FRY14_20220920_omb

FRY14_20220920_omb.pdf

Capital Assessments and Stress Testing Reports

OMB: 7100-0341

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Supporting Statement for the
Capital Assessments and Stress Testing Reports
(FR Y-14A/Q/M; OMB No. 7100-0341)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No.
7100-0341). These collections of information are applicable to top-tier U.S. bank holding
companies (BHCs), U.S. intermediate holding companies of foreign banking organizations
(IHCs), and covered savings and loan holding companies (SLHCs) 1 (collectively holding
companies) with $100 billion or more in total consolidated assets. The FR Y-14A, FR Y-14Q,
and FR Y-14M reports (FR Y-14 reports) are used to set firms’ stress capital buffer (SCB)
requirements. The data are also used to support the supervision and regulation of these financial
institutions.
The Board adopted a number of revisions to the FR Y-14 reports that improve the
Board’s ability to identify risks not currently captured in the supervisory stress test, enhance data
reconciliation efforts, and make other clarifications. For the FR Y-14Q, the revisions are
effective for either the September 30, 2022, as of date, or the June 30, 2023, as of date. For the
FR Y-14M, the revisions are effective for the September 30, 2022, as of date, and for the
FR Y-14A, the revisions are effective for the December 31, 2022, as of date.
The current estimated total annual burden for the FR Y-14 reports is 809,000 hours, and
would increase to 810,464 hours. The revisions would result in an increase of 1,464 hours. The
draft reporting forms and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms/home/review.
Background and Justification
Section 165(i)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act)2 requires the Board to conduct an annual stress test of certain companies to
evaluate whether the company has sufficient capital, on a total consolidated basis, to absorb
losses as a result of adverse economic conditions (supervisory stress test). 3 Further, section
165(i)(2) of the Dodd-Frank Act requires the Board to issue regulations requiring such
companies to conduct company-run stress tests.4 On May 24, 2018, the Economic Growth,
Regulatory Relief, and Consumer Protection Act (EGRRCPA) amended sections 165(i)(1) and

Covered SLHCs are those that are not substantially engaged in insurance or commercial activities. See 12 CFR
217.2.
2
Pub. L. No. 111-203, 124 Stat. 1376 (2010).
3
See 12 U.S.C. § 5365(i)(1).
4
See 12 U.S.C. § 5365(i)(2).

(2) of the Dodd-Frank Act, among other changes. 5 The Board’s rules implementing sections
165(i)(1) and (i)(2) of the Dodd-Frank Act, and section 401 of EGRRCPA, establish stress
testing requirements for certain BHCs, state member banks, savings and loan holding companies,
foreign banking organizations, and nonbank financial companies supervised by the Board.6
Additionally, the Board’s capital plan rule requires certain firms to submit capital plans to
the Board annually and requires such firms to request prior approval from the Board under
certain circumstances before making a capital distribution. 7 In connection with submissions of
capital plans to the Board, firms are required, pursuant to 12 CFR 225.8(e)(3) and 12 CFR
238.170(e)(3), to provide information including, but not limited to, the firm’s financial condition,
structure, assets, risk exposure, policies and procedures, liquidity, and risk management.
The FR Y-14 reports collect stress test and capital plan data from the largest holding
companies, which are those with $100 billion or more in total consolidated assets. The data
collected through the FR Y-14 reports provide the Board with the information needed to help
ensure that large holding companies have strong, firm‐wide risk measurement and management
processes supporting their internal assessments of capital adequacy and that their capital
resources are sufficient given their business focus, activities, and resulting risk exposures.
Information gathered in this data collection is also used in the supervision and regulation of these
financial institutions.
The FR Y-14 reports complement other Board supervisory efforts aimed at enhancing the
continued viability of large firms, including continuous monitoring of firms’ planning and
management of liquidity and funding resources, as well as regular assessments of credit, market,
and operational risks, and associated risk management practices.
Description of Information Collection
These collections of information are applicable to top-tier holding companies with total
consolidated assets of $100 billion or more. This family of information collections is composed
of the following three mandatory reports:
• The annual FR Y-14A, which collects quantitative projections of balance sheet, income,
losses, and capital across a range of macroeconomic scenarios, and qualitative
information on methodologies used to develop internal projections of capital across
scenarios.8
EGRRCPA requires “periodic” supervisory stress tests for bank holding companies with $100 billion or more, but
less than $250 billion, in total consolidated assets and amended section 165(i)(1) to require annual supervisory stress
tests for bank holding companies with $250 billion or more in total consolidated assets. EGRRCPA amended section
165(i)(2) to require bank holding companies with $250 billion or more in total consolidated assets, and financial
companies with more than $250 billion in total consolidated assets, to conduct “perio dic” stress tests. Finally,
EGRRCPA amended both sections 165(i)(1) and (2) to no longer require the Board to include an “adverse” scenario
in company-run or supervisory stress tests, reducing the number of required stress test scenarios from three to two.
6
See 12 CFR 252, subparts B, E, F, and O.
7
See 12 CFR 225.8; 12 CFR 238.170.
8
In certain circumstances, a firm may be required to re-submit its capital plan. See 12 CFR 225.8(e)(4); 12 CFR
238.170(e)(4). Firms that must re-submit their capital plan generally also must provide a revised FR Y-14A in
connection with their resubmission.
5

•
•

The quarterly FR Y-14Q, which collects granular data on various asset classes, including
loans, securities, trading assets, and pre-provision net revenue (PPNR) for the reporting
period.
The monthly FR Y-14M, which is comprised of three retail portfolio- and loan-level
schedules, and one detailed address matching schedule to supplement two of the
portfolio- and loan-level schedules.
FR Y-14A (annual collection)

The annual collection of quantitative projected regulatory capital ratios across various
macroeconomic scenarios is comprised of five primary schedules (Summary, Scenario,
Regulatory Capital Instruments, Operational Risk, and Business Plan Changes), each with
multiple supporting tables. The FR Y-14A schedules collect current financial information and
projections under the Board’s supervisory scenarios. The information includes balances for
balance sheet and off‐balance‐sheet positions, income statement and PPNR, and estimates of
losses across various portfolios. Firms are also required to submit qualitative information
supporting their projections, including descriptions of the methodologies used to develop the
internal projections of capital across scenarios and other analyses th at support their
comprehensive capital plans.
FR Y-14Q (quarterly collection)
The FR Y-14Q schedules (Retail, Securities, Regulatory Capital Instruments, Regulatory
Capital, Operational Risk, Trading, PPNR, Wholesale Risk, Fair Value Option/Held for Sale,
Supplemental, Counterparty, and Balances) collect firm‐specific data on positions and exposures
that are used as inputs to supervisory stress test models to monitor actual versus forecast
information on a quarterly basis and to conduct ongoing supervision.
FR Y-14M (monthly collection)
The FR Y-14M report includes two portfolio- and loan-level schedules for First Lien data
and Home Equity data, and an account- and portfolio-level schedule for Domestic Credit Card
data. To match senior and junior lien residential mortgages on the same collateral, the Address
Matching schedule gathers additional information on the residential mortgage loans reported in
the First Lien and Home Equity schedules.
Respondent Panel
The respondent panel consists of holding companies with $100 billion or more in total
consolidated assets, as based on (1) the average of the firm’s total consolidated assets in the four
most recent quarters as reported quarterly on the firm’s Consolidated Financial Statements for
Holding Companies (FR Y-9C; OMB No. 7100-0128) or (2) the average of the firm’s total
consolidated assets in the most recent consecutive quarters as reported quarterly on the firm’s
FR Y-9Cs, if the firm has not filed an FR Y-9C for each of the most recent four quarters.
Reporting is required as of the first day of the quarter immediately following the quarter in which
the respondent meets this asset threshold, unless otherwise directed by the Board.

Proposed Revisions to the FR Y-14 Reports
The proposed revisions would have allowed the Board to better identify risks not
currently captured in the stress test, facilitate data reconciliation, and mitigate ambiguity within
the instructions. Data reconciliation is an important step in the stress testing analysis conducted
by the Federal Reserve, as it ensures values are being reported consistently across firms.
Consistent data leads to consistent treatment f or stress testing purposes, which is critical, as
stress testing is used to determine a firm’s capital requirements via the SCB requirement. The
Board also proposed other revisions and clarifications to the instructions. All proposed revisions
would have been effective for the September 30, 2022, report date for the FR Y-14Q and
FR Y-14M, and for the December 31, 2022, report date for the FR Y-14A.
General
The Board proposed to change the as of date of the fourth quarter, unstressed submissions
of FR Y-14Q, Schedules F (Trading) and L (Counterparty). Per the FR Y-14Q instructions, firms
are required to report these schedules the earlier of fifty-two calendar days following the date on
which they are notified of the global market shock (GMS) date, or March 15. The instructions
also state that unless the Board requires the data to be provided over a different weekly period,
firms may provide these data as of the most recent date that corresponds to their weekly internal
risk reporting cycle as long as it falls before the as of date. The Board proposed to revise the
instructions to allow firms to use the most recent date that corresponds to their weekly internal
risk reporting cycles as long as it falls within the same calendar week as the as of date. This
change would have provided firms with more flexibility in reporting these schedules and would
have corresponded to guidance provided in the Dodd-Frank Act Stress Test Publications: 2021
Stress Test Scenarios document.9
Capital
Savings and loan holding companies
On February 3, 2021, the Board adopted a final rule, 10 to tailor the requirements in the
Board’s capital plan rule 11 based on risk. As part of the final rule, the Board adopted several
revisions, notably that SLHCs would be subject to capital planning requirements beginning with
the 2022 stress testing and capital planning cycle (cycle). Previously, SLHCs were not required
to submit FR Y-14Q, Schedule C (Regulatory capital instruments) and Schedule D (Regulatory
capital) because they were not subject to capital planning requirements. However, given that
SLHCs are now subject to these requirements, the Board proposed to require SLHCs to submit
these schedules. 12 This revision would have aligned with the spirit of the capital plan rule.
9

See Board of Governors of the Federal Reserve System, Dodd-Frank Act Stress Test Publications: 2021 Stress
Test Scenarios (Washington: Board of Governors, February 2021),
https://www.federalreserve.gov/publications/stress-test-scenarios-february-2021.htm.
10
86 FR 7927 (February 3, 2021).
11
12 CFR 225.8.
12
SLHC requirements for submitting the capital information required in these schedules for the 2022 cycle is
forthcoming.

Assumptions associated with Comprehensive Capital Analysis and Review (CCAR)
submissions
The FR Y-14A, Schedule A (Summary) instructions describe when firms must use
“planned capital actions” and “alternative capital actions,” but do not define either term o r list
the required assumptions for reported capital actions. Because the Board did not release CCAR
instructions13 for the 2021 cycle, it instead issued a CCAR Q&A (GEN0500) that contained the
definitions and assumptions of capital actions required per the capital plan rule. The Board
proposed to incorporate the definitions and assumptions of “planned capital actions” and
“alternative capital actions” previously contained in CCAR Q&A GEN0500 into the FR Y-14A
instructions to provide clarity regarding the meaning of these terms.
Under the supervisory severely adverse (SSA) scenario CCAR submission, firms are
required to include the effects of planned business plan changes (BPCs) and use planned capital
actions. Per the Board’s capital rule, 14 if a firm does not stay above its minimum capital
requirements, including regulatory capital buffers that may encompass the SCB requirement,
then it is subject to automatic restrictions on capital distributions and discretionary bonus
payments. Requiring firms to assume that their planned BPCs and planned capital actions will
occur under stressed conditions has resulted in unrealistic projections, as some or all of the
planned capital actions would not be able to materialize if firms dropped into their regulatory
capital buffers over the course of the projection horizon. Under the Internal stress scenario, firms
are required to only include the effects of planned BPCs that the firm anticipates occurring, given
the scenario, and to use alternative capital actions. To improve comparability between the CCAR
Summary submissions under the Internal stress and SSA scenarios, the Board propose d to revise
the planned BPC and capital action assumptions of the Summary CCAR submission under the
SSA scenario to match those of the Internal stress scenario.
Firms are required to incorporate the effects of planned, material BPCs in their CCAR
submissions of the Summary schedule. The instructions did not specify whether firms must also
include the effects of planned, immaterial BPCs that firms anticipate occurring over the
projection horizon under baseline or stressed conditions. For clarity, the Board proposed to
revise the instructions to give firms the option to include the effects of planned, immaterial BPCs
in their CCAR Summary submissions. Inclusion of the effects of planned, material BPCs in
CCAR Summary submissions was still required.
Other proposed changes
The Board often provides firms the option to phase in the effects of new accounting
standards or other changes that affect the calculation of regulatory capital through the use of
transition provisions (e.g., transitioning the impact of current expected credit loss methodology
(CECL) adoption on regulatory capital). Firms must report regulatory capital items on
FR Y-14Q, Schedule D (Regulatory Capital) exclusive of the effects of transition provisions,
13

