881
(2)

(3)

4254
(4)

(3)

(4)

(5)

(6)

(14)

By Maturity

Offsetting
Securities
Positions for (HTM and
Trading Book
AFS)

Other

One Year
and Under

Over One
Year

Trading
Assets

M887
(9)

M888
(10)

M889
(11)

M956
(12)

M874
(13)

(15)

(16)

(17)

(18)

(19)

Gross-Net

Of Which,
Resale
Agreements
and
Securities
Of Which,
Lending
Same
(CounterparCountry
ty)

Unused
Commitments

Guarantees
(Excluding
Credit
Total Credit Total Credit Total Credit Total Credit
Derivatives Derivatives Derivatives Derivatives Derivatives
Sold)
Purchased
Sold
Purchased
Sold

Total
Collateral

Of Which,
Cash

M869
(14)

M870
(15)

M871
(16)

M872
(17)

M873
(18)

C936
(19)

M875
(20)

(20)

(21)

(22)

(23)

(24)

(25)

(26)

M876
(21)
(27)

M877
(22)

M878
(23)

M879
(24)

(28)

(29)

(30)

Of which, Resale
and Reverse
Repurchase
Agreements and
Securities Lending
(Counterparty)

Part B

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Insert B

Credit Derivatives (By Reference Entity)
Gross-Gross

Trading Assets

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Insert A

Amount of
CrossAmount of
bBorder
Gross
Claims
Claims
Outstanding Amount of Outstanding
Foreign
After
from
Office
Mandated
Derivative
Adjustments Claims on
Products
Local
for Transfer
after
of Exposure Residents
Mandated
(Excluding (Excluding Adjustments
Derivative for Transfer
Derivative
Products) of Exposure
Products)

Information on exposures (as defined in Part A, Column 4) to any country not listed in Part A, where exposure exceeds 0.75 percent but does not exceed 1 percent of the reporting institution's assets or is between 15 percent and 20 percent of its total
capital, whichever is less.
Names of countries where exposures meet the reporting criteria stated for Part B:

Statement by management of the reporting institution concerning the information reported above (optional).

(CEXA 5224)

Total amount of exposure to all of the countries listed in Part B .......................... CEXA 5223 $
Management's statement will not be edited or screened by the supervisory agencies. Disclosure of the statement shall not signify that any federal supervisory agency has verified or confirmed the accuracy of the information
12/2022
contained therein.
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12/2013

Insert A
Immediate-Counterparty Basis
Amount of Cross-Border
Amount of Foreign Office
Claims Outstanding
Claims on Local Residents
(Excluding Derivative
in Local and Non-Local
Products)
Currencies (Excluding
Derivative Products)
MXXX
MXXX
(1)
(2)
New Column

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New Column

12/2022
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Insert B
Distribution of Amounts in Columns 1 and
2 (Immediate-Counterparty Basis)
By Type of Borrower

Public
MXXX
(9)

NBFIs
MXXX
(10)

Other
MXXX
(11)

New Column

New Column

New Column

New Column

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Banks
MXXX
(8)

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12/2022

Appendix A ‐ Columns Snapshot

FFIEC 009a (page 1)
Information on exposure (as defined for Column 6) to any country that exceeds  .75 percent of the reporting institution's total assets or 15 percent of its total capital, whichever is less.
Immediate-Counterparty 
Basis

Distribution of Amounts in Columns 1 and 2 
(Immediate-Counterparty Basis)

Guarantor Basis

By Type of Borrower

FFIEC 009a (page 2)

Public
NEW
(9)

NBFIs 
NEW
(10)

Other
NEW
(11)

Banks 
M884
(12)

Public
M885
(13)

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Banks 
NEW
(8)

NBFIs 
M886
(14)

Other
M887
(15)

Offsetting 
One Year and 
Positions for 
Under
Over One Year  Trading Assets Trading Book
M888
M889
M956
M874
(16)
(17)
(18)
(19)

Securities 
(HTM and 
AFS)
M869
(20)

