FFIEC 101 18 Question Format OMB Supporting Statement

Supporting Statement for the
Regulatory Capital Reporting for Institutions Subject to the
Advanced Capital Adequacy Framework
(FFIEC 101; OMB No. 7100-0319)
1.

Explain the circumstances that make the collection of information necessary.

The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, without revision, the
Federal Financial Institutions Examination Council (FFIEC) Regulatory Capital Reporting for
Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101; OMB No.
7100-0319). The FFIEC 101 collects data regarding the levels and components of risk-based
capital from firms subject to the Board’s advanced approaches capital framework (advanced
approaches framework), as well as data regarding the supplementary leverage ratio (SLR) from
firms subject to that requirement. The FFIEC 101 must be filed quarterly by certain large or
internationally active state member banks (SMBs), bank holding companies (BHCs), savings and
loan holding companies (SLHCs) that are subject to the advanced approaches framework and
other Board-regulated institutions that adopt the framework on a voluntary basis (collectively,
advanced approaches banking organizations); additionally, certain BHCs, SLHCs, SMBs, and
U.S. intermediate holding companies (IHCs) that are not advanced approaches banking
organizations must report only certain information regarding the SLR. The extention to the
FFIEC 101 that is the subject of this request has been approved by the FFIEC. The Federal
Deposit Insurance Corporation (FDIC) and the Office of the Comptroller of the Currency (OCC)
(together with the Board, the agencies) have also submitted similar requests for OMB review to
request this information from banks under their supervision.
2.

Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current collection.

The mandatory FFIEC 101 report collects information from all Board-regulated advanced
approaches banking organizations, as well as information regarding the SLR from Category III
institutions. Advanced approaches banking organizations are required to submit detailed data on
the components of their capital and risk-weighted assets in nineteen schedules (A through S).
Category III institutions must complete only Schedule A, SLR Tables 1 and 2.
Advanced Approaches Regulatory Capital and Summary Risk-Weighted Asset
Information. Schedule A collects information about the components of Tier 1 capital, Tier 2
capital, and adjustments to regulatory capital as defined within the rule. Schedule B contains
summary information about risk-weighted assets by risk type, and, in the case of credit risk
exposures, outstanding balances and aggregated information about the drivers and estimates that
underlie the calculation of risk-weighted assets. Tables 1 and 2 of Schedule A collect
information about each advanced approaches banking organization and top-tier Category III
BHCs, SHCs, and SMBs, and all Category III IHCs SLR, the ratio of tier 1 capital to total
leverage exposure. Table 1 reconciles balance sheet assets reported in published financial
statements and total leverage exposure. Table 2 collects components of on-balance sheet and off-

balance sheet exposures, for the calculation of total leverage exposure, tier 1 capital, and the
calculation of the SLR.
Schedule B collects general exposure information from advanced approaches banking
organizations. Respondents must report:
• Wholesale exposures, including separate reporting for the following types of exposures:
Corporate; Bank; Sovereign; Income producing real estate; High volatility commercial
real estate; Eligible margin loans, repo-style transactions, and OTC derivatives with cross
product netting; and Eligible margin loans, repo-style transactions, and OTC derivatives
without cross product netting,
• Retail Exposures, including separate reporting for the following types of exposures:
Residential mortgage closed-end first liens, Residential mortgage closed-end junior liens,
Residential mortgage revolving exposures, Qualifying revolving exposures, and Other
retail exposures,
• Securitization exposures,
• Cleared transactions, including separate reporting for the following types of exposures:
Derivative contracts and netting sets to derivatives, Repo-style transactions, and Default
fund contributions,
• Equity exposures, and
• Other assets; including separate reporting for the following types of exposures: Unsettled
transactions, Assets not included in a defined exposure category, Non-material portfolios
of exposures, Credit valuation adjustments, Assets subject to the general risk-based
capital requirements, Excess eligible credit reserves not included in Tier 2 capital,
Advanced market risk equivalent assets; and Operational risk.
Some of the aggregate data items submitted in Schedule B are derived from information
contained in the more detailed confidential supporting schedules described below. The data
contained in Schedule B describe the main summary-level components of respondents’ riskweighted assets.
Wholesale Exposures. Schedules C through J request data on respondents’ wholesale
exposures. Each schedule represents a sub-portfolio of the wholesale exposure category as listed
on Schedule B. For each reported sub-portfolio, the schedule groups exposures into sub-portfolio
segments using supervisor-defined probability of default (PD) ranges. The reported cells within
these schedules then describe the main risk parameters and characteristics of each sub-portfolio
segment.
Retail Exposures. Schedules K through O request data on respondents’ retail exposure
category. Each schedule represents a sub-portfolio of the retail exposure category as listed on
Schedule B. PD ranges are used to sub-divide each sub-portfolio into segments.1 The reported
cells within these schedules then describe the main risk parameters and characteristics of each
sub-portfolio segment. The retail schedules also incorporate risk characteristics that are believed
to be commonly used drivers within respondents’ risk management and measurement processes,
1

Unlike the wholesale credit exposure reporting schedules, the PD ranges for retail exposures differ from subportfolio to sub-portfolio.