For an example of these instructions, see Board of Governors of the Federal Reserve System, Comprehensive
Capital Analysis and Review 2020 Summary Instructions (Washington: Board of Governors, March 2020),
https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200304a3.pdf.
14
12 CFR Part 217.

whereas regulatory capital items on FR Y-9C, Schedule HC-R (Regulatory Capital) may be
reported inclusive of transition provisions if firms elect to apply the transition provisions. As
described in the Dodd-Frank Act Stress Test 2021: Supervisory Stress Test Methodology
document,15 the Board adjusts the numerator and denominator of the supervisory stress test
capital calculations to align with the capital rule, which includes the effects of transition
provisions. To ensure consistency with regulatory capital balances that are used in the capital
calculations of the supervisory stress test and to improve comparability across the capital
schedules of the FR Y-14Q and FR Y-9C, the Board proposed to revise Schedule D to remove
the requirement that firms exclude the effects of transition provisions.
Firms currently report the carrying value of capital instruments at quarter-end in Column
I (Carrying value, as of quarter-end) of FR Y-14Q, Schedule C.1 (Regulatory capital instruments
as of quarter end). On this schedule, firms also report some components that affect the carrying
value, such as the fair value of swaps associated with the capital instrument (Column K). Not all
categories of components that affect the carrying value had their own item, and some
components may only be applicable to certain capital instruments. The Board proposed to add an
item to capture all other changes that affect the carrying value of an instrument that were not
currently captured by the existing component items. This item would have enhanced data
reconciliation efforts for Schedule C.1.
Firms report repurchases and redemptions on both FR Y-14A, Schedule C (Regulatory
capital instruments) and FR Y-14Q, Schedule C (Regulatory capital instruments). The
FR Y-14A, Schedule C instructions require firms to report repurchases and redemptions as
negative values. The FR Y-14Q, Schedule C instructions do not specify how to report
repurchases and redemptions, and so, there is diversity in practice across firms. For consiste ncy
between the reports, the Board proposed to require repurchases and redemptions to be reported
as negative values on FR Y-14Q, Schedule C.
Firms report dividends on FR Y-14A, Schedule A.1.d (Capital) and Schedule C. The
instructions for dividend items on Schedules A.1.d and C reference definitions on FR Y-9C,
Schedule HI-A (Changes in holding company equity capital). On Schedule HI-A, firms report
values on a year-to-date basis, while most items on Schedules A.1.d and C are reported on a
quarter-to-date basis. As a result, some firms reported dividend items on a year-to-date basis,
while others reported values on a quarter-to-date basis. To remove ambiguity, the Board
proposed to revise the instructions for the following items to specify that these items must be
reported on a quarter-to-date basis:
• “Cash dividends declared on preferred stock” (Schedule A.1.d, item 12; Schedule C item
116) and
• “Cash dividends declared on common stock” (Schedule A.1.d, items 13 and 117;
Schedule C, item 117).
Firms are required to report issuances of capital and subordinated debt instruments on
FR Y-14Q, Schedule C.3 (Regulatory capital and subordinated debt instruments issuances during
15

quarter). The instructions do not specify whether subordinated debt instruments that were
acquired must be reported on Schedule C.3. Such instruments were not issued by a firm but are
new to a firm’s balance sheet. Given that these instruments are new to a firm’s balance sheet, the
Board proposed to revise the instructions to state that subordinated debt instruments acquired via
a merger or acquisition must be reported on Schedule C.3. The Board proposed to further clarify
that firms must also report on Schedule C.3 situations in which a Committee on Uniform
Securities Identification Procedures (CUSIP) number for a subordinated debt instrument
changes, even if the terms of the instrument did not change. This revision would have ensured
that CUSIP number changes are properly captured.
Firms are required to report the unamortized discounts/premiums, fees, and foreign
exchange translation impacts as of quarter-end in Column J of FR Y-14Q, Schedule C.1.
However, there is inconsistency across firms in terms of whether discounts and premiums must
be reported as positive or negative values. To remove ambiguity, the Board proposed to clarify
that unamortized amounts of discounts must be reported as positive values and unamortized
amounts of premiums must be reported as negative values. These revisions would have
standardized the reporting of this item.
To further enhance data reconciliation efforts, the Board proposed to add four items to
FR Y-14Q, Schedule C.1. The specific items the Board proposed to add were:
• “Interest expense for the quarter (net of swaps),”
• “Interest expense for the quarter (with swaps, excluding any gains or losses due to the fair
value adjustment of ASC 185/FAS 133 hedges),”
• “Interest expense for the quarter (with swaps, this number should reconcile to the
quarterly number reported in FR Y-9C BHCK4397 for all subordinated debt
instruments),” and
• “Fair value adjustment at the quarter end for subordinated debt securities that are carried
at fair value.”
The addition of these items would have ensured that balances on Schedule C.1 are
properly reconciled for use in supervisory models. With the addition of these items, the Board
also proposed to remove the following four items from Schedules C.1 and C.3, as they would
have no longer been needed:
• “Y-9C BHCK4602 reconciliation” (Column N of Schedule C.1),
• “Currency of foreign exchange swap payment” (Column LL of Schedule C.3),
• “Notional amount of foreign exchange swap ($ Million)” (Column MM of Schedule C.3),
and
• “Exchange rate implied by foreign exchange swap” (Column NN of Schedule C.3).
Securities
Firms are required to report the amount of allowance for credit losses in FR Y-14Q,
Schedule B.1 (Securities 1 - main schedule). However, the instructions for this item do not
specify whether amounts must be reported as positive or negative values. To improve the
consistency of reporting across firms, the Board proposed to revise the instructions to indicate
that the allowance for credit losses on Schedule B.1 must be reported as a positive number. This

revision would have better enabled the Board to compare reported values, as all values would
have been reported in the same manner.
Trading
As mentioned in the Dodd-Frank Act Stress Test 2021: Supervisory Stress Test
Methodology document,16 the Board adjusts a firm’s trading profit and loss to estimate losses on
private equity investments in affordable housing that qualify as public welfare investments under
Regulation Y. The data used to make this adjustment is currently collected through a
supplemental collection, and the Board proposed to formalize this supplemental collection by
incorporating its key elements into FR Y-14Q, Schedule F.24 (Private equity). The proposal
would have required firms to isolate and report private equity exposures that qualify as public
welfare investments in new line items. The instructions would have specified that a public
welfare investment is defined as an equity investment in corporations or projects designed
primarily to promote community welfare, such as the economic rehabilitation and development
of low-income areas.17 Incorporating this supplemental collection into FR Y-14Q, Schedule F
(Trading) would have allowed for more standardized reporting, which is crucial to ensure private
equity investments in affordable housing that qualify as public welfare investments are treated
the same across firms.
The Board also proposed to make clarifications to the Schedule F instructions regarding
the reporting of accrual loan and fair value option (FVO) loan hedges across Schedule F, the
reporting of interest rate basis risk on Schedule F.6 (Rates DV01), and limiting the allowable
units used to report interest rate sensitivities on Schedule F.7 (Rates Vega). These clarifications
would have removed ambiguity around the reporting of hedges on Schedule F and would have
standardized reporting of interest rate information, which would have improved data
comparability across firms.
Counterparty
Client-cleared derivative exposures
Beginning with the June 30, 2021, as of date, firms were required to include clientcleared derivative exposures in FR Y-14Q, Schedule L (Counterparty). 18 Exposures to clientcleared derivatives are excluded from the calculation of stressed losses. As part of Schedule L.5
(Derivatives and securities financing transaction profile), firms are required to rank their top 25
exposures by certain counterparty methodologies. Client-cleared derivative exposures are
currently excluded from these rankings. The Board proposed to require firms to rank their top 25
16

See Board of Governors of the Federal Reserve System, Dodd-Frank Act Stress Test 2021: Supervisory Stress
Test Methodology (Washington: Board of Governors, April 2021),
https://www.federalreserve.gov/publications/files/2021-april-supervisory-stress-test-methodology.pdf.
17
For reporting public welfare investments made at the bank holding company level, an affordable housing private
equity investment would be recognized by the Federal Reserve if it also qualifies under 12 CFR 225.28(b)(12) and
12 CFR 225.127. For reporting public welfare investments made at the bank level, an affordable housing private
equity investment would be recognized by the Federal Reserve if it also qualifies under the applicable public welfare
investment criteria of the bank’s primary Federal regulator.
18
85 FR 56607 (September 14, 2020).

exposures for client-cleared derivatives on Schedule L.5. This new ranking would have enabled
the Board to continue to exclude exposures to client-cleared derivatives from the calculation for
stressed losses and would have provided more insight into the size and diversity of these
exposures. As part of this revision, the Board would have also modified the instructions to
reinforce that exposures to client-cleared derivatives must be excluded from other top 25
rankings.
Counterparty identification
Firms are required to report counterparty attribute information (e.g., legal entity identifier
(LEI), industry code, etc.) at the counterparty legal entity level on FR Y-14Q, Schedule L. The
Board proposed to require firms to report counterparty attribute information at the
consolidated/parent level in addition to the counterparty legal entity level. Collecting this
information at the consolidated/parent level would have enabled the Board to better identify
exposures to parent and subsidiary entities within the same organizational structure, which would
have allowed for a more robust analysis of counterparty exposure. This more robust analysis
would have improved the Board’s ability to evaluate the counterparty risk faced by firms.
Additional/offline credit valuation adjustment (CVA) reserves
Firms are currently required to report “trades not captured” in the “Additional/offline
CVA Reserves” item of FR Y-14Q, Schedule L.1.e (Aggregate CVA data by ratings and
collateralization). “Trades not captured” refers to trades or counterparties for which CVA is
computed outside of a firm’s regular CVA system, which could occur due to the complexity or
novelty of a particular trade. Such trades would not be captured in Schedules L.2 (EE [Expected
exposure] profile by counterparty) or L.3 (Credit quality by counterparty) due to the custom
CVA approximation methodology of these trades. The instructions for the “Additional/offline
CVA Reserves” item require firms to report exposures to counterparties only at the aggregate
level. Several firms report significant portions of their counterparty exposures as
additional/offline CVA reserves. The Board proposed to require firms to report these exposures
by rating, which is more granular than the current requirements, to better understand, identify,
and monitor risks associated with exposures reported in this item. Such data would have
provided a more complete picture of counterparty exposures at firms with significant amounts
reported as additional/offline CVA reserves.
Unstressed vs. stressed counterparty submissions
Firms are required to report unstressed data on Schedule L quarterly and are required to
report stressed data on this schedule annually. The Schedule L instructions note that for
unstressed submissions, firms must only include exposures in certain sub-schedules for which
the firm computes CVA for its public financial statement reported under U.S. generally accepted
accounting principles (U.S. GAAP) or applicable standard. However, for stressed submissions,
firms must also include transactions that would not typically require CVA for public financial
statement reporting under U.S. GAAP or applicable standard (e.g., fully- or over- collateralized
derivatives). Therefore, the scope of reported exposures is larger for stressed submissions.

