Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks

Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks; Report of Assets and Liabilities of a Non-U.S. Branch That Is Managed or Controlled by a U.S. Branch or Agency of a For

FFIEC002_202309_i_draft

Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks

OMB: 7100-0032

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FFIEC 002
Draft Instructions for Revisions Proposed to
Take Effect September 30, 2023

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The following draft instructions, which are subject to change, present
the pages from the FFIEC 002 as they are proposed to be revised,
subject to final approval by the Office of Management and Budget.
These proposed revisions are described in the federal banking
agencies’ initial Paperwork Reduction Act (PRA) Federal Register
notice published in the Federal Register on February 21, 2023. (see FIL7-2023, dated February 22, 2023). As discussed in the agencies' final
PRA Federal Register notice published in the Federal Register on June
13, 2023, the agencies are proceeding with the revisions to the FFIEC
002, with certain modifications.

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The initial and final PRA Federal Register notice and draft redlined
reporting form for these proposed revisions to the FFIEC 002 are
available on the FFIEC webpage for the FFIEC 002.

Draft as of June 13, 2023

INSTRUCTIONS FOR THE PREPARATION OF

Other Data for Deposit Insurance
Assessments
Schedule O

, 3, 8, and 9.

Item Instructions

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Item 1 Total deposit liabilities before exclusions
(gross) as defined in Section 3(l) of the Federal Deposit
Insurance Act and FDIC regulations.
Report the gross total deposit liabilities as of the calendar quarter-end report date that meet the statutory
definition of deposits in Section 3(l) of the Federal
Deposit Insurance Act before deducting allowable
exclusions from total deposits. An institution’s gross
total deposit liabilities are the combination of:

• All deposits and credit balances to nonrelated parties
reported in Schedule RAL, item 4.a, column A;
• Interest accrued and unpaid on all deposits and
credit balances to nonrelated parties included in
Schedule RAL, item 4.f, column A;
• Deposits of majority-owned depository subsidiaries
of the parent foreign bank and the interest accrued
and unpaid on such deposits;
• The amount by which demand deposits reported in
Schedule RAL, item 4.a, column A, have been
reduced from the netting of the reporting branch’s
reciprocal demand balances with U.S. branches and
agencies of foreign banks;
• The amount by which any other deposit liabilities
reported in Schedule RAL, item 4.a, column A, have
been reduced by assets netted against these liabilities
FFIEC 002

• Deposits in the insured branch to the credit of the
branch’s parent foreign bank or any of its offices,
branches, agencies, or wholly owned subsidiaries; and

• Other obligations meeting the Section 3(l) statutory
definition of a deposit that may be housed in systems
of record not normally thought of as deposit systems, such as loan, payroll, and escrow systems and
manual records that contain information needed to
answer depositors’ questions on their deposits.

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This schedule is to be completed only by branches
whose deposits are insured by the FDIC. Each FDICinsured branch must complete items 1 and 2, 4 through
6, Memorandum items 1, 6, and 7, and if applicable,
item 3 and Memorandum items 2 and 3 each quarter.
and 6,

in accordance with generally accepted accounting
principles;

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General Instructions

See the Glossary entry for “deposits” for the statutory
definition of deposits.

If unposted debits and unposted credits are included in
the gross total deposit liabilities reported in this item,
they may be excluded in Schedule O, item 2 below.
Item 2 Total allowable exclusions, including interest
accrued and unpaid on allowable exclusions (including
foreign deposits).
Report the total amount of allowable exclusions from
deposits as of the calendar quarter-end report date if
the branch maintains such records as will readily permit verification of the correctness of its reporting of
exclusions. Any accrued and unpaid interest on the
allowable exclusions listed below should also be
reported in this item as an allowable exclusion.
The allowable exclusions include:
(1) Foreign Deposits: As defined in Section 3(l)(5) of
the Federal Deposit Insurance Act, foreign
deposits include
(a) any obligation of a depository institution
which is carried on the books and records of
O-1

June 2021

September 2023

Schedule O

or equal to the sum of Schedule E, item 5, column A,
and item 5, column C.

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Deposits of states and political subdivisions in the U.S.
include deposits of public funds standing to the credit
of states, counties, municipalities, and local housing
authorities; school, irrigation, drainage, and reclamation districts; or other instrumentalities of one or more
states of the United States, the District of Columbia,
Puerto Rico, and U.S. territories and possessions.
Deposits of states and political subdivisions in the U.S.
also include deposits of funds advanced to states and
political subdivisions by U.S. Government agencies
and corporations and deposits of withheld income
taxes of states and political subdivisions.

State law may require an institution to pledge securities
(or other readily marketable assets) to cover the uninsured portion of the deposits of a state or political subdivision. If the institution has pledged securities with a
value that exceeds the amount of the uninsured portion
of the state or political subdivision’s deposits, only the
uninsured amount (and none of the insured portion of
the deposits) should be reported as a “preferred
deposit.” For example, a political subdivision has
$350,000 in deposits at an institution which, under
state law, is required to pledge securities to cover only
the uninsured portion of such deposits ($250,000 in
this example). The institution has pledged securities
with a value of $300,000 to secure these deposits. Only
$250,000 of the political subdivision’s $350,000 in
deposits (the uninsured amount) would be considered
“preferred deposits.”