AF

Country
CEX59209
CEXA

Amount of 
Cross‐Border 
Claims 
Amount of 
Outstanding 
Gross Claims 
Amount of 
After 
Amount of  Outstanding 
Amount of  Foreign Office  Mandated  Foreign Office 
from 
Cross‐Border  Claims on 
Adjustments 
Claims on 
Derivative 
Claims 
Local 
for Transfer of 
Local 
Products after 
Outstanding 
Residents 
Exposure 
Residents 
Mandated 
Total of 
(Excluding 
(Excluding 
(Excluding 
(Excluding  Adjustments  Columns (3) 
Gross 
Derivative 
Derivative 
Derivative 
Derivative  for Transfer of  Plus (4) Plus  ForeignOffice 
Liabilities
Products) 
Products) 
Products) 
Products) 
Exposure
(5)
NEW
NEW
5215
M881
M882
4254
M883
(1)
(2)
(3)
(4)
(5)
(6)
(7)

Distribution of amounts in Columns 3 and 4
Distribution of Amounts in Columns 3 and 4 (Guarantor Basis, Except Column [19]) 
Distribution of amounts in Column
6 (Guarantor Basis, includes derivative products)
(Guarantor Basis, except Column 19)
By Type of Borrower
By Maturity
Trading Assets

Information on exposure (as defined for Column 6) to any country that exceeds  .75 percent of the reporting institution's total assets or 15 percent of its total capital, whichever is less.
Collateral Held Against Claims With No Risk Transfer 
(Reported in Columns 3 and 4—By Counterparty)

Cross‐Border and Foreign 
Office Commitments and 
Guarantees

Credit Derivatives (By Reference Entity)

Of Which, 
Cash
M871
(22)

Of which, resale
and reverse
repurchase
agreements and
securities lending
(counterparty)

Guarantees 
(Excluding 
Credit 
Derivatives 
Sold)
M875
(26)

Total Credit 
Derivatives 
Purchased
M876
(27)

Total Credit 
Derivatives 
Sold 
M877
(28)

Total Credit 
Derivatives
Purchased
M878
(29)

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Country
CEX59209
CEXA

Total 
Collateral
M870
(21)

Of Which, 
Resale 
Agreements 
and Securities 
Of 
Lending 
Which,Same  (Counterparty
Unused 
Country
)
Commitments
M872
M873
C936
(23)
(24)
(25)

Gross‐Net

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Gross‐Gross

Total Credit 
Derivatives 
Sold 
M879
(30)

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Federal Financial Institutions Examination Council

Instructions for the Preparation of

Country Exposure Information Report
Reporting Form FFIEC 009a
December 2022

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Effective September 2019

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INSTRUCTIONS FOR PREPARATION OF

Country Exposure Information Report

General Instructions

Who Must Report

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

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This report must be filed by every institution that submits Form FFIEC 009 and that has exposure meeting
the reporting requirements for Form FFIEC 009a as
defined in these instructions.

6

Total assets of reporting banks are those submitted on
the Report of Condition to the federal bank supervisors as of the same date. For bank holding companies
total assets are those submitted on the most recent
Form FR Y-9C.

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

Total capital is as defined in the agencies’ guidelines on
capital adequacy and consists of Tier 1 plus Tier 2
capital.

Public Release of Country Exposure
Information Reports
The individual FFIEC 009a reports are made publicly
available.
A reporting institution may request confidential treatment for some or all of the portions of the
FFIEC 009a if the institution is of the opinion that
disclosure of specific commercial or financial information in the report would likely cause substantial harm
to its competitive position. In certain limited circumstances, the reporting institution’s primary federal
supervisor may approve confidential treatment of
some or all of the items for which such treatment has
been requested if the institution has clearly provided a
compelling justification for the request. A request for
confidential treatment must be submitted in writing
prior to the electronic submission of the report. The
written request must identify the specific items for
which confidential treatment is requested, provide justification for the confidential treatment requested for
the identified items, and demonstrate the specific
nature of the harm that would result from public
release of the information. Merely stating that competitive harm would result is not sufficient. Information for which confidential treatment is requested may
subsequently be released by the reporting institution’s
primary federal supervisor in accordance with the
terms of 12 CFR 4.16 (OCC), 12 CFR 261.16 (Board),
GEN-1

FFIEC 009a

September 2016

9

FFIEC 009a

Insert A

3
Column 1—Amount of Cross-border Claims
Outstanding After Mandated Adjustments for
Transfer of Exposure (excluding derivative
products) - Guarantor Basis

12 CFR 309.6 (FDIC), or as otherwise provided
by law.

Filing of Reports

Any FFIEC 009a respondent who needs filing guidance is encouraged to visit the Federal Reserve System
Website https://www.frbservices.org/central-bank/
reporting-central/index.html for additional information
on Reporting Central. The Website also includes a link
that respondents may use to contact the Federal
Reserve Bank of New York.