The scope of reported exposures on FR Y-14Q, Schedule L expanded for data as of June
30, 2020, to include securities financing transactions (SFTs). 19 This additional scope of
transactions increases the divide between the transactions reported on unstressed submissions
compared to those reported on stressed submissions. As a result of this greater divide and to
better compare the impact of stressed conditions on a firm’s counterparty exposures, the Board
proposed to require aggregate unstressed CVA related exposures to be reported together with
stressed exposures in Schedule L.1.e. This data would have given the Board a more complete
understanding of firms’ counterparty credit risk, as it would have enabled the Board to directly
compare the same exposures under unstressed and stressed conditions.
Wrong-way and right-way risk
Across Schedule L, firms are required to report wrong-way risk and right-way risk
exposures. Wrong-way risk arises when the exposure to a counterparty is adversely correlated
with the credit quality of that counterparty. Right-way risk occurs when this situation is reversed.
When wrong-way risk is directly connected to a particular counterparty (e.g., the counterparty’s
rating was downgraded), it is referred to as specific wrong-way risk. Due to questions received
from reporting firms, the Board proposed to clarify how to report occurrences of specific wrongway risk. The Board proposed to require firms to assume zero for the value of the received
collateral during the calculation of both stressed and unstressed net current exposure when
specific wrong-way risk is present in the collateral. This revision would have aligned with the
principle of conservatism in the Board’s Stress Testing Policy Statement. 20
The Board also proposed to incorporate the response to FR Y-14 Q&A Y140001374 to
remove ambiguity regarding the reporting of right-way risk on Schedule L. Specifically, the
Board would have revised the instructions to require firms to exclude stressed exposures on
trades where the exposure is eliminated upon default of the counterparty. This revision would
have ensured that only true exposures are captured on Schedule L.
Discount factor
Firms are required to report the discount factor used to calculate stressed and unstressed
CVA on Schedule L.2. The instructions for this item mention the London Interbank Offered Rate
(LIBOR), which was discontinued at the end of 2021. Given this, th e Board proposed to
generalize the language to instead mention the reference or benchmark rate used to discount the
expected exposure in a firm’s CVA model. This revision would have allowed for more flexibility
since LIBOR was discontinued.
Unique identifiers
The general instructions of Schedule L state that unique identifiers (e.g., Counterparty
ID) and names must be consistent across all sub-schedules. However, the Board had identified
several cases in which this requirement has not been met. To reinforce this requirement, the
Board proposed to add language to the instructions for Schedules L.2 and L.3 to remove any
19
20

84 FR 70529 (December 23, 2019).
Appendix B of 12 CFR 252.

potential uncertainty in reporting unique identifiers. This revision would have resulted in more
consistent reporting across Schedule L.
Collateral
Firms are required to report the total unstressed mark-to-market value of collateral of
derivatives on Schedule L.5.1 (Derivative and SFT information by counterparty legal entity and
netting set/agreement). The instructions note that all collateral reported must be eligible financial
collateral. The response to FR Y-14 Q&A Y140001155 clarified that eligible financial collateral
refers to the definition of “financial collateral” in the Board’s capital rule. 21 To mitigate
confusion, the Board proposed to incorporate the response to Q&A Y140001155 into the
Schedule L.5.1 instructions.
Firms are also required to report the type of non-cash collateral or initial margin (e.g.,
corporate debt) allowed under a given agreement in the “Non-Cash Collateral Type” item of
Schedule L.5.1. The instructions for this item only mention posted collateral in terms of what
must be reported. In response to questions from reporting firms, the Board proposed to require
firms to include all non-cash collateral or initial margin that was posted or received in actuality
as opposed to only those allowed under a given agreement. This revision would have reduced
ambiguity surrounding what to report and would also have provided the Board with a more
encompassing view of the non-cash collateral involved in applicable transactions. This more
encompassing view would have resulted in more accurate loss calculations and would have
enhanced risk monitoring.
Credit Support Annexes (CSAs)
On Schedule L.5.1, firms are required to indicate in the “CSA contractual features (nonvanilla)” item whether any transactions conducted under a given CSA agreement have any nonvanilla contractual features (e.g., downgrade triggers). However, the instructions for this item do
not specify how firms should report transactions that have vanilla contractual features. The
Board proposed to clarify that for such transactions, firms must report “NA” in this item.
Due to questions from reporting firms, the Board also proposed to clarify that the “CSA
contractual features (non-vanilla)” item applies to any non-standard market terms inclusive of
features such as minimum threshold amounts (MTAs), changes to MTAs, additional termination
events, and ratings-based thresholds. This revision would have removed uncertainty regarding
what features are considered non-vanilla for purposes of this item.
Reporting scope
On Schedules L.1-L.3, top counterparties are identified based on the exposure amount at
a consolidated counterparty level for ranking purposes in determining top 95% stressed or
unstressed CVA. The Board had received several questions regarding the scope of this reporting,
including consistency across schedules. To remove ambiguity, the Board proposed to clarify that
if a consolidated or parent counterparty is selected as top 95% of CVA, then a firm’s exposures
21

12 CFR 217.2.

to all the counterparties and legal entities associated with the consolidated or parent counterparty
must be included and reported in L.1 (Derivatives profile by counterparty and aggregate across
all counterparties), rather than including only counterparties and legal entities with which the
firm has a CVA. In comparison, the firm can report in Schedules L.2 and L.3 the exposure
information limited to the legal entities and/or netting sets with which the firm has a CVA. These
revisions would have provided a more complete view of counterparty exposures faced by firms
and would have incorporated responses to FR Y-14 Q&As Y140001180 and Y140001190 into
the Schedule L instructions.
Per FR Y-14 Q&A Y140001181, Schedules L.1.a and L.1.b (Top consolidated/parent
counterparties comprising 95% of firm unstressed CVA, ranked by unstressed and stressed CVA,
respectively) must be reported at the legal entity level, at a minimum. This is also true for
Schedules L.2 and L.3. The Board had received several questions from reporting firms regarding
providing data at the netting set or sub-netting level. In light of these questions, the Board
proposed to clarify that firms may choose to report these schedules at the netting set or subnetting set level. Note that the Schedule L instructions specify that if a firm chooses to report one
of these schedules at the netting set or sub-netting set level, then it must report all of them at that
level.
Gross current exposure
In several places on Schedule L.1, firms are required to report the gross current exposure
of given transactions. Gross current exposure is defined as pre-collateral exposure after bilateral
counterparty netting. The Board had received questions from reporting firms on whether fairvalued SFTs should be in scope for reporting in the gross current exposure items. The
questioners noted that the definition provided applies to derivatives but does not apply to SFTs.
The response to FR Y-14 Q&A Y140001279 clarified that gross current exposure items only
apply to derivatives and must be left blank for SFTs. The Board proposed to incorporate this
response into the Schedule L.1 instructions.
Minimum transfer amounts
Firms are required to report the minimum amounts that must be transferred to the
counterparty and to the reporting firm in the event of a margin call in Schedule L.5.1. Due to
observed diversity in reporting, the Board proposed to specify that firms must report the U.S.
dollar equivalent of values reported in these items, as opposed to the non-U.S. dollar local
currency associated with a particular CSA. This revision would have standardized the units
reported in this item and improved comparability across exposures.
Other revisions
The instructions for Schedule L.5 state that for positions with no legal netting set
agreement, mark-to-market amounts can be aggregated and reported as a single record. The
instructions further state that firms must report “N” in the “Legal Enforceability” item and
“None” in the “Netting Set ID” item for such aggregated records. In the case of the “Legal
Enforceability” item, these instructions are redundant and in the case of the “Netting Set ID”

item, they conflict with language provided later in the Schedule L.5 instructions. The Board
proposed to remove the redundant and conflicting language from Schedule L.5, which would
have clarified that firms must only report “NA” in the “Netting Set ID” item for positions with
no legal agreement. This revision would have incorporated the response from FR Y-14 Q&A
Y140001383 into the Schedule L instructions.
Firms are required to report mark-to-market amounts that reflect the positive or negative
contribution to an exposure upon counterparty default and close-out netting in Schedule L.5. The
Board had received questions from reporting firms about whether this language applies to both
derivatives and SFTs. Reporting firms had also asked the Board how to report in line with the
instructions in cases where close-out netting for SFTs is not enforceable (i.e., the SFT mark-tomarket received cannot be netted against the amount posted when calculating current exposure).
The response to FR Y-14 Q&A Y140001386 clarified that the language regarding reporting
mark-to-market amounts that reflect the positive or negative contribution to an exposure upon
counterparty default and close-out netting only applies to derivatives and not to SFTs. This
FR Y-14 Q&A also clarified that firms must report zero in cases where the SFT close-out netting
is not enforceable. The Board proposed to incorporate the response in FR Y-14 Q&A
Y140001386 into the instructions by (1) revising the Schedule L.5 general instructions to specify
that the language reflecting the positive or negative contribution to exposure upon counterparty
default only applies to derivatives, and (2) revising the “Unstressed Mark -to-Market Received
(SFTs)” and “Stressed Mark-to-Market Received (SFTs)” items of Schedule L.5.1 to specify that
in cases where the close-out netting is not enforceable, firms must report zero. Relatedly, since
the Board proposed to revise the Schedule L.5 general instructions to specify reporting for
derivatives, the Board also proposed to revise the instructions for the stressed and unstressed
mark-to-market received and posted SFT items on Schedule L.5.1 to clarify that these items must
be reported as positive values.
Firms became required to include exposures to client-cleared derivatives in Schedule L.5
for the June 30, 2021, as of date. As part of this requirement, firms must report SFT exposures
when a firm acts as an agent on behalf of a client for which lender indemnification has been
provided against the borrower’s default. Due to observed diversity in reporting practices, the
Board proposed to revise the Schedule L.5 instructions to clarify that firms must also include
SFT exposures when the firm acts as an agent on behalf of a client for which a credit guarantee
has been provided against the borrower’s default. This revision would have reinforced the
original intent of adding the reporting of exposures to client-cleared derivatives to Schedule L.5,
in that it would have required firms to report their indirect exposures to clients when credit risk is
present, regardless of whether that exposure arises from a lender indemnification or a credit
guarantee.
Firms are required to report stressed CVA values on Schedules L.1 and L.5.1. On
Schedule L.1, the instructions state that firms must report the full revaluation of asset-side CVA
under stressed conditions. On Schedule L.5.1, the instructions state that firms must only include
stressed CVA as it relates to derivatives. For consistency across Schedule L, the Board proposed
to revise the “Stressed CVA” item of Schedule L.5.1 to require firms to include stressed CVA as
it relates to SFTs, as well as continue to include stressed CVA as it relates to derivatives. This
revision would have allowed the Board to get a more complete and consistent picture of CVA

exposure across reporting firms.
Wholesale
Internal risk rating
Firms began reporting FR Y-14Q, Schedule H.4 (Internal risk rating) as of March 31,
On this schedule, firms are required to report the ratings used in their internal risk rating
system, as well as a description of each rating. There has been a wide variety of internal ratings
and descriptions provided, which has made evaluations across f irms difficult. To improve
comparability of internal ratings reported in this schedule, the Board proposed to add three items:
minimum probability of default, maximum probability of default, and the calculation method of
the probability of default (i.e., calculated through the cycle or as a point-in-time value). The
minimum and maximum probability of default items would have allowed the Board to assess
credit risk more easily across firms by providing benchmark values for internal ratings. The type
of probability of default item would have provided critical information for how the minimum and
maximum values are calculated (e.g., point in time calculation). The addition of these items
would have enhanced wholesale risk monitoring.
2020.22

Undrawn commitments
Firms are required to report the interest rate charged on the credit facility for corporate
and commercial real estate (CRE) loans on FR Y-14Q, Schedule H.1 and H.2, items 38 and 27,
respectively. The instructions require the reporting of the most conservative interest rate for fully
undrawn facilities, which was intended to accommodate a scenario in which there are multiple
interest rate options, and the actual interest rate would not be known until the loan was drawn.
However, reporting firms asked how to report a second scenario where a facility is comprised of
multiple lines of credit, each with a separate interest rate. The Board proposed to clarify the
reporting requirements for these two scenarios in the instructions to improve consistency and
mitigate confusion. For the first scenario, the Board proposed to clarify that the instruction to
report the most conservative interest rate only applies to situations where the obligor has a choice
of interest rates and one is chosen when the line is drawn. For the second scenario, the
instructions would have required firms to report the dollar-weighted average interest rate that
approximates the overall rate as if the credit facility were funded and fully drawn on the
reporting date.
Update property type options
Firms currently report the property type of their CRE loans on FR Y-14Q, Schedule H.2,
in item 9 (Property Type). While this item contains multiple property type options, the structure
of the CRE market has changed since these initial property type options were implemented for
this item. More specifically, over the past decade, there has been rapid growth in the healthcare
and assisted living industry, resulting in demographic changes, as well as in e-commerce
platforms, which rely on warehouses for storage. The existing property type options do not
separately break out these industries, and these CRE loans are commingled with other property
22

