FFIEC 009 and FFIEC 009a 18 Question Format OMB Supporting Statement

Supporting Statement for the
Country Exposure Report (FFIEC 009; OMB No. 7100-0035) and the
Country Exposure Information Report (FFIEC 009a; OMB No. 7100-0035)
1.

Explain the circumstances that make the collection of information necessary.

In 1977, the agencies, under the auspices of the FFIEC, implemented the mandatory
FFIEC 009 in response to substantial growth in U.S. banks’ international lending and a lack of
information on banks’ country risk exposures. In 1984, the FFIEC increased the frequency of
FFIEC 009 reporting from semiannual to quarterly to implement provisions of the International
Lending Supervision Act of 1983 (the Act) for the purpose of obtaining more timely data on
changes in the composition and maturity of banks’ loan portfolios subject to transfer risk, which
is the possibility that an asset cannot be serviced in the currency of the payment because the
obligor’s country lacks the necessary foreign exchange or has put restraints on its availability.
In 1984, the agencies, under the auspices of the FFIEC, implemented the mandatory
FFIEC 009a as a supplement to the FFIEC 009 in accordance with provisions of the Act. The
FFIEC 009a provides public disclosures of information regarding material country risk exposure.
2.
Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current collection.
The agencies collect the FFIEC 009 and FFIEC 009a under the auspices of the FFIEC.
The Board is responsible for collecting and compiling the data reported on the FFIEC 009 and
FFIEC 009a on behalf of all three agencies. Each of the agencies submits a separate supporting
statement to OMB for this collection of information for relevant banking organizations under
their supervision. For the Board, these banking organizations are state member banks, Edge or
agreement corporations, bank holding companies (BHCs), savings and loan holding companies
(SLHCs), and U.S. intermediate holding companies of foreign banking organizations (IHCs).
The agencies use the information collected by the FFIEC 009 to supervise the overseas
lending activities of U.S. banking organizations. The information is used to monitor the degree
of country risk and transfer risk in U.S. banking organizations’ portfolios and the potential
impact of adverse international developments on these banking organizations. The FFIEC 009 is
the source of information about the geographic distribution of bank claims that the Board
provides to other U.S. government agencies and, in aggregate form, to the Bank for International
Settlements (BIS). The information collected in the FFIEC 009 is not available from any other
source.
3.

Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology.

The data collected through the FFIEC 009 and FFIEC 009a are submitted electronically
through the Board’s Reporting Central online application.

4.

Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.

The data collected through the FFIEC 009 and FFIEC 009a are unique and cannot be
replaced by data already collected by the federal government.
5.

If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.

Of respondents to the FFIEC 009 and FFIEC 009a, 2 for the FFIEC 009 and 2 for the
FFIEC 009a are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $750 million in total assets), https://www.sba.gov/document/support-table-size-standards. There are no special accommodations given to mitigate the burden on small
institutions.
6.

Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.
Federal statute requires the quarterly submission of the data.

7.

Explain any special circumstances that would cause an information collection to be
conducted in a manner inconsistent with 5 CFR 1320.5(d)(2).

This information collection is conducted in a manner consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Describe comments in response to the Federal Register notice and efforts to consult
outside the agency.

On January 20, 2022, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (87 FR 3170) requesting public comment for 60 days on the
extension, with revision, of the FFIEC 009 and FFIEC 009a. The comment period for this notice
expired on March 21, 2022. The agencies received one comment letter from a banking trade
association. The commenter requested clarification of certain aspects of the proposed FFIEC 009
and FFIEC 009a reporting forms and instructions. The specific comments and the agencies’
responses follow.
First, the commenter noted that the proposed change to the naming of headers for
Columns 13 through 17 and 18 through 22 of Schedule C, Part I, which the agencies stated
would be a nonsubstantive change, could imply that the risk transfers reported on the FFIEC 009
would be limited to only those with guarantors in countries other than that of the immediate
counterparty, but would no longer include risk transfers between different sectors within the
same country. The commenter recommended renaming the headers to include both other sectors
and other jurisdictions to ensure there would be no substantive change in reporting. The agencies

