SPST-0153 Regulatory Capital Rules - Endgame NPR - 9-18-2023

SUPPORTING STATEMENT
REPORTING, RECORDKEEPING, AND DISCLOSURE REQUIREMENTS ASSOCIATED WITH
THE REGULATORY CAPITAL RULES

(OMB No. 3064-0153)

INTRODUCTION
This submission is being made in connection with a joint notice of proposed rulemaking (NPR)
published in the Federal Register with the Federal Deposit Insurance Corporation (FDIC), the Office of
the Comptroller of the Currency (OCC), and the Board of Governors of the Federal Reserve System
(FRB) (collectively, the agencies). The current information collection titled, Reporting, Recordkeeping,
and Disclosure Requirements Associated with Regulatory Capital Rules (OMB No. 3064-0153) expires
on August 31, 2026.
A.

JUSTIFICATION
1.

Circumstances and Need
The FDIC’s capital rule at 12 C.F.R. part 324 1 contains disclosure and recordkeeping
requirements associated with minimum capital requirements and overall capital
adequacy standards for insured state nonmember banks, state savings associations, and
certain subsidiaries of those entities. The data is used by the FDIC to evaluate capital
before approving various applications by insured depository institutions, to evaluate
capital as an essential component in determining safety and soundness, and to determine
whether an institution is subject to prompt corrective action provisions.
In July 2023, the agencies issued an NPR that proposes revisions to this information collection.
These revisions include new recordkeeping requirements related to the legal status in bankruptcy
of collateral posted to a qualifying central counterparty (QCCP); the management of hedged
exposures during bankruptcy, reorganization, or restructuring; and the monitoring of operational
risk. The NPR would include new reporting requirements related to the exclusion of certain
operational loss data from a banking organization’s operational risk calculation. The NPR would
also revise existing disclosure requirements and add new disclosure requirements. The disclosure
requirements are laid out in 15 tables (14 of which are applicable to the FDIC), and the overall
number of disclosure requirements has dropped by 54 line items, including all quantitative
disclosures, which are now included in regulatory reporting.

2.

Use of the Information Collected
The FDIC uses the data collected under the rule to fulfill its statutory obligations to
adopt a risk-based capital requirement and assess the adequacy of a qualifying bank’s
risk-based capital. The specific information collection requirements are as follows:

1

In 2014, the FDIC revised its capital rule in accordance with Section 171 of the Dodd-Frank Act, which requires the agencies to
establish minimum risk-based and leverage capital requirements.

1

Minimum Regulatory Capital Ratios
Reporting
Section _.22(b)(2)(iv) states that with prior notice to the FDIC, an FDIC-supervised
institution that results from a merger, acquisition, or purchase transaction and that is not
an expanded risk-based approaches FDIC-supervised institution may change its
accumulated other comprehensive income (AOCI) opt-out election.
Section _.22(c)(4) states that with the prior written approval of the FDIC, an FDICsupervised institution that underwrites a failed underwriting, for the period of time
stipulated by the FDIC, is not required to deduct an investment in the capital of an
unconsolidated financial institution to the extent the investment is related to the failed
underwriting.
Sections _.22(c)(5)(i) and (c)(6) state that a bank, with the prior written approval of the
FDIC, for the period of time stipulated by the FDIC, that underwrites a failed
underwriting is not required to deduct a significant investment in the capital of an
unconsolidated financial institution or an investment in a covered debt instrument if such
investment is related to such failed underwriting.
Section _.22(d)(2)(i)(C) states that a bank, with the prior written approval of the FDIC,
for the period of time stipulated by the FDIC, that underwrites a failed underwriting is
not required to deduct a significant investment in the capital of an unconsolidated
financial institution in the form of common stock if such investment is related to such
failed underwriting.
Section _.22(d)(2)(iii) states that an expanded risk-based approaches FDIC-supervised
institution may change its exclusion preference (to exclude deferred tax assets (DTAs)
relating to adjustments relating to common equity tier 1 capital) only after obtaining the
prior approval of the FDIC.
Section _.22(h)(2)(iii)(A) allows the use of a conservative estimate of the amount of a
bank’s indirect investment in its own capital instruments, its indirect investment in the
capital of an unconsolidated financial institution, or its indirect investment in a covered
debt instrument held through a position in an index, as applicable, with prior approval by
the appropriate agency.
Recordkeeping Requirements
Section _.3(d) of the agencies’ capital rules provide for termination and close-out netting
across multiple types of transactions or agreements if the bank obtains a written legal
opinion verifying the validity and enforceability of the agreement under certain
circumstances and maintains sufficient written documentation of this legal review.