84 FR 70529 (December 23, 2019).

types in other options. The Board proposed to update the property type options to include
“Healthcare/Assisted Living” and “Warehouse/Distribution.” This revision would have improved
risk identification within the CRE portfolio.
Clarify informal “Advised Lines” exclusion
On FR Y-14Q, Schedule H.1, the instructions for corporate loan population state to
exclude informal “advised lines,” but the current definition of this term is ambiguous, potentially
resulting in the exclusion of more commitments than there should be. The Board propose d to
modify the language to clarify that only lines of credit that are unknown to the customer must be
excluded from Schedule H.1. This modification would have ensured that all applicable
commitments are reported, other than the clearly defined exclusions.
Retail
Credit score reporting requirements
Firms are required to report the origination credit bureau score for the primary account
holder and the refreshed credit bureau score for domestic credit card account holders on
FR Y-14M, Schedule D (Domestic credit card) in items 38 and 40, respectively. For both items,
the instructions allow firms to map an internal credit score used to determine the primary account
holder’s creditworthiness to a commercial credit score for cases in which a commercial credit
score was not obtained or was not being used to evaluate the creditwo rthiness of the primary
account holder. The ability to map an internal credit score to a commercial credit score has
resulted in reporting inconsistencies, due to the subjectivity of the mapping. To standardize the
reporting of credit scores, the Board proposed to revise the language in the instructions for both
items to require firms to report a commercial credit score if one was available at origination or
refresh for the primary account holder. The Board proposed to further revise the instructions to
state that if a commercial credit score was not available at the time of origination or refresh and
if the underwriting decision was based on an internal score, then firms would have been required
to map their internal credit scores to commercial credit scores.
Firms are also required to report the FICO score range of the credit score of the borrower
at origination in the “Original commercially available credit bureau score or equivalent” segment
variable on all sub-schedules of FR Y-14Q, Schedule A (Retail). The instructions for this
segment variable allow the reporting of an internal credit score mapped to a commercial credit
score if an internal score was used in the original underwriting decision. To also standardize
credit score reporting on Schedule A, the Board proposed to require firms to report a commercial
credit score if one was available at origination. Firms would have been required to map their
internal credit scores or non-FICO commercial credit scores to FICO credit scores if a FICO
credit score was not available at origination. Additionally, the instructions for this segment
variable require firms to report in FICO credit score ranges and state that upon request, the
Federal Reserve will provide ranges for other commercial credit scores. However, to further
standardize the reporting of credit scores, the Board proposed to remove this sentence from the
instructions. Removing this sentence would have required firms to create their own mappings
from their internal credit scores or from non-FICO commercial credit scores to FICO credit

scores.
Loans in forbearance or other loss mitigation situations
The coronavirus pandemic (COVID event) caused an increase in loans in forbearance or
other loss mitigation situations (collectively, loss mitigation). These loans have different risk
characteristics than other loans reported on the FR Y-14M. While there are some loss mitigation
items on the FR Y-14M, the Board observed during the COVID event that there were still data
gaps, and several loss mitigation items did not have the flexibility to capture loss mitigation in
the face of occurrences such as the COVID event. To fill observed data gaps, the Bo ard proposed
to add a “Workout Type Started” item to Schedule A (Domestic first lien) and Schedule B
(Domestic home equity), as well as an “Actual Payment Amount” item to Schedule A. The
“Workout Type Started” item would have been used in conjunction with the “Workout Type
Completed” item (Schedule A, item 77; Schedule B, item 61) and would have allowed the Board
to track any changes to the loss mitigation plans of the loan once a loan had undergone loss
mitigation. The “Actual Payment Amount” item would have allowed the Board to track actual
payments made on loans, which would have enabled the Board to better monitor activity on
loans in loss mitigation. Note that this item was only proposed to be added to Schedule A
because an equivalent item already existed on Schedule B (item 68).
Firms are required to report the principal deferred amount and the principal write-down
amount in items 87 and 89, respectively, of Schedule A. Per the instructions, these items are only
reported if the loan has been modified. During the COVID event, certain loans were not
modified but did experience principal deferrals and write-downs. However, these amounts were
not reported on Schedule A due to the requirement that the loans be modified. To expand the
circumstances under which firms would report these items, the Board proposed to remove the
requirement that these items only be reported if loans are modified. Relatedly, the Board
proposed to rename item 87 to “Deferred Amount” to capture all deferred amounts, not just those
related to the loan principal.
Finally, the Board proposed to revise the reporting options to the “Modification Type”
and “Workout Type Completed” items (Schedule A, items 74 and 77, respectively; Schedule B,
items 77 and 61, respectively) to add flexibility to enable these items to apply to a broader set of
occurrences, such as the COVID event. These revisions would have enabled the Board to better
monitor loss mitigation loans.
Other revisions
Firms currently flag whether portfolio loans are held-for-investment (HFI) and measured
at fair value under the FVO or are held-for-sale (HFS) in item 130 (HFI FVO/HFS Flag) of
Schedule A. However, the actual fair-value amount is not reported on Schedule A. Firms are
required to report the aggregate fair-value amounts of HFS loans and HFI loans measured under
the FVO on FR Y-14Q, Schedule J (Retail FVO/HFS). For data reconciliation across the
FR Y-14M and FR Y-14Q, as well as for monitoring purposes, the Board proposed to add a new
field to Schedule A to capture the fair-value amount of HFS loans and HFI loans measured under
the FVO.

Additionally, on both Schedule A and Schedule B, there is an item that captures the
adjustable-rate mortgage (ARM) index (Schedule A, item 32; Schedule B, item 29). This item
did not include options for the Bloomberg Short-Term Bank Yield (BSBY) rate. The Board
proposed to revise this item to include several “BSBY” options, to allow firms to identify loans
using this index rate.
The Board also proposed to remove several items from Schedule A, as they were no
longer needed, assuming that the aforementioned revisions to Schedule A were implemented
(items proposed for removal would have been redundant). Specifically, the Board proposed to
remove the following items:
• “Capitalization” (item 81),
• “Duration of Modification” (item 83),
• “Interest Rate Reduced” (item 98),
• “Term Extended” (item 100),
• “P&I Amount Before Modification” (item 101),
• “P&I Amount After Modification” (item 102),
• “Remaining Term Before Modification” (item 105), and
• “Remaining Term After Modification” (item 106).
Firms are required to report the cohort default rate (CDR) of student loans on FR Y-14Q,
Schedule A.10 (Student Loan). There are several CDR buckets, one of which requires reporting
in cases in which the CDR is greater than 10 percent (item 16). However, the instructions did not
specify how to report cases when the CDR is equal to 10 percent. For completeness, the Board
proposed to rename and revise item 16 to clarify that firms must also include in this item
balances for which the CDR equals 10 percent.
Balances
Firms are required to report quarter-end balances of bank cards and charge cards on
FR Y-14Q, Schedule M.1 (Quarter-end balances) in items 3.a and 3.b, respectively. The
instructions did not define bank or charge cards, but in general, bank cards and charge cards
differ in two key ways. First, bank cards allow holders to spend up to their credit limits during
each billing cycle, while charge cards typically have no preset spending limits. Second, ban k
cards allow holders to pay outstanding balances over time, while charge cards must be fully paid
off each billing cycle. There are some products that have features of both bank and charge cards,
in that only a portion of the outstanding balance can be rolled over to the next billing cycle.
Products with features of both bank and charge cards have caused inconsistent reporting across
firms. To remove ambiguity, the Board proposed to better clarify which products must be
reported as charge cards in the instructions.
Firms are required to report quarter-end balances of small/medium enterprise (SME)
cards in item 2.c (SME cards and corporate cards) on Schedule M.1. The instructions define
SME cards as “credit card accounts where the loan is underwritten with the sole proprietor or
primary business as an applicant.” The instructions also refer to several FR Y-9C items where
SME cards and corporate cards are reported. Firms are required to report the applicable balances
of SME cards and corporate cards in item 2.c that are reported in the referenced FR Y-9C items.

The item 2.c instructions do not reference FR Y-9C, Schedule HC-C, item 9.a (Loans to
nondepository financial institutions). Upon review, the Board determined that certain card
balances reported in Schedule HC-C, item 9.a could be included in Schedule M.1, item 2.c.
Therefore, the Board proposed to revise the instructions for Schedule M.1, item 2.c to reference
Schedule HC-C, item 9.a.
Time Schedule for Information Collection
The following tables outline, by schedule and reporting frequency (annually, quarterly, or
monthly), the as of dates for the data and their associated due date for the current submissions to
the Board.
Schedules and
Sub-schedules

Summary,
Macro Scenario

Submission Date
to Federal Reserve

Data as of date

FR Y-14A Filings
• Data are due April 5 th of the
following year.
• Adjusted summary schedule
submission: The Federal Reserve
will notify companies at least 14
calendar days in advance of the
• Data as of
date on which it expects
December 31 st.
companies to submit any adjusted
capital actions.

Operational Risk,
Business Plan Changes,
and Collection of
Supplemental CECL
Information schedules

• Data as of
December 31 st.

CCAR Market Shock
exercise
Summary schedule
• Trading Risk
• Counterparty

Data as of a
specified date in the
first quarter. As of
date would be
communicated by
Federal Reserve. 23

Upon resubmission of a firm’s capital
plan:
• As required.
• Data are due April 5 th of the
following year.
Upon resubmission of a firm’s capital
plan:
• As required.
•

Data are due April 5 th.

Upon resubmission of a firm’s capital
plan:
• As required.

As outlined in section 252.144 (Annual Stress Tests) of Regulation YY (12 CFR 252) and section 238.143 of
Regulation LL (12 CFR 238), the as of date will be October 1 of the calendar year preceding the year of the stress
test cycle to March 1 of the calendar year of the stress test cycle and will be communicated to the BHCs and
SLHCs by March 1st of the calendar year. BHCs and SLHCs are permitted to submit the CCR schedule and the
Trading and CCR sub-schedules of the Summary schedule as-of another recent reporting date prior to the supplied
as-of date as appropriate.

Regulatory Capital
Instruments

Schedules
Retail,
Securities,
Regulatory
Capital
Instruments,
Regulatory
Capital,
Operational
Risk,
PPNR,
FVO/HFS,
Supplemental,
Wholesale
Risk,
and
Balances

• Data as of
December 31 st.

Firm Category

All firms

•

Original submission: Data are due
April 5 th of the following year.
• Adjusted submission: The Federal
Reserve will notify companies at
least 14 calendar days in advance
of the date on which it expects
companies to submit any adjusted
capital actions.
• Incremental submission: At the
time the firm seeks approval for
additional capital distributions
pursuant to 12 CFR 225.8(j) or
within 15 days after making any
capital distribution approved
pursuant to that section or a capital
distribution in excess of the firm’s
final planned capital distributions.
Upon resubmission of a firm’s capital
plan:
• As required

Frequency

Data as of
date
FR Y-14Q Filings

Submission Date
to Board

Quarterly

Data are due seven
calendar days after the
FR Y-9C reporting
schedule (52 calendar
days after the calendar
quarter-end for
December and 47
calendar days after the
calendar quarter-end
for March, June, and
September).

Quarter-end

Trading
Counterparty

All firms

Quarterly

Fourth Quarter Trading and
Counterparty
regular/unstressed
submission: 52
calendar days after the
notification date
(notifying respondents
of the as of date) or
March 15, whichever
comes earlier. Unless
the Board requires
the data to be
provided over a
different weekly
Fourth
period, BHCs,
Quarter:
SLHCs, and IHCs may
GMS as of
provide these data as
date for all
of the most recent date
exposures
that corresponds to
except
their weekly internal
Trading FVO risk reporting cycle as
Loan Hedges, long as it falls within
which must
the same week as the
be reported as as of date.
of calendar
quarter-end.
Fourth quarter –
Counterparty stressed
All Other:
GMS submission:
Quarter-end. April 5 th.
All other: 47 calendar
days after the calendar
quarter-end (Seven
days after the
FR Y-9C reporting
schedule).
Upon resubmission of
a firm’s
capital plan –
Counterparty
stressed GMS
submission: as
required

Schedules

All schedules

Data as of date

Submission Date
to Board

FR Y-14M (Monthly Filings)
The last business day
By the 30 th calendar day of the
of each calendar
following month.
month.