R

Rounding

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

D

Legal Entity Identifier (LEI)

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

Part A
Country

Insert B
the FFIEC 009a

6
The countries listed in Part A should be those where
exposure, as defined for Column 4, Part A, exceeds
.75 1 percent of total assets or 20 percent of total capital,
whichever is less. The names of the countries reported
should be as they appear on Form FFIEC 009. The
United States should be excluded from this report.
GEN-2
September 2019

For each country line reportable on the 3
FFIEC 009a report, report in Column 1 the sum of
Columns 1 through 5 from Schedule C, Part II, of the
FFIEC 009 report.

4
Column 2—Amount of Foreign–Office Claims
on Local Residents (excluding derivative
products) - Guarantor Basis
For each country line reportable on the 4
FFIEC 009a report, report in Column 2 the sum of
Columns 6 through 10 from Schedule C, Part II, of the
FFIEC 009 report.

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The report is to be prepared quarterly, as of the last
calendar day of March, June, September, and December. All respondents should submit their completed
report, each quarter they meet the reporting requirements, to the Federal Reserve Bank of New York
(FRBNY), via the Federal Reserve System’s Reporting
Central system, within 45 calendar days after the
March 31, June 30, and September 30 as-of date. The
submission deadline is 50 calendar days after the
December 31 as-of date.

5
Column 3—Amount of Gross Claims
Outstanding from Derivative Products after
Mandated Adjustments for Transfer of
Exposure - Guarantor Basis

List the total amount of claims from derivative products: From the FFIEC 009 report, Column 5 of Schedule D.

6
Column 4—Total Amount of Cross-Border
Claims and Foreign–Office Claims on Local
Residents - Guarantor Basis
Total of Columns 1 through 3.

3 through 5.

7
Column 5—Gross Foreign-Office Liabilities
List the total amount of gross foreign-office liabilities
as reported on the FFIEC 009 report, Columns 1 and 2
of Schedule L. Note that Columns 1 and 2 of Schedule L include foreign-office liabilities to both local and
non-local residents.

Columns 126 to
of amounts
in
Columns
to20:
14:Distribution
Distribution
of Amounts
column 6 (Guarantor
Basis, except
[19];
Outstanding
in Columns
1 and column
2 (except
includes
derivative
products)
Column 13)
12
Column 6—Banks - Guarantor Basis
6

Report the amounts included in Columns 1 and 2 of
this report where the counterparties are banks, as

15
FFIEC 009a

10

Insert A
Column 1—Amount of Cross-border Claims Outstanding (excluding derivative products)
– Immediate-Counterparty
For each country line reportable on the FFIEC 009a report, report in Column 1 the sum of Columns 1
through 5 from Schedule C, Part I, of the FFIEC 009 report.

Column 2—Amount of Foreign–Office Claims on Local Residents in Local and NonLocal Currencies (excluding derivative products) – Immediate-Counterparty

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For each country line reportable on the FFIEC 009a report, report in Column 2 the sum of Columns 6
through 10 and Column 12 from Schedule C, Part I, of the FFIEC 009 report.

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Insert B
Column 8—Banks – Immediate-Counterparty
Report the amounts included in Columns 1 and 2 of this report where the counterparties are banks, as defined
in Section II.D.1 of the FFIEC 009 instructions. These amounts are included on FFIEC 009 report on
Schedule C, Part I, Columns 1 and 6.

Column 9—Public- Immediate-Counterparty

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

Column 10—Non-Bank Financial Institutions (NBFIs) – Immediate-Counterparty

Report the amounts included in Columns 1 and 2 of this report where the counterparties are NBFIs, as defined
in Section II.D.3 of the FFIEC 009 instructions. These amounts are included on FFIEC 009 report on Schedule
C, Part I, Columns 3 and 8.