2

Standardized Approach
Reporting
Section _.34(a)(1)(ii) states that an FDIC-supervised institution that is not an expanded
risk-based approaches FDIC-supervised institution may elect to calculate the exposure
amount for all its OTC derivative contracts under the standardized approach for
counterparty credit risk (SA–CCR) in § 324.113(c) by notifying the FDIC, rather than
calculating the exposure amount for all its derivative contracts using CEM.
Section _.37(c)(4)(i)(E) requires that a bank obtain the prior approval of the FDIC to
make any material changes to the policies and procedures describing how it determines
the period of significant financial stress used to calculate its own internal estimates for
haircuts and be able to provide empirical support for the period used.
Recordkeeping Requirements
Section _.35(b)(3)(i)(A) of the agencies’ capital rules require, for a cleared transaction
with a qualified central counterparty (QCCP), that a client bank apply a risk weight of 2
percent, provided that the collateral posted by the bank to the QCCP is subject to certain
arrangements and the client bank has conducted a sufficient legal review (and maintains
sufficient written documentation of the legal review) to conclude with a well-founded
basis that the arrangements, in the event of a legal challenge, would be found to be
legal, valid, binding and enforceable under the law of the relevant jurisdictions.
Section _.37(c)(4)(i)(E) requires that a bank have policies and procedures describing how
it determines the period of significant financial stress used to calculate its own internal
estimates for haircuts and be able to provide empirical support for the period used. In
addition, the bank must obtain the prior approval of the FDIC for to make any material
changes to these policies and procedures.
Section _.41(b)(3) allows for synthetic securitizations a bank’s recognition, for riskbased capital purposes, of a credit risk mitigant to hedge underlying exposures if certain
conditions are met, including the bank’s having obtained a well-reasoned opinion from
legal counsel that confirms the enforceability of the credit risk mitigant in all relevant
jurisdictions.
In addition, section _.41(c)(2)(i) requires that a bank support a demonstration of its
comprehensive understanding of a securitization exposure by conducting and
documenting an analysis of the risk characteristics of each securitization exposure prior
to its acquisition, taking into account a number of specified considerations.
Section .41(c)(2)(ii) requires on an on-going basis (no less frequently than quarterly), a
bank must evaluate, review, and update as appropriate the analysis required under this
section for each securitization exposure.