Public Availability of Data
No data received through this information collection is made available to the public.
Legal Status
The Board has the authority to require BHCs to file the FR Y-14 reports pursuant to
sections 5(b) and 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. §§
1844(b) and 1844(c)) and section 165(i) of the Dodd-Frank Wall Street Reform and Consumer
Protection Act (Dodd-Frank Act) (12 U.S.C. § 5365(i)) as amended by sections 401(a) and (e) of
the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). Section
5(b) of the BHC Act authorizes the Board to issue regulations and orders relating to capital
requirements for bank holding companies. Section 5(c) of the BHC Act authorizes the Board to
require a BHC and any subsidiary of such company to submit reports to keep the Board informed
of its financial condition, systems for controlling financial and operating risks, transactions with
depository institution subsidiaries of the BHC, and compliance with law. Section 165(i)(1) of the
Dodd-Frank Act, as amended by the EGRRCPA, requires the Board to conduct supervisory
stress tests of certain companies. 24 Further, section 165(i)(2) of the Dodd-Frank Act, as amended
by the EGRRCPA, requires the Board to issue regulations requiring certain companies to
conduct company-run stress tests. 25
The Board has authority to require SLHCs file the FR Y-14 reports pursuant to section
10(b) of the Home Owners’ Loan Act (HOLA) (12 U.S.C. § 1467a(b)) as amended by section
369(8) and 604(h)(2) of the Dodd-Frank Act. Section 10(b) of HOLA, as amended, authorizes
the Board to require savings and loan holding companies to file “such reports as may be required
by the Board” containing “such information concerning the operations of such savings and loan
holding company … as the Board may require.”

See 12 U.S.C. § 5365(i)(1). Annual supervisory stress tests are required for bank holding companies with $250
billion or more in total consolidated assets. “Periodic” supervisory stress tests are required for bank holding
companies with $100 billion or more, but less than $250 billion, in total consolidated assets. 12 U.S.C. § 5365 note.
25
See 12 U.S.C. § 5365(i)(2). Bank holding companies with $250 billion or more in total consolidated assets and
financial companies with more than $250 billion in total consolidated assets must conduct “periodic” stress tests.

The Board has authority to require IHCs file the FR Y-14 reports pursuant to section 5(c)
of the BHC Act (12 U.S.C § 1844(c)) and sections 102(a)(1) and 165 of the Dodd-Frank Act
(12 U.S.C. §§ 5311(a)(1) and 5365).26 In addition, section 401(g) of EGRRCPA (12 U.S.C. §
5365 note) provides that the Board has the authority to establish enhanced prudential standards
for foreign banking organizations with total consolidated assets of $100 billion or more, and
clarifies that nothing in section 401 “shall be construed to affect the legal effect of the final rule
of the Board... entitled ‘Enhanced Prudential Standard for [BHCs] and Foreign Banking
Organizations’ (79 FR 17240 (March 27, 2014)), as applied to foreign banking organizations
with total consolidated assets equal to or greater than $100 million.”27 The FR Y-14 reports are
mandatory.
The information reported in the FR Y-14 reports 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)).28
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System with regard to the
proposed FR Y-14A/Q/M revisions.
Public Comments and Adopted Revisions
On March 1, 2022, the Board published an initial notice in the Federal Register (87 FR
11432) requesting public comment for 60 days on the extension, with revision, of the FR Y-14
reports. The proposed revisions would have enabled the Board to better identify risks not
currently captured in the stress test, facilitate data reconciliation, and mitigate ambiguity within
Section 102(a)(1) of the Dodd-Frank Act (12 U.S.C. § 5311(a)(1)), defines “bank holding company” for purposes
of Title I of the Dodd-Frank Act to include foreign banking organizations that are treated as bank holding companies
under section 8(a) of the International Banking Act of 1978 (12 U.S.C. §3106(a)). The Board has required, pursuant
to section 165(b)(1)(B)(iv) of the Dodd-Frank Act (12 U.S.C. § 5365(b)(1)(B)(iv)), certain foreign banking
organizations subject to section 165 of the Dodd-Frank Act to form U.S. intermediate holding companies.
Accordingly, the parent foreign-based organization of a U.S. IHC is treated as a BHC for purposes of the BHC Act
and section 165 of the Dodd-Frank Act. Because section 5(c) of the BHC Act authorizes the Board to require reports
from subsidiaries of BHCs, section 5(c) provides authority to require U.S. IHCs to report the information contained
in the FR Y-14 reports.
27
The Board’s Final Rule referenced in section 401(g) of EGRRCPA specifically stated that the Board would
require IHCs to file the FR Y-14 reports. See 79 FR 17240, 17304 (March 27, 2014).
28
Note that the Board may disclose a summary of the results of supervisory stress testing pursuant to 12 CFR
225.8(h)(5)(iii) and publishes a summary of the results of stress testing pursuant to 12 CFR 252.46(b) and 12 CFR
238.134, which includes aggregate data. In addition, under the Board’s regulations, covered companies must also
publicly disclose a summary of the results of stress testing. See 12 CFR 252.58; 12 CFR 238.146. The public
disclosure requirement contained in 12 CFR 252.58 for covered BHCs and covered IHCs is separately accounted for
by the Board in the Paperwork Reduction Act clearance for FR YY (OMB No. 7100-0350) and the public disclosure
requirement for covered SLHCs is separately accounted for by the Board in the Paperwork Reduction Act clearance
for FR LL (OMB No. 7100-0380).
26

the instructions. The comment period for this notice expired on May 2, 2022. The Board received
three comment letters from banking organizations and one comment letter from a banking
industry group. The Board has adopted the proposed revisions, except as discussed below. On
August 26, 2022, the Board published a final notice in the Federal Register (87 FR 52560).
General
The Board proposed to implement revisions to the FR Y-14Q and FR Y-14M effective
for the September 30, 2022, as of date, and revisions to the FR Y-14A effective for the
December 31, 2022, as of date. To allow firms time to adequately implement, test, and confirm
that they comply with the new reporting requirements, one commenter asked that all FR Y-14Q
and FR Y-14M revisions be delayed from the proposed implementation date of September 30,
2022, until June 30, 2023 (or later), and another commenter requested implementation of these
revisions be postponed until the September 30, 2023, as of date.
The Board is cognizant of firm burden as it relates to regulatory reporting. Some of the
proposed changes are critical for the supervisory stress test and so need to be implemented in
time for use in the 2023 supervisory stress test. Unless otherwise specified, the Board has
adopted revisions as proposed, effective for the September 30, 2022, as of date for the FR Y-14Q
and FR Y-14M and effective for the December 31, 2022, as of date for the FR Y-14A. However,
to reduce firm burden, the Board has delayed some of the revisions to FR Y-14Q, Schedule H
(Wholesale) and all the revisions to FR Y-14Q, Schedule L (Counterparty) until the June 30,
2023, as of date.
Counterparty
Client-cleared derivatives
On FR Y-14Q, Schedule L.5 (Derivatives and Securities Financing Transactions (SFT)
Profile), firms are required to rank their top 25 counterparties by certain counterparty
methodologies (methodology #1). The Board proposed to also require firms to rank their top 25
counterparties based purely on exposures to client-cleared derivatives (methodology #2), and to
exclude such exposures from methodology #1. Additionally, the Board proposed adding
language to the Schedule L.5 instructions requiring firms to incorporate all relevant clientcleared derivative exposures for all items in Schedule L.5, once the top 25 counterparties from
methodology #1 have been identified.
One commenter did not support these proposed revisions for two reasons. First, the
commenter noted that the Board already receives granular information on client-cleared
derivatives throughout Schedule L.5 and stated that it would be burdensome for firms to provide
the granular data on client-cleared derivatives necessary to rank them.
Second, the commenter asserted that exposures to client-cleared derivatives are currently
excluded from FR Y-14A, Schedule A.5 (Counterparty Credit Risk), item 3 (Counterparty
Default Losses) and 3.a (Impact of Counterparty Default Hedges). Therefore, as propo sed, firms
would be required to maintain dual processes for providing counterparty exposures on the

FR Y-14A and FR Y-14Q reports. The commenter asserted that these dual processes, combined
with the difficulties in maintaining two ranking methodologies described above, would be
burdensome to firms, and that, since client-cleared derivatives are not included in the calculation
of stressed losses, it is unclear what benefit this information would provide to justify the
additional firm burden.
In response, the Board notes that, while granular information on client-cleared derivatives
are reportable in Schedule L.5, the top-25 ranking produces valuable insights that allow the
Board to more effectively monitor exposures to client-cleared derivatives and provides better
information regarding the materiality of these exposures.
Further, while it is true that the exposure to client cleared derivatives is excluded from the
FR Y-14A, firms are already required to report in FR Y-14Q, Schedule L.5, a wide range of
information (both qualitative and quantitative) that goes beyond direct inputs used for estimating
the largest counterparty default losses that are reported in FR Y-14A, Schedule A.5, items 3 and
3.a.
Additionally, the commenter recommended that, if the Board did adopt these proposed
changes, the Board should provide information as to (1) if a counterparty is of sufficient size to
be captured in both rankings (methodologies #1 and #2), are firms required to report this
counterparty twice or only once under methodology #1, and (2) under methodology #2, whether
aggregate columns, such as “Total Net Current Exposure (CE),” should only include clientcleared derivative exposure to the parent entity under the ranking methodology or should instead
be inclusive of both client-clearing and non-client-clearing exposure to a firm.
The Board has adopted the revision as proposed with two exceptions. First, the Board has
clarified in the instructions the reporting between methodology #1 and methodology #2. Notably,
the Board clarified that firms are not required to report the same counterparty in both
methodologies (i.e., the same counterparty should not appear in the top -25 rankings for
methodology #1 and methodology #2). Second, in light of the burden of providing granular data
noted by the commenter, the Board has delayed adoption of this revision until the FR Y-14Q
reported as of June 30, 2023.
Securities Financing Transactions (SFTs)
The Board proposed to revise the definitions of “Unstressed Mark-to-Market Received
SFTs” and “Stressed Mark-to-Market Received SFTs” on FR Y-14Q, Schedule L (Counterparty)
to specify that in cases where close-out netting is not enforceable, firms must report zero. Three
commenters pointed out that this guidance conflicts with two existing FR Y-14 Q&As
(Y140001386 and Y140001492). Per one commenter, the guidance in Q&A Y140001386
appears to require firms to remove any consideration of the “received” leg of the transaction,
whereas the guidance in Q&A Y140001492 would allow for consideration of the net exposure of
an individual SFT but restrict netting across multiple transactions where no master netting
agreement is in place. The commenter notes that their understanding of the reporting on
Schedule L should align with the guidance provided in Q&A Y140001492, as that interpretation
better captures the economics of a transaction, and would prefer the instructions be revised to

agree with that interpretation. In addition, per the commenter, these proposed revisions may be
interpreted to further restrict the offsetting of the posted and received legs in determining net
current exposure of an individual transaction.
The Board agrees that the guidance provided in Q&A Y140001492 better captures the
economics of a transaction, and so has modified the instructions so that firms are required to
report “Unstressed Mark-to-Market Received SFTs” and “Stressed Mark-to-Market Received
SFTs” in a manner that aggregates the received amount across an unenforceable agreement for
each transaction that has a net positive mark-to-market value, effective for the June 30, 2023, as
of date.
The general instructions for Schedule L state that “for regular/unstressed submissions,
counterparty exposures on sub-schedules L.1-L.4 should be limited to transactions for which the
firm computes credit valuation adjustment (CVA) for its public financial statement reporting
under generally accepted accounting principles (GAAP) or applicable standard.” In the “Net
Current Exposure (Net CE)” item of Schedule L.1, the Board proposed to add language
clarifying that this item should be reported for both derivatives and fair-value SFTs. One
commenter noted that firms do not compute CVA for SFTs in public financial statement
reporting, and so asked that the Board specify whether SFTs should be included in the “Net
Current Exposure (Net CE)” item of Schedule L.1.
In response, the Board has clarified in the instructions that in the unstressed submission,
firms are required to include fair-valued SFTs in Net CE reporting, to the extent that the firm
computes CVA for them for the public financial statement reporting under U.S. GAAP or
applicable standard. In contrast, fair-valued SFTs are expected to be included in Stressed Net CE
reporting regardless of whether the firm computes CVA, given the general instructions of
Schedule L that states that “the scope of counterparty exposures on sub -schedules L.1-L.4 in
CCAR/stressed submission is expected to be larger and incorporates transactions that would not
typically require CVA for public financial statement reporting under GAAP or applicable
standard but which may pose a gap risk to the firm, requiring CVA, should the post-stress value
of collateral be insufficient to cover post-stress derivatives exposure.” The Board has adopted
this revision effective for the June 30, 2023, as of date.
The Board proposed to clarify that firms must include SFT exposures when they act as
agents on behalf of clients for which a credit guarantee has been provided against the borrowers’
defaults in Schedule L.5. One commenter noted that the proposal did not address how to report
guarantees provided in sponsored repurchase programs in which a firm, as a sponsoring member,
guarantees the performance of the clients to a central counterparty clearing house (CCP). The
commenter recommended the Board clarify how these guarantees should be reported.
The Board confirms that the guarantees associated with sponsored repurchase programs
in which the firm, as a sponsoring member, guarantees the client’s performance to CCPs should
be reported in Schedule L.5. However, the Board has not revised the instructions, as the
instructions already state that the firm should report its exposure arising from the credit
guarantee it provides against the borrower’s default. The Board has adopted this revision as
proposed, except that it has delayed implementation until the June 30, 2023, as of date.