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agree with the commenter’s recommendation and have revised the headers accordingly. In
connection with the proposed changes to the FFIEC 009 and FFIEC 009a, it was the agencies’
intent that risk transfers continue to be reported according to existing reporting practices and in
line with the instructions.
Second, the commenter asked for clarification on whether claims where cash collateral is
provided should be included in Column 18 of Schedule C, Part II. Furthermore, the commenter
stated that the use of “collateral” with respect to Column 18 seemed out of place and not paralle l
to the instructions for Column 17. In response to the comment, the agencies have combined the
instructions for Columns 17 and 18 to emphasize that the same claims are to be reported, but the
risk is to be assigned by different criteria. Furthermore, the revised instructions state that cash
held as collateral should not be reported in these columns.
Third, with regard to Schedule C, Part II, columns, 13 through 18, the commenter asked
for clarification on the reporting of collateral held against claims where risk transfer occurs
because the guarantor is located in a different country, or is from a different sector than the
immediate counterparty even though collateral held against the claim does not meet the
definition of collateral for risk transfer. This would occur in an overnight resale agreement,
collateralized by securities, with a foreign branch of a bank that is headquartered in a third
country. In response to the comment, the agencies have amended the instructions to clarify that
collateral held against claims that are subject to risk transfer does not need to be reported in
columns 13 through 18 of Schedule C, Part II.
Fourth, the commenter requested clarification on the reporting basis for Columns 1 and 2
of Schedule L, as the agencies proposed to rename the reporting basis for these columns in
Appendix A of the instructions but did not propose to change the substantive instructions. The
commenter proposed to amend the instructions for these columns to state that deposits of a
foreign branch are assumed to be liabilities of the branch unless they are explicitly guaranteed
outside of the country where the branch is located. This represents a change from the current
instructions, which refer to deposits that are redeemable elsewhere (rather than guaranteed
elsewhere). The agencies consider the modification as originally proposed to be a change in
name rather than a substantive alteration. The agencies note that there was no change in the
instructions for Columns 1 and 2 of Schedule L from the 2019 version and the proposed
amendment is out of scope for the current revision. Accordingly, the agencies have decided not
to change the corresponding instructions as recommended by the commenter. However, after
further consideration and in the interest of clarity, the agencies are revising the form to leave
blank the “Reporting Basis” entry in Appendix A (rightmost column) in the row addressing
Columns 1 and 2 of Schedule L (which was originally proposed to be “Guarantor Basis”). This
change provides a useful clarification because the location is that of the foreign office, not the
counterparty, and thus neither Immediate-Counterparty nor Guarantor Basis is applicable.
Furthermore, as established in section II.C of the FFIEC 009 general instructions, the ImmediateCounterparty versus Guarantor Basis distinction is to be reported only for claims and not for
liabilities.
Fifth, the commenter noted that the draft reporting instructions for Column 2 of the
FFIEC 009a report instruct firms to report the sum of Columns 6 through 10 from Schedule C,