3

Disclosure Requirements
Section _.42(e)(2) addresses risk-weighted assets for securitization exposures and
requires that a bank publicly disclose that is has provided implicit support to the
securitization and the risk-based capital impact to the bank of providing such implicit
support.
Section _.62(a) specifies a quarterly frequency for the disclosure of information in the
applicable tables set out in section _.63 and, if a significant change occurs, such that the
most recent reported amounts are no longer reflective of the bank’s capital adequacy and
risk profile, it also would require the bank to disclose as soon as practicable thereafter, a
brief discussion of the change and its likely impact. This section would allow for annual
disclosure of qualitative information that typically does not change each quarter,
provided that any significant changes are disclosed in the interim.
Section _.62(b) requires that a bank have a formal disclosure policy approved by the
board of directors that addresses its approach for determining the disclosures it makes.
The policy is required to address the associated internal controls and disclosure controls
and procedures.
Section _.62(c) requires a bank with total consolidated assets of $50 billion or more that
is not an advanced approaches bank, if it concludes that specific commercial or financial
information required to be disclosed under section _.62 is exempt from disclosure by the
agency under the Freedom of Information Act (5 U.S.C. 552), to disclose more general
information about the subject matter of the requirement and the reason the specific items
of information have not been disclosed.
Section _.63(a) requires certain disclosures for each of the last three years beginning on
the effective date of the rule for banks with total consolidated assets of $50 billion or
more that are not advanced approaches banks, including qualitative and quantitative
disclosures related to capital structure, capital adequacy, capital conservation buffer,
general credit risk, counterparty credit risk- related exposures, credit risk mitigation,
securitizations, certain equities, and interest rate risk for non-trading activities.
In addition, section _.63(b) requires quarterly disclosure of a bank’s common equity tier
1 capital, additional tier 1 capital, tier 2 capital, tier 1 and total capital ratios, including
the regulatory capital elements and all the regulatory adjustments and deductions needed
to calculate the numerator of such ratios; total risk-weighted assets, including the
different regulatory adjustments and deductions needed to calculate total risk-weighted
assets; regulatory capital ratios during any transition periods, including a description of
all the regulatory capital elements and all regulatory adjustments and deductions needed
to calculate the numerator and denominator of each capital ratio during any transition
period; and a reconciliation of regulatory capital elements as they relate to its balance
sheet in any audited consolidated financial statements.
Tables 1 through 10 to section _.63 set forth qualitative and quantitative disclosure
requirements for scope of application, capital structure, capital adequacy, capital
4

conservation buffer, credit risk, counterparty credit risk-related exposures, credit risk
mitigation, securitizations, equities not subject to Subpart F of the rule, and interest rate
risk for non-trading activities.
Expanded Risk-Based Approaches
Reporting Requirements
Section _.113(i)(3)(ii)(C) requires prior approval regarding a supervisory delta
adjustment.
Section _.114(d)(6)(vi) requires prior approval regarding exposure amount of a QCCP to
a clearing member.
Section _.150(d)(5) requires prior approval of business indicator exclusions.
Section _.150(e)(3)(i)-(ii) requires prior approval of an operational loss events exclusion.
Recordkeeping Requirements
Section _.114(b)(3)(i)(A) requires that a bank maintain sufficient written documentation
of the legal review for a cleared transaction with a QCCP.
Section _.120(e)(1) requires documentation of legal review of an adjustment for credit
derivatives without restructuring as a credit event.
Section _.121(d)(2)(ii)(C) requires the maintenance of written documentation for certain
eligible margin loans and repo-style transactions subject to the minimum haircut floors.
Section _.130 addresses operational criteria for recognizing the transfer of risk.
Section _.130(b)(3) requires a well-reasoned legal opinion confirming the enforceability
of the credit risk mitigant in all relevant jurisdictions.
Section _.130(c)(2)(i)-(ii) requires a bank to demonstrate its comprehensive
understanding of a securitization exposure for each securitization exposure by conducting
an analysis of the risk characteristics of a securitization exposure prior to acquiring the
exposure and document such analysis within three business days after acquiring the
exposure.
Section _.130(c)(2)(ii) requires that, on an ongoing basis (no less frequently than
quarterly), a bank must evaluate, review, and update as appropriate the analysis required
under this section for each securitization exposure.
Section _.150(f)(1)-(2) requires that a bank must have documentation regarding
operational loss event data collection processes that meet certain requirements.
5