Other Revisions
The Board proposed to clarify that if a consolidated or parent counterparty is selected as a
counterparty comprising 95% of a firm’s CVA, then a firm’s exposures to all the counterparties
and legal entities associated with the consolidated or parent counterparty must be included and
reported in Schedule L.1 (Derivatives profile by counterparty and aggregate across all
counterparties), rather than including only counterparties and legal entities with which the firm
has a CVA. One commenter pointed out that this proposed revision would contradict the
response to FR Y-14 Q&A Y140001356, which states that firms are not required to include the
active agreements that do not have actual trades on the reporting as of date. The commenter
recommended that the Board instead clarify the instructions to be consistent with the
interpretation in Q&A Y140001356.
The Board notes that the proposed revision is consistent with the response to Q&A
Y140001356. Q&A Y140001356 covers a related case in which a firm has active agreements
that do not have actual trades on the reporting date. The proposed revision related to a different
case in which a firm has actual trades on the reporting date but does not compute CVA on them.
In this case, while CVA is zero, not all counterparty data is expected to be zero or null (such as
notional, gross CE, etc.). Under the proposed revisions, a firm would have been required to
report these exposures to all the counterparties/legal entities associated with the
consolidated/parent counterparty reportable in Schedule L.1, regardless of their CVA values. The
Board has adopted this revision as proposed, but has delayed implementation until the June 30,
2023, as of date.
The Board proposed to clarify that in the “Non-Cash Collateral Type” item of Schedule
L.5.1 (Derivative and SFT information by counterparty legal entity and netting set/agreement),
firms must include all non-cash collateral or initial margin that was posted or received in
actuality, as opposed to only non-cash collateral allowed under a given agreement. One
commenter recommended the Board specify that firms should not report this item for legally
unenforceable agreements and in cases where no agreement is in place.
Given the structure of applicable transactions, the Board agrees with the commenter and
has clarified the instructions so that firms should not report the “Non-Cash Collateral Type” field
in Schedule L.5.1 in cases where there is no legal agreement in place, or the agreement is not
legally enforceable. The Board has adopted this revision effective for the June 30, 2023, as of
date.
The Board proposed to require firms to report counterparty attribute information (e.g.,
industry code) at the consolidated parent level (firms were already required to report this
information at the counterparty legal entity level). One commenter sought several clarifications
about this proposed change. First, firms are currently required to report the internal rating of
consolidated/parent counterparties in the “Consolidated/Parent Counterparty Internal Rating”
item. Per the commenter, firms generally assign ratings and grades at the counterparty legal
entity level, and a parent counterparty would only receive a grade or rating if the firm had
transactions with that entity directly. The commenter suggested that the Board revise the
instructions to cover situations where a parent counterparty is not rated or graded by the firm and

recommended two approaches. Under the first approach, firms would report default grades (e.g.,
the firm would report BB- for all such counterparties). Under the second approach, firms would
report the mean or median rating across counterparty legal entities to form a composite rating.
The commenter noted that the information provided under the second approach would have
limited value to the Board as it is already reported in a separate item.
Second, in the “Consolidated/Parent Counterparty Industry Code” item, firms are
required to report a North American Industry Classification System (NAICS) code if one is
available. The commenter requested clarification on whether the primary business activity of the
parent should be determined by looking at the contributions of revenue across subsidiaries or
whether parent entities should be aligned to holding company NAICS codes.
The Board proposed to capture attribute information at the consolidated parent level, as it
would have enabled the Board to better identify exposures to the same organizational structure
(e.g., parent and subsidiary). However, the Board acknowledges the concerns and data
limitations raised by the commenter. Upon further review of the proposed changes considering
the concerns raised in the comment, the Board has not adopted the proposed changes to require
firms to report counterparty attribute information at the consolidated parent level.
The Board did not propose any revisions to the “Agreement Role” item on Schedule
L.5.1. In this item, firms are required to report “NA” when the transactions do not relate to
centrally cleared or exchange traded derivatives, when the reported counterparty is a CCP, or
when the firm is a clearing member of a CCP or an exchange and the exchange does not
guarantee the client’s performance to the CCP or exchange. One commenter suggested that for
back-to-back derivatives (i.e., when a firm is acting as a financial intermediary on behalf of the
client and enters into an offsetting transaction with a CCP or an exchange), firms should be
required to report “Principal” instead of “NA”. According to the commenter, this approach
would enable the Board to differentiate these exposures from the firms’ exposures to the CCP
arising from transactions, which firms enter into as a principal in house derivatives, as well as to
potentially remove these exposures as inputs to the calculation of stressed losses. The Board will
consider this revision for a future proposal.
Trading
Public Welfare Investments
The Board proposed to require firms to isolate certain private equity exposures that
qualify as public welfare investments in FR Y-14Q, Schedule F.24 (Private Equity). One
commenter asked the Board to clarify whether the new items added for public welfare
investments are intended to capture affordable housing investments not eligible for tax credits.
The commenter also asked the Board to confirm that such tax oriented public welfare
investments should instead be reported in Schedule F.25 (Other Fair Value Assets) if fair-value
option (FVO) has been elected for the investment.
The Board confirms that the new items added to Schedule F.24 for public welfare
investments were not intended to capture public welfare investments eligible for tax credits, and

that such tax oriented public welfare investments should instead be reported in Schedule F.25 if
held at fair value, including if FVO has been elected for the investment. The Board has adjusted
the proposed revisions to the Schedule F.24 instructions to clarify both of these matters and has
otherwise adopted the revisions as proposed, effective for the September 30, 2022, as of date.
Other Revisions
The Board proposed to better delineate the exposures that should be included in the
“FVO Hedges” and “[Accrual Loan] AL Hedges” versions of Schedule F (Trading). One
commenter was supportive of these changes, though questioned whether firms needed to provide
all of the sub-schedules of Schedule F for these versions. Specifically, the commenter suggested
that Schedule F.22 (IDR-Corporate Credit) and F.23 (IDR-Jump to Default) be left blank for the
“FVO Hedges” and “AL Hedges” versions. The commenter’s rationale is twofold. First, the data
submitted on these schedules either does not affect the macro scenario projections or are not u sed
by firms to determine macroeconomic scenario projections, and so the data are only
informational or are only used in the calculation of trading incremental default losses (i.e., not
relevant for the macro scenario projections). Second, these schedules are operationally
burdensome for firms to provide as they require firmwide aggregation and netting.
The Board agrees with the commenter’s rationales and has revised the instructions to
indicate that Schedules F.22 and F.23 are not required for the FVO Hed ges and AL Hedges
submissions, effective for the September 30, 2022, as of date.
The Board did not propose any changes to the treatment of non-fair value private equity
investment exposures for determining stressed losses. However, one commenter recommended
that the Board subject these exposures to the macro scenario, and not to the global market shock
scenario. The Board indicated in a final FR Y-14 notice from 2020 29 that it believes the macro
scenario is more appropriate than the global market shock for evaluating losses associated with
non-fair value private equity exposures but would continue to analyze the issue.
The Board is still reviewing the scenario treatment of non-fair value private equity
exposures and will consider revising this treatment in a future Federal Register notice.
Wholesale
Informal Advised or Guidance Lines
The Board proposed to revise the definition of informal advised or guidance lines on
FR Y-14Q, Schedule H.1 (Corporate) to be an authorization for a line of credit that is unknown
to the customer. These lines are excluded from reporting on Schedule H.1. The Schedule H.1
instructions also require firms to include “...any unused commitments that are reported on
FR Y-9C, Schedule L [Derivatives and Off-Balance Sheet Items] that would be reported in the
relevant FR Y-9C category if such loans were drawn.” One commenter said that this proposed
revision would require firms to report certain credit facilities as commitments in Schedule H.1,
even though such facilities are intentionally structured and documented such that the lender is
29

See 85 FR 86560 (December 30, 2020).

not under any legal obligation to extend credit or purchase assets (defined facilities). Two
commenters further noted that there are several definitions of commitments across various Board
rules and reporting forms. The commenters requested the Board align the definition of
commitment on Schedule H.1 with that of FR Y-9C, Schedule L, or with the definition from the
capital rule. Per the commenters, this would reduce operational burden on reporting firms and
would lead to more consistent practices across firms. If the definition of commitment is not made
the same across Schedule H.1, Schedule L, and the capital rule, then the commenters asked the
Board to clearly delineate how these definitions differ. The commenters added that if the Board
does not align the definitions as recommended, then it should clarify what lines of credit
“unknown to the customer” means.
The clarification of the definition of informal advised or guidance lines was intended to
bring Schedule H.1 more clearly into alignment with the FR Y-9C. However, the Board
acknowledges the concerns raised by the commenter. To avoid confusion and clarify the
relationship to the FR Y-9C, the Board has not adopted the proposed revisions to the definition
of informal advised or guidance lines. Further, to ensure alignment with the FR Y-9C, the Board
has removed the language surrounding the exclusions of informal advised or guidance lines. The
aforementioned reference to FR Y-9C, Schedule L will remain in the instructions without any
exclusions, which should mitigate ambiguity. Given the comments surrounding firm burden, the
Board has delayed implementation of this revision until the June 30, 2023, as of date.
Internal Ratings Mapping
The Board proposed to add “Minimum Probability of Default,” “Maximum Probability of
Default,” and “[Probability of Default] PD Calculation Method” items to FR Y-14Q, Schedule
H.4 (Internal Risk Rating). Per the proposal, these items would enable the Board to better assess
credit risk across firms by providing benchmark values for internal ratings. Two commenters
raised several issues with this proposal. First, firms may segment their portfolios and assign
certain PDs to internal ratings within each segment. This could lead to a wide range of PDs for
firms’ internal risk ratings and possibly overlapping minimum and maximum PDs across
different ratings. Such overlap would not allow the Board to easily compare credit risk across
firms, and so may not be appropriate for use in supervisory models. In addition, some firms may
assign a single PD to a given internal rating, and so the data provided may not be very useful to
accomplish the intended goal of the proposed changes. Given the diversity in practice across
firms, one commenter requested that the Board acknowledge that these items would not be used
by supervisory models to determine stressed losses, and another commenter recommended that
the Board not adopt these proposed changes.
Second, firms are already required to report PD information at the facility level in
FR Y-14Q, Schedules H.1 and H.2 (Commercial Real Estate). The commenters noted that this
facility-level data provides more insight than minimum and maximum PD. The commenter
added that while firms could provide the minimum and maximum PD for their internal ratings,
the firm may not hold any exposures that have PDs equivalent to the minimum or maximum PD
for a given internal rating. By contrast, PD data already required on Schedules H.1 and H.2 allow
the Board to see the exact PDs of reported exposures. Per the commenters, the fact that firms
may not have any exposures at the minimum and maximum PD for a given internal rating and

the fact that firms already reported facility-level PD information mean that the additional burden
of reporting the minimum and maximum PD for a given internal rating is not justified.
Third, one commenter asserted that there may be a future proposal to the capital rule to
eliminate the existing internal ratings-based approach. If this occurs, it would no longer be
appropriate to require the reporting of these items, per the commenter. Given the possibility of
this occurring, the commenter suggests firms should not be required to provide these items due to
the burden of creating a process that may be obviated in the near future.
Commenters also requested information regarding how this data will be used, how firms
should report if certain ratings do not have associated PD ranges, and how firms should report
situations where a PD is assigned to an internal rating but there are no exposures with that PD
reportable in Schedules H.1 or H.2 (i.e., whether a firm would still be required to include such a
portfolio segment in establishing the range of PDs for a given rating). One commenter also
suggested that these items should be changed to alpha-numeric characters to allow firms to report
“NA” and “Null” values, as well as be expanded from the proposed four-decimal places to seven
decimal places, as some firms have PD ranges that extend beyond four decimal places. Finally,
one commenter recommended that the “PD Calculation Method” item instructions specify how
firms should report hybrid calculation methods that consider through the cycle and point in time
aspects (as proposed, firms can only select one of those two options as their PD calculation
method).
The Board notes that the “Minimum PD” and “Maximum PD” items are intended to give
additional context with regard to understanding a firms' internal ratings. Current reporting on
Schedule H (Wholesale) without these items has resulted in inconsistent ratings detail across
firms, and the addition of these items will produce useful data points for interpreting the ratings.
The reporting of these items creates an opportunity for firms to provide a more robust view of
their internal ratings to help the Board better assess credit risk. Additionally, the free text field
will remain available for firms to provide further explanation if necessary.
In addition, reporting the calculation method at the level of the internal rating will
provide the Board with additional detail in assessing the PDs reported, with a lower burden than
requiring this data at a facility level. It may be the case that a firm does not hold any exposures at
the minimum and maximum PDs reported for each internal rating; however, the PD information
is still crucial in allowing the Board to better interpret internal ratings. Further, the Board has not
issued a notice of proposed rulemaking or final rule to revise the capital rule to eliminate the
existing internal ratings-based approach.
Lastly, to reduce burden and to be responsive to commenters, the Board has revised the
instructions to allow for the reporting of “NA” for internal ratings that do not have exposures in a
reporting quarter, to expand the character limit for these items to allow firms to report up to
seven decimal places, and to add a hybrid calculation option to the “Calculation Method” item.
The Board has adopted this revision effective for the September 30, 2022, as of date.