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(4) For all other deposit accounts, the branch should
make a reasonable estimate of the portion of
these deposits that is uninsured using the data
available from its information systems. In developing this estimate, if the branch has automated
information systems in place that enable it to
identify jointly owned accounts and estimate the
deposit insurance coverage of these deposits, the
higher level of insurance afforded these joint
accounts should be taken into consideration.
Similarly, if the branch has automated information systems in place that enable it to classify
accounts by deposit owner and/or ownership
capacity, the branch should incorporate this
information into its estimate of the amount of
uninsured deposits by aggregating accounts held
by the same deposit owner in the same ownership
capacity before applying the $250,000 insurance
limit. Ownership capacities include, but are not
limited to, single ownership, joint ownership,
business (excluding sole proprietorships), revocable trusts, irrevocable trusts, and retirement
accounts.

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In the absence of automated information systems, a
branch may use nonautomated information such as
paper files or less formal knowledge of its depositors if
such information provides reasonable estimates of
appropriate portions of its uninsured deposits. A
branch’s use of such nonautomated sources of information is considered appropriate unless errors associated with the use of such sources would contribute significantly to an overall error in the FDIC’s estimate of
the amount of insured and uninsured deposits in the
banking system.

Item M3 Preferred deposits.
(To be completed for the December report only.)
Report in this item all deposits of states and political
subdivisions in the U.S. included in Schedule E, item 5,
columns A and C, which are secured or collateralized
as required under state law. Exclude deposits of the
U.S. Government which are secured or collateralized as
required under federal law. Also exclude deposits of
trust funds which are secured or collateralized as
required under state law unless the beneficiary is a state
or political subdivision in the U.S. The amount
reported in this memorandum item must be less than
FFIEC 002

Item M4 & M5
Not Applicable.
Item M6 Outstanding balance of Paycheck Protection
Program (PPP) loans
The PPP was established by Section 1102 of the 2020
Coronavirus Aid, Relief, and Economic Security Act,
which was enacted on March 27, 2020. PPP covered
loans, as defined in Section 7(a)(36) of the Small Business Act (15 U.S.C. 636(a)(36)), are fully guaranteed as
to principal and accrued interest by the U.S. Small
Business Administration.
Report the aggregate amount at which PPP loans held
for investment and held for sale are included in Schedule C, Part I, and PPP loans held for trading are
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March 2021

Schedule O

in this Memorandum item 7 should also be calculated
on a weekly average basis.
Item M8 Sweep deposits
Report in the appropriate subitem the indicated sweep
deposit data (as defined in the Glossary entry for
“Sweep Deposits”).
Item M8(a) Fully insured, affiliate sweep deposits
Report the amount of affiliate sweep deposits that are
fully insured.

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Item M8(b) Not fully insured, affiliate sweep deposits
Report the amount of affiliate sweep deposits for
which less than the entire amount of the deposit is covered by deposit insurance.
Item M8(c) Fully insured, non-affiliate sweep deposits
Report the amount of non-affiliated sweep deposits
that are fully insured.

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included in Schedule RAL, item 1(f)(5), as of the
report date.
Item M7
Not Applicable.
Item M7 Quarterly average amount of holdings of
assets purchased from money market funds under the
Money Market Mutual Fund Liquidity Facility
(MMLF)
To prevent the disruption in the money markets from
destabilizing the financial system, the Board of Governors of the Federal Reserve System authorized the
Federal Reserve Bank of Boston on March 19, 2020, to
establish the MMLF pursuant to Section 13(3) of the
Federal Reserve Act (12 U.S.C. 343(3)). Under the
MMLF, the Federal Reserve Bank of Boston will
extend non-recourse loans to eligible borrowers to purchase eligible assets from money market mutual funds,
which will be posted as collateral to the Federal
Reserve Bank of Boston.
Report the quarterly average amount of holdings of
assets purchased under the MMLF.

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This quarterly average should be consistent with and
calculated using the same averaging method used for
calculating the “Average consolidated total assets for
the calendar quarter” reported in Schedule O, item 4. If
the quarterly average reported in Schedule O, item 4, is
calculated on a daily average basis, the quarterly average reported in this Memorandum item 7 should also
be calculated on a daily average basis. If the quarterly
average reported in Schedule O, item 4, is calculated on
a weekly average basis, the quarterly average reported

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September 2021

September 2023

Item M8(d) Not fully insured, non-affiliate sweep
deposits
Report the amount of non-affiliate sweep deposits for
which less than the entire amount of the deposit is covered by deposit insurance.

Item M9 Total sweep deposits that are not brokered
deposits
Report the total amount of sweep deposits that are
excluded from being reported as brokered deposits.

FFIEC 002


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