Section _.161(b) requires a bank to a have a formal disclosure policy approved by the
board of directors that addresses its approach for determining the disclosures it makes.
Disclosure Requirements
Section _.20(c)(1)(xiv) requires that the bank disclose to the holders of an offering
instrument (with respect to additional tier 1 capital) that they may be fully subordinated
to interests held by the U.S. government in the event that the FDIC-supervised
institution enters into a receivership, insolvency, liquidation, or similar proceeding.
Section _.20 (d)(1)(xi) requires that the bank disclose to the holders of an offering
instrument (with respect to additional tier 2 capital) that they may be fully subordinated
to interests held by the U.S. government in the event that the FDIC-supervised
institution enters into a receivership, insolvency, liquidation, or similar proceeding.
Section _.162 requires a bank that is an expanded risk-based approaches bank to make
the quantitative disclosures described in Tables 1 through 14. The bank must make
these disclosures publicly available for each of the last three years (that is, twelve
quarters) or such shorter period beginning when the bank becomes subject to Subpart E.
Table 2 to section _.162 addresses disclosures related to capital structure. Table 3 to
section _.162 addresses disclosures related to capital adequacy. Table 4 to section _.162
addresses disclosures related to countercyclical capital buffers. Table 5 to section _.162
addresses general disclosures related to credit risk. Table 6 to section _.162 addresses
general disclosure for counterparty credit risk-related exposures. Table 7 to
section_.162 addresses credit risk mitigation disclosures. Table 8 to section _.162
addresses securitization disclosures. Table 9 to section _.162 addresses disclosures for
entities not subject to Subpart F. Table 10 to section _.162 addresses disclosures related
to interest rate risk for non-trading activities. Table 11 to section _.162 addresses
additional disclosure related to the credit quality of assets. Table 12 to section _.162
addresses general qualitative disclosure requirements related to CVA. Table 13 to
section _.162 addresses qualitative disclosures for banks using the SA-CVA. Table 14 to
section _.162 addresses general qualitative information on operational risk framework
disclosure.
3.

Use of Technology to Reduce Burden
The agencies use information technology to reduce burden on institutions and decrease
costs to insured depository institutions and the agencies. Insured depository institutions
are required to store data in an electronic format allowing timely retrieval for analysis,
reporting and disclosure purposes. Institutions are also encouraged to provide
information for public disclosure on their websites.

4.

Efforts to Identify Duplication
The information collected is institution-specific. The information is used to fully assess
the adequacy of a qualifying bank’s risk-based capital. Substantially all of the information
collected is not otherwise available.
6

5.

Minimizing the Burden on Small Entities
This collection does not have a significant impact on a substantial number of small
entities. In particular, according to Call Report data as of December 31, 2022, there
were 3,038 FDIC-supervised institutions. Only 9 of these FDIC- supervised institutions
are affected by the regulatory capital rule and do not have total assets of less than $850
million therefore meeting the Small Business Administration’s definition of a “small
entity.”

6.

Consequence of Less Frequent Collections
The FDIC would not be able to adequately monitor capital levels and ensure safety and
soundness in covered institutions if the information were collected less frequently.

7.

Special Circumstances
None. This information collection is conducted in accordance with the guidelines in 5 CFR
1320.5(d)(2).

8.

Consultation with Persons Outside the FDIC
The agencies published the proposed rule in the Federal Register (88 FR 64028, September
18, 2023). The comment period on the NPR in connection with the PRA closes on
November 30, 2023.

9.

Payment or Gift to Respondents
None.

10.

Confidentiality
Any information deemed to be of a confidential nature would be exempt from public
disclosure in accordance with the provisions of the Freedom of Information Act (5 U.S.C.
552).

11.

Information of a Sensitive Nature
This information collection contains no sensitive information.

7

12.

Burden Estimates
ESTIMATED HOURLY BURDEN - 2023 Basel III NPR (3064-0153)
Type of
Burden

Estimated
Number of
Respondents

Estimated
Number of
Responses per
Respondent

Estimated
Time per
Response

Frequency of
Response

Total Annual
Estimated
Burden

Reporting

9

1

2.00

On Occasion

18

Reporting

9

1

2.00

On Occasion

18

Cleared Transactions: Documentation of Legal
Review Regarding Risk Weight
Section _.114(b)(3)(i)(A)
Ongoing

Recordkeeping

9

1

1.00

On Occasion

9

Guarantees and Credit Derivatives_Substitution
Approach: Documentation of Legal Review of
Adjustment for Credit Derivatives Without
Restructuring as a Credit Event
Section _.120(e)(1)
One-time

Recordkeeping

9

1

40.00

On Occasion

360

Guarantees and Credit Derivatives_Substitution
Approach: Documentation of Legal Review of
Adjustment for Credit Derivatives Without
Restructuring as a Credit Event
Section _.120(e)(1)
Ongoing