Capital
Capital Action Assumptions
Planned capital actions are the capital actions firms would expect to take under baseline
conditions, and alternative capital actions are the capital actions firms would expect to take under
stressed conditions. The Board proposed to change the capital action assumptions of the
FR Y-14A, Schedule A (Summary) CCAR submission under the supervisory severely adverse
scenario from planned capital actions to alternative capital actions. In addition, the Board
proposed to add the definitions and assumptions of capital actions required per the capital plan
rule, as set forth in CCAR Q&A GEN0500, to the instructions for FR Y-14A, Schedule A. One
commenter was supportive of the change in the capital action assumptions for the CCAR
submission under the supervisory severely adverse scenario. However, the commenter pointed
out that the proposal seemed to apply two of the assumptions to alternative capital actions that
were intended only to apply to planned capital actions in the severely adverse scenario. These
assumptions were: (1) that the dollar value of dividends, repurchases, and redemptions of capital
instructions do not vary from the amount in the Internal baseline scenario, and (2) that the dollar
value of the issuance of capital instruments does not vary by scenario from the amount in the
Internal baseline scenario unless the scenario directly impacts shareholder’s equity or
consideration paid in connection with a planned merger or acquisition.
The Board confirms that these two assumptions would not apply to alternative capital
actions and are no longer necessary to include in the instructions because planned capital actions
will only be used in the baseline scenario. The Board has removed these two assumptions from
the instructions and has adopted this revision effective for the December 31, 2022, as of date. In
addition, the Board has rescinded CCAR Q&A GEN0500 because it refers to the prior
instructions, which required firms to use planned capital actions in the supervisory severely
adverse scenario, and would therefore cause confusion.
Interest Expense
The Board proposed to add an “Interest expense for the quarter (net of swaps)” item to
FR Y-14Q, Schedule C (Regulatory Capital Instruments). One commenter asked for clarification
for whether firms should report quarter-to-date profit and loss (P&L) movement of the interest
expense on the subordinated debt instrument only, as opposed to total interest expense.
The Board confirms that the commenter’s interpretation is correct in that firms should
report quarterly P&L for the specific subordinated debt instrument net of P&L attributable to
swaps. The Board has revised the instructions to clarify this reporting and has adopted this
revision effective for the September 30, 2022, as of date.
The Board proposed to add an “Interest expense for the quarter (with swaps, excluding
any gains or losses due to the fair value adjustment of ASC 815/FAS 133 hedges)” item to
Schedule C. One commenter asked the Board to confirm that firms would need to report quarterto-date interest profit and loss movement on debt plus swap interest (i.e., debt couponing and
amortization of original issuance discount/premium) and underwriting fee plus swap interest

accrued and realized cashflow in this item.
The Board confirms that the commenter’s interpretation is correct in that firms should
report the quarterly P&L for the specific subordinated debt instrument including any
underwriting fees and income/expense due to swaps but excluding the gains/losses due to any
fair value adjustments over the quarter. With respect to realized cash flow, firms should only
report cash flow from swaps to the extent that they are included in interest expense on
subordinated debt. The Board has revised the instructions to clarify this reporting and has
adopted this revision effective for the September 30, 2022, as of date.
The Board proposed to add an “Interest expense for the quarter (with swaps, this number
should reconcile to the quarterly number reported in FR Y-9C BHCK4397 for all subordinated
debt instruments)” item to Schedule C. One commenter asked for clarification for whether firms
should report quarter-to-date movement on interest plus the Financial Accounting Standards
(FAS) 133 fair value adjustment for both debt and swaps in this item.
The “Interest expense for the quarter (with swaps, this number should reconcile to the
quarterly number reported in FR Y-9C BHCK4397 for all subordinated debt instruments)” item
is meant to capture the entirety of interest expense on the subordinated debt instrument, inclusive
of swaps and fair value adjustments. The sum of this item across all subordinated debt sec urities
should reconcile to the interest expense on subordinated debt that is reported on the FR Y-9C.
The Board has revised the instructions to clarify this reporting and has adopted this revision
effective for the September 30, 2022, as of date.
Other Revisions
The Board proposed to add a “Fair value adjustment at the quarter end for subordinated
debt securities that are carried at fair value” item to Schedule C. One commenter asked how this
proposed item would interact with the existing “Fair value of associated swaps ($Millions)” item
also on Schedule C. Specifically, the commenter wanted clarification on whether the proposed
item is meant to capture all fair value adjustments on long term debt that have a fair value hedge
relationship while the existing item is meant to capture only the fair value of outstanding swaps.
Additionally, the commenter also sought clarification on whether the proposed item is asking for
the FAS 133 basis adjustment (if not, then firms would report a zero value, as a subordinated
debt portfolio is not reported at fair value), and whether the existing item should include accrued
interest.
The proposed “Fair value adjustments at the quarter end for subordinated debt securities
carried at fair value” item was meant to capture the quarterly fair value adjustment made to the
security that flows through a firm's income statement as interest expense on subordinated debt.
The existing item “Fair value of associated swaps ($ Millions)” captures the total fair value of
outstanding swaps on this security, and not the quarterly movements (e.g., fair value
adjustments). The Board has revised the instructions to clarify this reporting and has adopted this
revision effective for the September 30, 2022, as of date.

Retail
Modified Loans
The Board proposed to clarify that “Modification Type” (FR Y-14M, Schedule A
(Domestic First Lien), item 74; Schedule B (Domestic Home Equity), item 77) should only be
completed if firms report “1” in “Workout Type Completed” (Schedule A, item 77; Schedule B,
item 61), indicating that a loan has been modified. The instructions for “Workout Type
Completed” specify that firms must report “1’ in the month that the modification is complete and
the new loan terms are in effect. One commenter asked the Board to clarify whether
“Modification Type” should only be completed in the month that modification is complete and
the new loan terms are in effect.
The Board notes that “Workout Type Completed” should only be reported in the month
the workout was completed. Per the instructions, “Modification Type” should be filled out fo r all
months the loan is currently operating under modified terms (including the month that “Workout
Type Completed” = 1). The Board has revised the instructions for “Modification Type” to clarify
how to report this item and has adopted the revision, effective for the September 30, 2022, as of
date.
One commenter pointed out that “Modification Type” requires firms to report “0” if a
loan has not been modified, but this is inconsistent with the proposed changes requiring firms to
only report this item if a loan has been modified, as indicated in “Workout Type Completed.”
The commenter asked for clarification for how to report this item for loans that have not been
modified.
The Board notes that if a loan is not operating under modified terms, then “Modification
Type” should be populated as “0 = Loan has not been modified.” If “Workout Type Completed”
= 1 (Modification), then “Modification Type” should be coded with an allowable value other
than “0.” The Board has updated the instructions to clarify this point and has adopted the
revision, effective for the September 30, 2022, as of date.
The Board proposed several revisions to the “Modification Type” item to allow for
multiple types of modifications to a loan, such as modifications caused by the COVID event.
One commenter sought clarification from the Board on how COVID-related deferral or
forbearance plans should be reported in “Modification Type.” Per an April 2020, interagency
statement,30 COVID-related deferral or forbearance plans should not be treated as modifications,
as they are temporary plans to reduce the hardships faced by the borrower. The commenter
recommended that firms only report “Modification Type” in cases where the modification is due
to loss or mitigation efforts, and not to capture COVID-related deferrals or forbearances.
In response, the Board notes that it proposed to add “Workout Type Started” to Schedule
A (item 143) and Schedule B (item 120) of the FR Y-14M. All forbearances should be reported
“Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with Customers
Affected by the Coronavirus (Revised)” April 7, 2020.
https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20200407a1.pdf.
30

under “Workout Type Started” and “Workout Type Completed,” regardless of the cause of the
forbearance. If any modification to the terms of the loan occurs as a result, then it should be
reported in “Modification Type.” The Board has adopted the revision as proposed, effective for
the September 30, 2022, as of date.
One commenter asked how non-loss mitigation-related modification plans (non-default)
(e.g., plans under the Service Members Relief Act (SCRA)) should be treated in “Modification
Type.” The commenter notes that in FR Y-14 Q&A Y140001307, the Board indicated that loans
under SCRA plans should be considered as active loss mitigation.
The Board has clarified that if the loan is active under loss mitigation, then “Modification
Type” should reflect the type of accommodation the loan is undergoing (per Q&A Y140001307,
SCRA plans should be considered as active loss mitigation).
One commenter asked how firms should report “Modification Type” in cases where the
type of modification is unknown. Per the commenter, a loan that was modified under a Home
Affordable Modification Program (HAMP) may have offered the borrower a variety of types of
modification, and this level of detail is not available in certain loan systems, particularly for
loans that were modified prior to 2013.
The Board acknowledges that there may be cases where loan modification information is
unknown. Firms must report the value that reflects the current modification arrangement using
all information available. To address this comment, the Board has added option “99=Other” to
“Modification Type.” Firms should report “99=Other” if no information regarding the
modification is available. The Board has also updated “Modification Type” to remove reference
to any specific program (such as HAMP). The Board has adopted this revision effective for the
September 30, 2022, as of date.
The Board proposed to add an option to “Modification Type” for firms to report when the
loan modification results in recapitalization. One commenter asked the Board to provide a
definition for the “Recapitalization” option.
The Board has added a definition for “Recapitalization” to “Modification Type” to
capture instances where accrued and/or deferred principal, interest, servicing advances, expenses,
fees, etc. are capitalized into the unpaid principal balance of the modified loan. The Board has
adopted this revision effective for the September 30, 2022, as of date.
The Board proposed to retire several options in the “Modification Type” and “Workout
Type Completed” items, considering the proposed addition of other items. One commenter asked
how historical reporting would be updated or aligned to the new values.
The Board notes that historical reporting will remain unchanged from the current
practice, which requires firms to report items and values based on the forms and instructions for
a given as of date. The Board has adopted these revisions as proposed, effective for the
September 30, 2022, as of date.