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

12

FFIEC 009a

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

13
Column 7—Public - Guarantor Basis

6

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

18

20
Column 14—Securities (HTM and AFS)
3 and 4

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

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Column 8—Non-Bank Financial Institutions
(NBFIs) - Guarantor Basis

19
In Column 13, report amounts included on the
FFIEC 009 report on Schedule C, Part II, Column 18
that represent short positions in the same securities, at
the issuer (on a legal entity basis) and instrument level
(i.e., debt versus debt and equity versus equity) as the
long positions reported in Column 12 of this report.

6

Report the amounts included in Columns 1 and 2 of
this report where the counterparties are NBFIs, as
defined in Section II.D.3 of the FFIEC 009 instructions. These amounts are included on
FFIEC 009 report on Schedule C, Part II, Columns 3
and 8, and Schedule D, Column 3.
15
6

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Column 9—Other - Guarantor Basis

D

Report the amounts included in Columns 1 and 2 of
this report where the counterparties cannot be classified as Banks, Public or NBFIs (see Section II.D.6 of
the FFIEC 009 instructions). These amounts are
included on the FFIEC 009 report on Schedule C,
Part II, Columns 4, 5, 9 and 10, and Schedule D, Column 4.
16 and 17

Columns 10 and 11—By Maturity
6

For each country, distribute the amounts reported in
Columns 1 and 2 according to time remaining to maturity as defined in Section IV.A of the
FFIEC 009 instructions: One Year and Under (Column 10) and Over One Year (Column 11). 17
16

16 and 17

In completing Columns 10 and 11, estimates may be
used.
18 and 19

Columns 12 and 13—Trading Assets

3 and 4

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

21 to 24

Columns 15 to 18: Collateral Held Against
Claims with No Risk Transfers
21 through 24

Columns 15 through 18 below are to be reported based
on the location of the counterparty and are not
mutually-exclusive.
21

3 and 4

In Column 15, report for each country claims included
in Columns 1 and 2 that represent claims for which the
obligor provided collateral that did not meet the definition of collateral for risk-transfers of claims, namely
through resale agreements, securities lending arrangements and other similar financing agreements. This
amount is included on the FFIEC 009 report on
Schedule C, Part II, Column 13.
22

21

In Column 16, report for each country the amounts
included in Column 15 of this report where the collateral provided was cash. This amount is included on the
FFIEC 009 report on Schedule C, Part II, Column 14.
23

21

In Column 17, report for each country the amounts
included in Column 15 where the holder of the cash
collateral or the issuer of the securities provided for
collateral are in the same country as the counterparty
to the transaction. This amount is included on the
FFIEC 009 report on Schedule C, Part II, Column 15.
24

21

In Column 18, report for each country the amounts
included in Column 15 that represent claims resulting
from resale agreements, securities lending transaction,
or similar financing agreements. This amount is
included on the FFIEC 009 report on Schedule C,
Part II, Column 16.
GEN-3

FFIEC 009a

September 2016

13

FFIEC 009a

25 and 26

Columns 19 and 20: Cross-Border and
Foreign-Office Commitments and
Guarantees
25

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

Column 19—Unused Commitments

Part B

Report for each country the amounts included on the
FFIEC 009 report on Schedule O, Column 1, that represent unused commitments. See Section VII.A of the
FFIEC 009 instructions for additional details.
26

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

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Column 20—Guarantees (Excluding Credit
Derivatives Sold)
Report for each country the amounts included on the
FFIEC 009 report on Schedule O, Column 2, that represent legally binding guarantees and insurance contracts issued by the reporter’s U.S. or foreign offices for
which the ultimate obligor is not a U.S. resident,
excluding credit derivatives sold. Reporting should be
done based on the location of the ultimate obligor.
27 through 30

27 and 28

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Columns 21 through 24: Credit Derivatives
(By Reference Entity)
Columns 21 and 22—Gross-Gross
27

D

Report in Column 21, by country of the underlying
reference asset, the notional value of total credit
derivatives purchased. The amounts are included on
the FFIEC 009 report on Schedule O, Column 3.
28

Report in Column 22, by country of the underlying
reference asset, the notional value of total credit
derivatives sold. The amounts are included on the
FFIEC 009 report on Schedule O, Column 4.
29 and 30

Columns 23 and 24—Gross-Net
29 and 30

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

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

27 and 28

GEN-4
September 2016

FFIEC 009a

14