Recordkeeping

9

1

1.00

Annual

9

Collateralized Transactions: Maintain Written
Documentation for Transactions Subject to the
Minimum Haircut Floors
Section _.121(d)(2)(ii)(C)
Ongoing

Recordkeeping

9

1

1.00

On Occasion

9

Recordkeeping

1

1

39.00

On Occasion

39

Recordkeeping

1

1

81.00

On Occasion

81

Recordkeeping

9

4

2.00

Quarterly

72

Operational Risk Capital: Prior Approval of
Business Indicator Exclusions
Section _.150(d)(5)
Ongoing

Reporting

9

1

20.00

On Occasion

180

Operational Risk Capital: Prior Approval of
Operational Loss Events Exclusion
Section _.150(e)(3)(i)-(ii)
Ongoing

Reporting

9

1

40.00

On Occasion

360

Expanded Risk-Based Approach:
REPORTING, RECORDKEEPING, and
DISCLOSURE
Adjusted Derivative Amount: Prior Approval
Regarding Supervisory Delta Adjustment
Section _.113(i)(3)(ii)(C)
Ongoing
Cleared Transactions: Prior Approval Regarding
Exposure Amount of a QCCP to a Clearing
Member
Section _.114(d)(6)(vi)
Ongoing

Operational Criteria for Recognizing the Transfer
of Risk: Legal Opinion
Section _.130(b)(3)
Ongoing
Operational Criteria for Recognizing the Transfer
of Risk: Documentation of Analysis of Risk of
Securitization Exposure -- Section _.130(c)(2)(i)(ii)
One-time
Operational Criteria for Recognizing the Transfer
of Risk - Updating Analysis for Each
Securitization Exposure
Section _.130(c)(2)(ii)
Ongoing

8

Type of
Burden

Estimated
Number of
Respondents

Estimated
Number of
Responses per
Respondent

Estimated
Time per
Response

Frequency of
Response

Total Annual
Estimated
Burden

Recordkeeping

9

1

70.00

On Occasion

630

Operational Risk Capital - Operational Risk
Management and Operational Loss Event Data
Collection Processes DocumentationSection
_.150(f)(1)-(2)
Ongoing

Recordkeeping

9

1

22.00

Annual

198

Disclosure Policy
Section _.161(b)
Ongoing

Recordkeeping

9

1

1.00

Annual

9

Disclosure – Section _.20(c)(1)(xiv), (d)(1)(xi)
Ongoing

Disclosure

9

1

2.00

On Occasion

18

Section _.162
Scope of Application Disclosures: Section _.162,
Table 1
Capital Structure Disclosures: Section _.162,
Table 2
Capital Adequacy Disclosures: Section _.162,
Table 3
Countercyclical Capital Buffer Disclosures:
Section _.162, Table 4
Credit Risk: General Disclosures: Section _.162,
Table 5
General Disclosure for Counterparty Credit RiskRelated Exposures: Section _.162, Table 6
Credit Risk Mitigation Disclosures: Section _.162,
Table 7
Securitization Disclosures: Section _.162, Table 8
Equities Not Subject to Subpart F Disclosure:
Section _.162, Table 9
Interest Rate Risk for Non-Trading Activities
Disclosures: Section _.162, Table 10
Additional Disclosure Related to the Credit
Quality of Assets: Section _.162, Table 11
General Qualitative Disclosure Requirements
Related To CVA: Section _.162, Table 12
Qualitative Disclosures for Banks Using the SACVA: Section _.162, Table 13
General Qualitative Information on Operational
Risk Framework Disclosure: Section _.162, Table
14
One-time

Disclosure

9

1

328.00

On Occasion

2,952

Expanded Risk-Based Approach:
REPORTING, RECORDKEEPING, and
DISCLOSURE
Operational Risk Capital - Operational Risk
Management and Operational Loss Event Data
Collection Processes Documentation
Section _.150(f)(1)-(2)
One-time