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Part I, of the FFIEC 009 report, which are “Claims on Local Residents in Non-Local Currency.”
However, the proposal does not provide an indication in the heading for Column 2 of the
FFIEC 009a that the data reported in the column should be limited to only claims on local
residents in non-local currency, nor is there any reference in the draft instructions for the
reporting of claims on local residents in local currency. The commenter recommended the
agencies clarify whether the data in Column 2 should include claims on local residents in both
local and non-local currencies and subsequently modify the heading for Column 2 to clearly
specify what is to be captured.
The commenter also stated if the intention for new Columns 1 and 2 of the FFIEC 009a is
to collect data on the total claims by the immediate counterparty and as a result should reflect the
claims in both local and non-local currencies, the agencies should clarify the reporting
instructions for Column 2 to reference Column 12 from Schedule C, Part I of the FFIEC 009 to
incorporate claims on local residents in local currency. The agencies agree both new Columns 1
and 2 of the FFIEC 009a should reflect total claims by immediate counterparty and Column 2
should include claims that are reflected in column 12, Schedule C, Part 1 of the FFIEC 009, in
addition to those reflected in columns 6 through 12. Therefore, the agencies agree with the
commenter’s recommendation to include a reference to Column 12 from Schedule C, Part I o f
the FFIEC 009 in the FFIEC 009a instructions for Column 2 and will modify the heading for
Column 2 on the FFIEC 009a report form to specify what is included.
Sixth, the commenter noted that Schedule D of the FFIEC 009 collects information on the
fair value of derivative contracts, and the headers for new Column 1 “Amount of Cross-border
Claims Outstanding” and Column 2 “Amount of Foreign Office Claims on Local Residents” of
the FFIEC 009a explicitly indicate that firms should exclude derivative products. The commenter
pointed out that referencing Schedule D in the instructions for new Columns 8 through 11 of the
FFIEC 009a created an inconsistency and recommended removing the references to Schedule D
from the instructions of Columns 8 through 11. The agencies note that the amounts in Columns 8
through 11, which are reported on an immediate counterparty basis, correspond to the crosssectoral aggregated amounts in Columns 1 and 2 which are not intended to include derivatives.
Therefore, the agencies agree with the commenter’s recommendation to remove the references to
Schedule D of the FFIEC 009 and will modify the instructions accordingly.
Seventh, the commenter noted an inconsistency in the proposed FFIEC 009a instructions
for Column 3 “Amount of Cross-border Claims Outstanding After Mandated Adjustments for
Transfer of Exposure (excluding derivative products)” (existing Column 1), Column 4 “Amount
of Foreign Office Claims on Local Residents (excluding derivative products)” (existing Column
2) and Columns 12 through 15 (existing Columns 6 through 9), which redistribute the same
amounts reported in Columns 3 and 4. The commenter noted that there is a conflict because, by
including references to FFIEC 009 Schedule D, the instructions imply that Columns 12 through
15 include derivative products, while derivatives are explicitly excluded from Columns 3 and 4.
The commenter recommended that the agencies revise the reporting instructions for Columns 12
through 15 to remove the references to the FFIEC 009, Schedule D thereby removing derivatives
from the reporting of guarantor basis claims in the sector breakdown of Columns 12 through 15.
The agencies agree there is an inconsistency, Columns 3 and 4 correctly exclude derivatives,
whereas Columns 12 through 15 are intended to include derivatives. Derivatives are listed in

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Column 5 and included in Column 6, total claims on a guarantor basis, which is the sum of
Columns 3, 4, and 5. Therefore, the agencies will revise the column headers and the instructions
for Columns 12 through 17 of the FFIEC 009a to reference the total in Column 6 and note
derivative products are to be included. Therefore, Columns 12 through 15 will include
derivatives and retain the references to Schedule D of the FFIEC 009.
Eighth, the commenter noted that, given the changes to the FFIEC 009 and the
renumbering of columns, the instructions for the new Column 24 (currently Column 18) of the
FFIEC 009a “Of Which, Resale Agreements and Securities Lending (Counterparty)” incorrectly
references FFIEC 009 Schedule C, Part II, Column 16. Additionally, the commenter noted that
the column header for Column 24 does not include “Reverse Repurchase Agreements” which is
inconsistent with the column headers of Columns 17 and 18 on the FFIEC 009, Schedule C, Part
II, which are “Of Which, Resale and Reverse Repurchase Agreements and Securities Lending
(Counterparty)” and “Of Which, Resale and Reverse Repurchase Agreements and Securities
Lending (Collateral),” respectively. Therefore, the commenter recommended that the agencies
revise the reporting instructions for Column 24 of the FFIEC 009a to reference Column 17 of
Schedule C, Part II of the FFIEC 009 and revise the header for Column 24 of the FFIEC 009a, to
read “Of Which, Resale and Reverse Repurchase Agreements and Securities Lending
(Counterparty),” to be consistent with the headers in the corresponding columns of the
FFIEC 009. The agencies agree with the commenter and will revise the instructions and headers
accordingly.
Lastly, the commenter expressed a concern that there is potentially conflicting guidance
regarding CUSIP netting practices in the FFIEC 009. Specifically, the commenter noted that the
agencies had provided one method for netting in a Frequently Asked Question issued in
September 2015, while a different method was described in informal guidance during a 2016
regulatory reporting seminar conducted by one of the agencies. In 2019, the agencies received a
related comment on whether CUSIP netting in the FFIEC 009 should follow U.S. GAAP. In
response to that comment, the agencies clarified that CUSIP netting should not follow U.S.
GAAP and reiterated that the current FFIEC 009 instructions (incorporating the method
described in September 2015) is the correct method for CUSIP netting in the FFIEC 009.1 The
agencies continue to confirm that only the CUSIP netting method described in the FFIEC 009
instructions is appropriate.
On August 11, 2022, the agencies, under the auspices of the FFIEC, published a final
notice in the Federal Register (87 FR 49647) requesting public comment for 30 days on the
extension, with revision, of the FFIEC 009 and FFIEC 009a. The comment period for this notice
expires on September 12, 2022.
9.

Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There are no payments or gifts provided to respondents.

1

See 84 FR 47340, 47342 (September 9, 2019).

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10.

Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy. If the collection requires a
systems of records notice (SORN) or privacy impact assessment (PIA), those should
be cited and described here.

The information for individual reporting entities reported in the FFIEC 009 is collected as
part of the Board’s supervisory process, and therefore, such information is afforded confidential
treatment pursuant to exemption 8 of the Freedom of Information Act (FOIA) which protects
information contained in “examination, operating, or condition reports” obtained in the bank
supervisory process (5 U.S.C. § 552(b)(8)). In addition, confidential commercial or financial
information, which a submitter both customarily and actually treats as private, may be exempt
from disclosure under exemption 4 of the FOIA (5 U.S.C. § 552(b)(4)). Aggregated data from
the FFIEC 009 that does not reveal the activities of individual reporting entities may be made
public.
Data from the FFIEC 009a is published on the FFIEC web page as part of the E.16
release and aggregated data from the FFIEC 009a may also be made public. Individual
respondents may request that information submitted to the Board through the FFIEC 009a be
kept confidential. If a respondent requests confidential treatment, the Board will determine
whether the information is entitled to confidential treatment on a case-by-case basis. Confidential
commercial or financial information, which a submitter both customarily and actually treats as
private, may be exempt from disclosure under exemption 4 of the FOIA.
11.

Provide additional justification for any questions of a sensitive nature.
There are no questions of a sensitive nature.

12.

Provide estimates of the annual hourly burden of the collection of information.

As shown in the table below, the estimated total annual burden for the FFIEC 009 and
FFIEC 009a with respect to banking organizations supervised by the Board is 26,564 hours, and
would increase to 27,422 hours. The estimated number of respondents is based on the reporting
panel as of June 2021. The agencies estimate that the proposed revisions would increase the
average hours per response for FFIEC 009 by 4 hours. This change in burden is primarily due to
adding the two new collateral columns. Since the proposed revisions to the FFIEC 009a reflect
disclosures of data already collected, but not currently disclosed on the FFIEC 009, the agencies
estimate that the average hours per response for FFIEC 009a would increase by 0.5 hours. These
reporting requirements represent less than 1 percent of the Board’s total paperwork burden.

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Estimated
number of
respondents

Annual
frequency

49
37

4
4

131
6

25,676
888
26,564

49
37

4
4

135
6.5

Proposed Total

26,460
962
27,422

Change

858

FFIEC 009 and FFIEC 009a
Current
FFIEC 009
FFIEC 009a

Estimated
Estimated
average hours annual burden
per response
hours

Current Total
Proposed
FFIEC 009
FFIEC 009a

The estimated total annual cost to the public for the FFIEC 009 and FFIEC 009a is
$1,605,794, and would increase to $1,657,660 with the proposed revisions.
Total cost to the public was estimated using the following formula: percent of staff time,
multiplied by annual burden hours, multiplied by hourly rates (30% Office & Administrative
Support at $21, 45% Financial Managers at $74, 15% Lawyers at $71, and 10% Chief Executives
at $102). Hourly rates for each occupational group are the (rounded) mean hourly wages from
the Bureau of Labor Statistics (BLS), Occupational Employment and Wages, May 2021,
published March 31, 2022, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.
13.