The Board proposed to add several reportable values to “Modification Type” on Schedule
B, one of which was “99 = Other”. However, this item already had the “26 = Other” option. One
commenter asked what the difference was between the options of “26 = Other” and “99 = Other”
for “Modification Type” on Schedule B.
The Board did not intend to have two values indicating the same modification type, and
so has removed “26=Other” from “Modification Type” on Schedule B, effective for the
September 30, 2022, as of date.
The Board proposed to retire the “9 = Proprietary Other” option of “Modification Type”
on Schedules A and B. FR Y-14 Q&A Y140000738 previously specified that firms should report
home equity modifications that do not meet the definition of modification, as defined in the
FR Y-14M instructions, as “9 = Proprietary Other” in “Modification Type.” One commenter
asked how firms should report such loans once the “9 = Proprietary Other” option has been
retired.
Firms should report the code that reflects the current modification arran gement using all
information available. If no information regarding the modification type is available, then firms
should report as “99=Other.” The Board has adopted this revision as proposed, effective for the
September 30, 2022, as of date.
One commenter asked whether the Board proposed to retire the “13 = HELOC Line
Renewal (Regular)” and “14 = HELOC Line Renewal (loss mitigation strategy)” options from
“Modification Type” on Schedule B. The instructions for these values have been stricken out, but
the options themselves were not.
The Board did not intend to strike out the instructions for these values and has updated
the instructions accordingly. These values were not removed from “Modification Type” on
Schedule B, and the Board did not propose any revisions to these values. The Board has adopted
this revision effective for the September 30, 2022, as of date.
The Board proposed to add an option to “Workout Type Completed” for firms to report
“17=Partial Claim/Junior Lien” on Schedules A and B. The proposed instructions for “Workout
Type Completed” would have required firms to report “17=Partial Claim/Junior Lien” in the
month that a loan partial claim or the origination of a junior lien resulting from loss mitigation
was completed. One commenter noted that some modifications, such as Federal Housing
Authority (FHA)-HAMP Combination Loan Modifications and Partial Claims, may result in a
partial claim. These modifications establish an affordable monthly payment, resolve the
outstanding mortgage payment arrearages, and permanently modify the first mortgage monthly
payment. The commenter added that these modifications are zero-interest subordinate liens that
will include a portion of the amount to be resolved and if borrowers meet the requirements, a
principal deferment. The remainder is added to the principal loan balance of the first mortgage
and extends the term for 30 years at a fixed interest rate. The commenter would like the Board to
clarify how to report these types of modifications in the “Workout Type Completed” items.
If a workout program results in a partial claim or junior lien, then “Workout Type

Completed” should be coded as “17=Partial Claim/Junior Lien.” If the workout program results
in a change to terms of the loan, then “Workout Type Completed” should be reported as “1 –
Modification” and “Modification Type” should be reported using the code that best reflects the
modification. The Board has adopted this revision as proposed, effective for the September 30,
2022, as of date.
The Board proposed to add a “Workout Type Started” item to Schedule A. Firms would
be required to report this item for any loan where a loss mitigation effort has started or is in
progress for the current month. One commenter asked how firms should report situations where a
modification plan that was reported in a prior period fails and in the current reporting period, a
new plan starts.
In cases where loss mitigation efforts fail, firms should report “Workout Type
Completed” as “0=No workout completed or unsuccessful resolution of loss mitigation effort.” If
in the current month a new effort begins, firms should report “Workout Type Started” with the
relevant allowable value. The Board has revised the instructions to clarify this reporting,
effective for the September 30, 2022, as of date.
One commenter asked how firms should report situations where they offer a borrower a
trial period for a modified loan that could subsequently result in a loan modification. In these
cases, the commenter sought clarification as to whether firms should report the date that the trial
period began or when the modification program began.
Firms should report “Workout Type Started” with the appropriate value in the month(s)
the trial started and throughout the trial period for loans that enter a trial period for a
modification. The Board has adopted the revision as proposed, effective for the September 30,
2022, as of date.
The Board proposed to add new options for the “Workout Type Completed” item on
Schedule B. However, the Board did not provide proposed definitions for these new options. One
commenter asked the Board to provide these definitions.
The Board has updated the instructions to provide definitions for all new values in
“Workout Type Completed” on Schedule B that align with the definitions for the “Workout Type
Completed” item on Schedule A. The Board has adopted this revision effective for the
September 30, 2022, as of date.
The Board proposed to revise the language in the instructions for FR Y-14M, Schedule
A, items 87 (Principal Deferred Amount) and 89 (Principal Write-Down Amount) to expand the
circumstances under which firms would report these items, as currently these items are only
reported if a loan has been modified. One commenter pointed out that the Board did not propose
to revise the equivalent items on Schedule B (items 59 and 73, respectively), even though these
items are also only reported if a loan has been modified. The commenter suggested that the
Board also make these revisions to the corresponding Schedule B items, for consistency.
The Board agrees that the corresponding items on Schedule B should have been upda ted

and has revised the instructions to align the applicable items on Schedule B with those on
Schedule A. The Board has adopted these revisions effective for the September 30, 2022, as of
date.
Other Revisions
The Board proposed to require firms to provide the loan-level fair value of loans reported
on FR Y-14M, Schedule A, if those loans are measured under the FVO or are held -for-sale
(HFS). Currently, firms are required to indicate whether a loan is measured at fair value under
the FVO or is HFS but are not required to provide the fair value of a given loan. One commenter
raised two objections to this proposal. First, many firms do not have the fair value of FVO or
HFS loans readily available. Rather, per the commenter, fair value adjustments on FVO or HFS
loans are recorded and accounted for as a block and are not individually broken out. The
commenter added that requiring firms to provide loan-level fair values would be burdensome on
firms and would require significant manual effort as the data is not readily available.
Second, firms are already required to report aggregated fair value FVO and HFS amounts
for retail loans on FR Y-14Q, Schedule J (Retail FVO/HFS). In the commenter’s view, since the
Board currently collects similar information at the portfolio level, firms should not be required to
report fair value amounts at the loan level.
Collecting loan-level fair value information for mortgages allows the Board to better
monitor and assess risks surrounding FVO mortgages, which is limited when usin g the
aggregated FR Y-14Q data. Receiving timely information regarding the fair value of mortgages
is essential since these assets are highly sensitive to current market conditions, which can change
rapidly. Therefore, mortgages held at fair value have dif ferent risk profile than those held at
amortized cost. Given this, it is imperative that the Board receives loan-level fair value data for
these exposures. The Board has adopted this revision as proposed, effective for the September
30, 2022, as of date.
The Board proposed to remove items 57 (Capitalization) and 98 (Interest Rate Reduced)
from FR Y-14M, Schedule A, as they are no longer needed. One commenter suggested that, for
consistency, the Board should also remove the equivalent items (items 57 and 71, respectively)
from Schedule B.
The Board agrees that the equivalent items on Schedule B should also be removed, as
they are no longer needed given other adopted revisions. The Board has updated the instructions
to remove these items from Schedule B. The Board has adopted these revisions effective for the
September 30, 2022, as of date.
The Board proposed to add “Actual Payment Amount” (item 142) to Schedule A. In this
item, firms would have reported the actual dollar amount of the interest payment received in the
reporting month, excluding fee payments. One commenter questioned how to report situations
where there is an additional principal curtailment received with the payment, and how firms
should report if multiple payments are received in a given reporting month.

To reduce ambiguity, the Board has modified the proposed instructions to indicate that
firms should report the total payment received in a given month, including principal curtailment
received with the payment.
One commenter asked whether principal and interest reversals should be factored into
“Actual Payment Amount,” or if it should only capture received amounts.
For clarity, the Board has modified the proposed instructions to indicate that firms should
report the total payment received in a given month, net of any reversals. The Board has adopted
the proposal to add the “Actual Payment Amount” item to Schedule A, with these modifications,
effective for the September 30, 2022, as of date.
The Board proposed to add options for the Bloomberg Short-Term Bank Yield (BSBY)
to the “[Adjustable Rate Mortgage] ARM Index” item on Schedules A (item 32) and B (item 29).
There were no comments on the proposed changes; however, one commenter did have two
questions about this item. First, the commenter noted that the Federal Home Loan Bank of San
Francisco announced earlier this year that it will stop publishing all Cost of Fund Indices (COFI).
The “ARM Index” item currently contains options for firms to report COFI. The commenter
further noted that loans that reference COFI have been updated to reference other indices and
sought clarification as to whether firms should continue to report COFI, which was the reference
index at origination, or the updated indices. Second, the commenter also pointed out that the
“ARM Index” item requires firms to report origination values. The commenter recommended
that this be changed so that firms report the current index values, as it would provide more useful
information to the Board and be less burdensome on firms, as the current index information is
readily available.
The Board notes that COFI has not been retired and firms can continue to report COFI in
“ARM Index.” Firms should continue to report legacy loans that reference COFI using the COFI
options in “ARM Index.” In addition, origination values allow the Board to adequately assess
underwriting decisions at the time of origination, which can inform changes in credit availability
over time. The Board acknowledges that receiving current value information would also be
beneficial and will consider this suggestion for a future proposal. The Board has adopted the
revision as proposed, effective for the September 30, 2022, as of date.
Balances
In general, bank cards allow firms to pay outstanding balances over time, while charge
cards must be fully paid off each billing cycle. Some products have features of both bank and
charge cards, in that only a portion of the outstanding balance can be rolled over to the next
billing cycle. The Board proposed to revise the definition of “Charge cards” (item 3.b) on
FR Y-14Q, Schedule M.1 (Quarter-end balances) to specify that if a charge card loan has a payover-time feature, then the entire balance must be reported in this item. One commenter said that
this revision would cause misalignment between Schedule M and item 6.a. (Credit cards) of
FR Y-9C, Schedule C (Loans and Leases), and asked whether this misalignment was intentional.
The definition of item 3.b on FR Y-14Q, Schedule M requires firms to report the

applicable balance that is also reported in FR Y-9C, Schedule HC-C, items 6.a and 6.d (Other
consumer loans). Therefore, the Schedule M.1 and FR Y-9C, Schedule HC-C instructions would
align, and the Board has adopted the revision as proposed, effective for the September 30, 2022,
as of date.
Several items on FR Y-14Q, Schedule M.1, reference various FR Y-9C items where
applicable balances are reported. The Board proposed to add a reference to FR Y-9C, Schedule
HC-C, item 9.a (Loans to nondepository financial institutions) to Schedule M.1, item 2.c (SME
cards and corporate cards), as balances required in item 2.c could be reported in item 9.a. One
commenter requested that the Board also add references to FR Y-9C, Schedule HC-C, items 2.a
(Loans to U.S. banks and other U.S. depository institutions), 2.b (Loans to foreign banks), 3
(Loans to finance agricultural production and other loans to farmers), and 7 (Loans to foreign
governments and official institutions) to Schedule M.1, item 2.c, as balances reported in those
FR Y-9C items could also meet the definition listed for item 2.c. Relatedly, the commenter noted
that for congruency, any FR Y-9C items added to be referenced to Schedule M.1, item 2.c,
should also be added to Schedule M.2 (FR Y-9C Reconciliation), item 2 (SME cards and
corporate cards).
The Board agrees with the commenter that there could be loans reported in other
FR Y-9C items that meet the definition for reporting in Schedule M.1, item 2.c. Given this, the
Board has revised the instructions for item 2.c to add references to FR Y-9C, Schedule HC-C,
items 2.a, 2.b, 3, and 7. In response to the comment and for data reconciliation purposes, the
Board has also added applicable items to Schedule M.2, item 2. The Board has adopted these
revisions effective for the September 30, 2022, as of date.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-14 reports is
809,000 hours, and would increase to 810,464 hours as a result of the revisions, particularly
those made to the trading and counterparty schedules of the FR Y-14Q. These reporting
requirements represent approximately 11.6 percent of the Board’s total paperwork burden.

Estimated
number of
respondents31

Annual
frequency

Current
FR Y-14A
FR Y-14Q
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Current Total

36
36
34
0
36
0
8

1
4
12
1
1
1
1

1,330
1,986
1,072
7,200
480
4,800
2,560

47,880
285,984
437,376
0
17,280
0
20,480
809,000

Proposed
FR Y-14A
FR Y-14Q
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Proposed Total

36
36
34
0
36
0
8

1
4
12
1
1
1
1

1,330
1,999
1,071
7,200
480
4,800
2,560

47,880
287,856
436,968
0
17,280
0
20,480
810,464

FR Y-14

Change

Estimated
Estimated
average hours annual burden
per response
hours

1,464

The estimated total annual cost to the public for the FR Y-14 reports is $48,904,050, and
would increase to $48,992,549 with the revisions.32
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.

Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $750 million in total assets), https://www.sba.gov/document/support--table-size-standards.
The estimated number of respondents for the FR Y-14M is lower than for the FR Y-14Q and FR Y-14A because, in
recent years, certain respondents to the FR Y-14A and FR Y-14Q have not met the materiality thresholds to report
the FR Y-14M due to their lack of mortgage and credit activities. The Board expects this situation to continue for the
foreseeable future
32
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/.

Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FR Y-14 reports is $3,309,364. The estimated one-time cost to implement the revisions is
$87,500.

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File Created	2022-09-20