9

Expanded Risk-Based Approach:
REPORTING, RECORDKEEPING, and
DISCLOSURE
Section _.162
Scope of Application Disclosures: Section _.162,
Table 1
Capital Structure Disclosures: Section _.162,
Table 2
Capital Adequacy Disclosures: Section _.162,
Table 3
Countercyclical Capital Buffer Disclosures:
Section _.162, Table 4
Credit Risk: General Disclosures: Section _.162,
Table 5
General Disclosure for Counterparty Credit RiskRelated Exposures: Section _.162, Table 6
Credit Risk Mitigation Disclosures: Section _.162,
Table 7
Securitization Disclosures: Section _.162, Table 8
Equities Not Subject to Subpart F Disclosure:
Section _.162, Table 9
Interest Rate Risk for Non-Trading Activities
Disclosures: Section _.162, Table 10
Additional Disclosure Related to the Credit
Quality of Assets: Section _.162, Table 11
General Qualitative Disclosure Requirements
Related To CVA: Section _.162, Table 12
Qualitative Disclosures for Banks Using the SACVA: Section _.162, Table 13
General Qualitative Information on Operational
Risk Framework Disclosure: Section _.162, Table
14
Ongoing
SUBTOTAL: One-time
Recordkeeping, Reporting, and Disclosure

Type of
Burden

Estimated
Number of
Respondents

Estimated
Number of
Responses per
Respondent

Estimated
Time per
Response

Frequency of
Response

Total Annual
Estimated
Burden

Disclosure

9

4

90.00

Quarterly

3,240

4,023

SUBTOTAL: Ongoing
Recordkeeping, Disclosure, and Reporting

4,179

TOTAL RECORDKEEPING, DISCLOSURE, and
REPORTING

8,202
Type of
Burden

Estimated
Number of
Respondents

Estimated
Number of
Responses per
Respondent

Estimated
Time per
Response

Frequency of
Response

Total Annual
Estimated
Burden

Recordkeeping

3,038

1

8.00

On Occasion

24,304

Regulatory Capital Adjustments and Deductions -Prior Approval – Sections _.22(b)(2)(iv), (c)(4),
(c)(5)(i), (c)(6), (d)(2)(i)(C), (d)(2)(iii)
Ongoing

Reporting

1

1

6.00

On Occasion

6

Regulatory Capital Adjustments and Deductions -Prior Approval – Section _.22(h)(2)(iii)(A)
Ongoing

Reporting

3,038

1

2.00

On Occasion

6,076

Minimum Regulatory Capital Ratios:
REPORTING and RECORDKEEPING
Counterparty Credit Risk Operational
Requirements -- Legal Opinion -- Section _.3(d)
Ongoing

SUBTOTAL: One-time Reporting and
Recordkeeping

0

SUBTOTAL: Ongoing Reporting and
Recordkeeping

30,386

TOTAL REPORTING and RECORDKEEPING

30,386

10

Type of
Burden

Estimated
Number of
Respondents

Estimated
Number of
Responses per
Respondent

Estimated
Time per
Response

Frequency of
Response

Total Annual
Estimated
Burden

Reporting

1

1

2.00

On Occasion

2

Cleared Transactions: Cleared Transaction with a
QCCP Risk Weights
Section _.35(b)(3)(i)(A)
One-time

Recordkeeping

1

1

2.00

On Occasion

2

Cleared Transactions: Cleared Transaction with a
QCCP Risk Weights
Section _.35(b)(3)(i)(A)
Ongoing

Recordkeeping

3,038

1

2.00

Annual

6,076

Collateralized Transactions: Internal Estimates for
Haircuts
Section _.37(c)(4)(i)(E)
One-time

Recordkeeping

1

1

80.00

On Occasion

80

Collateralized Transactions: Internal Estimates for
Haircuts
Section _.37(c)(4)(i)(E)
Ongoing

Recordkeeping

3,038

1

16.00

Annual

48,608

Operational Requirements for Securitization
Exposures:
Legal Opinion Regarding Operational Criteria for
Synthetic Securitizations, Section _.41(b)(3)
Document Analysis of Operational Criteria for
Synthetic Securitizations, Section _.41(c)(2)(i)
One-time