Provide an estimate for the total annual cost burden to respondents or record
keepers resulting from the collection of information.
There are no annualized costs to the respondents.

14.

Provide estimates of annualized costs to the Federal government.

The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 009 and FFIEC 009a is $117,000.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.

The agencies propose to revise the FFIEC 009 and FFIEC 009a in the following four
ways to take effect as of the December 31, 2022, report date.

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Change from Ultimate Risk to Guarantor Basis in the FFIEC 009
The FFIEC 009 requires respondents to report their international claims based on the
country of residence of the counterparty and, additionally, to redistribute these immediate counterparty claims to provide the country of residence of the guarantors or collateral of the
claims. This redistribution is termed “Ultimate Risk Basis;” however, the redistribution
specified in the current FFIEC 009 instructions does not always identify the ultimate bearer of
risk but does identify the country of a guarantor. The term “Guarantor Basis” more accurately
describes what is being collected. Therefore, the agencies propose to rename the “Ultimate
Risk Basis” columns on the FFIEC 009 to “Guarantor Basis” and make corresponding changes
to the instructions.
Addition of Two New Collateral Columns to the FFIEC 009
The 2013 revision of the FFIEC 009 report introduced memorandum items on collateral
pledged against claims that is not eligible for risk transfer treatment as defined in the report
instructions. The items were introduced to help “users to better assess net risks based on their
own assumptions about the benefits of the collateral,” and were also intended to “produce
greater insight into reporting institutions' own internal calculations of foreign country
exposure, which typically take collateral into account.” 2 This information is especially useful
for certain claims such as reverse repurchase agreements and other securities financing
transactions reported on a direct counterparty basis. However, while the FFIEC 009 and
FFIEC 009a collect information regarding the amount of collateral that originates in the same
country as the direct counterparty, the reports do not record the source of collateral if it has
other origins, be it the U.S. or any other countries. This limits the ability of users to assess the
extent to which collateral mitigates risk because the mitigation could be greater (e.g., if
collateral originates in the U.S.), or less (if the collateral originates in a lower-rated third
country) than the risk mitigation provided by collateral from the same country as the direct
counterparty. This could also affect the ability of the FFIEC agencies to monitor U.S. bank
exposures to high-risk countries. 3
As of September 30, 2021, the FFIEC 009 reports included $1.039 trillion in collateral
supporting claims not eligible for risk transfer. Some $607 billion of this collateral originated
outside of the country of the direct counterparty, equivalent to 13.2 percent of all U.S. banking
organizations’ direct outstanding claims. Furthermore, $152 billion of the $607 billion of
collateral involved claims against counterparties domiciled in the Cayman Islands, representing
29 percent of direct outstanding claims to that jurisdiction. Other countries where collateral
against claims not eligible for risk transfer and not originating in the same country exceede d
$25 billion, or 15 percent of direct outstanding claims, included, but not limited to, France,
Japan, Canada, the United Kingdom, Germany, Singapore, South Korea, Ireland, and
Luxembourg.

2

78 FR 6176, 6179 (January 29, 2013).
For example, in 1979, the Board, FDIC, and OCC established the Interagency Country Exposure Review
Committee to ensure consistent treatment of the transfer risk associated with banks’ foreign exposures to both
public- and private-sector entities. See https://www.fdic.gov/regulations/safety/guide/icerc.pdf.
3