Recordkeeping

1

1

40.00

On Occasion

40

Operational Requirements for Securitization
Exposures:
Document Analysis of Operational Criteria for
Synthetic Securitizations, Section _.41(c)(2)(ii)
Ongoing

Recordkeeping

3,038

4

2.00

Quarterly

24,304

Reporting

1

1

1.00

On Occasion

1

Disclosure

1

1

226.25

On Occasion

226

Disclosure

1

1

20.00

Annual

20

Disclosure

1

4

111.25

Quarterly

445

Standardized Approach:
REPORTING, RECORDKEEPING, and
DISCLOSURE
Derivative Contracts: Exposure Amount
Methodology Section _.34(a)(1)(ii)
Ongoing

Collateralized Transactions: Internal Estimates for
Haircuts
Section _.37(c)(4)(i)(E)
Ongoing
Risk-Weighted Assets for Securitization
Exposures: Implicit Support Disclosure -- Section
_.42(e)(2)
Credit Risk: Disclosures – Sections _.62(a),(b), &
(c)
Credit Risk: Quantitative and Qualitative
Disclosures – Sections _.63(a) & (b) and _.63
Tables
One-time
Risk-Weighted Assets for Securitization
Exposures: Implicit Support Disclosure -- Section
_.42(e)(2)
Ongoing
Credit Risk: Disclosures – Sections _.62(a),(b),&
(c)
Credit Risk: Quantitative and Qualitative
Disclosures – Sections _.63(a) & (b) and _.63
Tables
Ongoing

11

SUBTOTAL: One-time
Recordkeeping, Reporting, and Disclosure

348

SUBTOTAL: Ongoing
Recordkeeping, Reporting, and Disclosure

79,456

TOTAL RECORDKEEPING, REPORTING, and
DISCLOSURE

79,804
TOTAL ESTIMATED HOURLY BURDEN
Total One-Time Burden Hours

4,371

Total Ongoing Burden Hours

114,021

TOTAL BURDEN HOURS

118,392

Annualized Cost of Internal Hourly Burden:

118,392 hours x $89.62981 per hour = $10,611,475.
Summary of Hourly Burden Cost Estimate (OMB No. 3064-0153)
Percentage Shares of Hours Spent by and
Hourly Compensation Rates for each Occupation Group
(by Collection)

Information
Collection
Request
Regulatory
Capital Rules

Exec. & Mgr.
($133.82)

Lawyer
($165.76)

Compl. Ofc.
($64.61)

Fin. Anlst.
($101.15)

Clerical
($37.83)

10

15

15

30

30

Estimated Hourly
Compensation Rate

$89.62981

Source: Bureau of Labor Statistics: National Industry-Specific Occupational Employment and Wage Estimates: Industry:
Credit Intermediation and Related Activities (5221 And 5223 only)' (May 2021), Employer Cost of Employee
Compensation (March 2021), and Employment Cost Index (March 2021 and December 2022). Standard Occupational
Classification (SOC) Codes: Exec. And Mgr = 11-0000 Management Occupations; Lawyer = 23-0000 Legal Occupations;
Compl. Ofc. = 13-1040 Compliance Officers; Fin. Anlst. = 13-2051 Financial and Investment Analysts; Clerical = 43-0000
Office and Administrative Support Occupations.
Note: The estimated hourly compensation rate for this ICR is the average of the hourly compensation rates for the
occupations used to comply with that collection, weighted by the share of hours spent by each occupation.

13.

Capital, Start-Up and Maintenance Costs
None.

14.

Estimated Annual Cost to the Federal Government
None. The reports are processed by existing FDIC staff.

15.

Reason for Change in Burden
The NPR modifies the reporting, recordkeeping, and disclosure requirements of the
regulatory capital rules by adding new requirements and revising existing reporting,
recordkeeping, and disclosure requirements. As a result, there is an increase in burden
hours of 24,771 hours.

12

16.

Publication
The information is not published.

17.

Display of Expiration Date
Not applicable.

18.

Exceptions to Certification
None.

B.

STATISTICAL METHODS
Not applicable.

13