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The agencies propose adding two new columns to the FFIEC 009, Schedule C, Part II,
Claims on an Ultimate Risk Basis and Memorandum Items, under “Collateral Held Against
Claims with No Risk Transfer.” The title of the first additional column would be: “Of Which
U.S.,” which would be inserted after the column titled “Of Which, Same Country.” This new
column would show the amount of collateral that consists of U.S. Treasury securities or other
securities issued by the U.S. The title of the second new column would be: “Of Which Resale
and Reverse Repurchase Agreements and Securities Lending (Collateral).” This column would
duplicate the existing column that reports collateral for financing and securities lending based
on the country of the counterparty (currently column 16) but would reallocate amounts based
on the country in which the collateral was issued. Together, these two new columns, along with
column 16, would help provide a more complete view of the origin of collateral and its value as
a risk mitigant. This proposed change to the FFIEC 009 would improve information on the
origin of the underlying securities acting as collateral for claims with no risk transfer.
Adjustment of Reporting Thresholds on the FFIEC 009a
The current FFIEC 009a form consists of two parts, Part A and Part B. Part A requires
detailed information on total exposures to any foreign country in excess of 1 percent of the
institution’s total assets or 20 percent of the institution’s total capital, whichever is less. Part B
requires only the country name for exposures to any foreign country in excess of 0.75 percent
of the institution’s total assets or 15 percent of the institution’s total capital, whichever is less,
and is not listed in Part A.
The current format of Part B of the FFIEC 009a (i.e., a list of country names) and the
difference in level of detail between Part A and Part B reporting requirements have caused
confusion and errors for reporting institutions. In addition, the more limited detail available in
Part B reporting makes this portion of the report much less useful than the more granu lar
reporting in Part A. Therefore, the agencies propose to eliminate Part B of the FFIEC 009a and
expand the scope for reporting the more granular information currently in Part A. Under the
proposed scope, reporting institutions would have to report more granular exposure
information for each foreign country that exceeds the lesser of 0.75 percent of total assets or 15
percent of total capital, which is the current Part B threshold. Revising the scope to provide
additional reporting granularity to the public should result in negligible additional burden for
reporting institutions because similar granularity is already being reported in the FFIEC 009.
Based on recent reporting, the proposed change is expected to provide more granular
disclosure for over $200 billion in additional foreign claims, mostly by global systemically
important banking organizations. 4 Additionally, the agencies expect a limited impact to
reporting institutions, as approximately one-third of reporting institutions will have no
additional countries to report, about one-third of reporting institutions will provide more detail
for one additional country, and the remaining reporting institutions will provide more detail for
an average of an additional two countries each.

4

As defined in 12 CFR 252.2.

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Addition of Immediate-Counterparty Claims Columns to FFIEC 009a
The FFIEC 009a data provide important market transparency and comparability data
regarding banking organizations’ foreign claims. The agencies propose to enhance its
effectiveness by adding key information on an immediate-counterparty basis. The current
format of the FFIEC 009a concentrates primarily on guarantor basis (currently labelled
Ultimate Risk Basis) claims. Guarantor basis information can be somewhat opaque to the
public and generally reflects an implicit assumption of full substitutability between claims
exposure and offsets such as credit derivatives or collateral.
The agencies propose to add six columns of information that report immediatecounterparty claims:
• One new column for Amount of Cross-Border Claims Outstanding (Excluding
Derivative Products),
• One new column for Amount of Foreign Office Claims on Local Residents (Excluding
Derivative Products), and
• Four new columns for Distribution of Amount of Cross-Border Claims across
counterparty sector, that is, Banks, Public, Non-Bank Financial Institutions (NBFIs),
and Other.
These new columns would parallel the existing Part A, columns (1), (2), and (6)-(9)
except they would be reported on an immediate-counterparty basis rather than a guarantor basis.
The agencies would retain the existing Guarantor Basis columns.
16.

Provide information regarding plans for publication of data.

The FFIEC publishes aggregate data from the FFIEC 009 in the quarterly E.16 statistical
release, Country Exposure Lending Survey. Both FFIEC 009 aggregated data and applicable
individual FFIEC 009a data are included in this release. In addition, the Federal Reserve makes
aggregate data available to the BIS, which publishes statistical data on consolidated bank claims
on foreign borrowers as its “consolidated international banking statistics” on its website
(https://www.bis.org/statistics/consstats.htm) and in its Quarterly Review.
17.

If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
No such approval is sought.

18.

Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
There are no exceptions.

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