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including the distribution of each sub-portfolio segment by loan-to-value ranges (applies only to
real estate exposures), weighted average credit bureau score, and weighted average account age.2
Securitization Exposures. Schedule P requests data on respondents’ securitization and
resecuritization exposures that are subject to either the supervisory formula approach, the
simplified supervisory formula approach, a 1250 percent risk weight, or deduction. A respondent
completes Schedule P by providing information on exposure amount, risk-weighted asset
amount, and deduction amount for each securitization and resecuritization based on the treatment
the exposure is subject to under the rule.
Cleared Transactions. Schedule Q requests data on respondents’ cleared transaction
exposures. The schedule divides cleared transactions into subcategories relating to the Clearing
member client bank and to the Clearing member bank. For the Clearing member client bank
category, a respondent completes Schedule Q by providing exposure amount and risk weighted
asset amount information on derivative contracts or netting sets of derivative contracts and repostyle transactions. Schedule Q requests that respondents provide exposure amount from default
fund contributions and risk-weighted asset amounts for exposures within the Clearing member
bank category, which include derivative contracts or netting sets of derivative contracts, repostyle transactions, and default fund contributions to non-qualified and qualified central
counterparties.
Equities. Schedule R requests information about respondents’ equity exposures by type of
exposure and by approach to measuring required capital. Schedule R also requests information
on equity exposures subject to specific risk weights and equity exposures to investment funds. A
respondent completes the appropriate section of the schedule based on whether it uses a simple
risk-weight approach, a full internal models approach, or a partially modeled approach to
measuring required capital for equity exposures.
Operational Risk. Schedule S requests data on respondents’ operational risk exposure.
Data items submitted in this schedule include various details about historical operational losses,
on a stand-alone and group-wide basis, for the current reporting period and those historical
operational losses used to model operational risk capital. The schedule also requests data related
to scenarios, distribution assumptions, and loss caps used to model operational risk capital.
3.

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

All affected institutions must submit their completed reports electronically using the
Federal Reserve’s Reporting Central application.

2

For qualifying revolving exposures and other (non-mortgage) retail exposures, the exposure at default of accounts
under two years old is reported instead of weighted average age for each sub-portfolio exposure segment.

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4.

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

The data collected through the FFIEC 101 are unique and cannot be replaced by data
already collected by the federal government.
5.

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

Of the respondents to the FFIEC 101, none are considered small entities as defined by the
Small Business Administration (i.e., entities with less than $850 million in total assets). Size
standards effective March 17, 2023. See https://www.sba.gov/document/support-table-sizestandards.
6.

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

Less frequent reporting would reduce the ability of the Board to identify and respond in a
timely manner to noncompliance with minimum regulatory capital ratios, adverse risk trends that
become apparent in the forward-looking risk estimates reported by respondents, and evidence of
risk estimates that call into question the accuracy of a bank’s capital calculation or place other
institutions with similar types of exposures at a competitive disadvantage. To be most useful as
an off-site analytical tool, these reports are intended to correspond to the frequency and timing of
other regulatory submissions including the Consolidated Reports of Condition and Income (Call
Report) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036) and the Board’s
Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No. 7100-0128).
7.

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

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

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

On June 29, 2023, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (88 FR 42131) requesting public comment for 60 days on the
extension, without revision, of the FFIEC 101. The comment period for this notice expired on
August 28, 2023. The agencies did not receive any comments. On October 13, 2023, the
agencies, under the auspices of the FFIEC, published a final notice in the Federal Register (88
FR 71083) requesting public comment for 30 days on the extension, with revision, of the
FFIEC 101. The comment period for this notice expires on November 13, 2023.

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9.

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

10.

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

For report dates before a reporting institution has completed its parallel run period,
Schedule A, except for items 78, 79, and 86-90, is released to the public. All of the information
reported in the other schedules of the FFIEC 101 will be confidential. For report dates after
reporting institution has completed its parallel run period, all items reported in Schedules A and
B (except for Schedule B, items 31.a and 31.b, column D) and items 1 and 2 of Schedule S will
be available to the public. All other items reported in the FFIEC 101 will be confidential. All
items reported on Schedule A, SLR Tables 1 and 2, are available to the public.
A reporting institution may request confidential treatment for some or all of the portions
of the FFIEC 101 report that will be made available to the public if the institution is of the
opinion that disclosure of specific commercial or financial information in the report would likely
result in substantial harm to its competitive position, or that disclosure of the submitted
information would result in an unwarranted invasion of personal privacy. If a reporting
institution requests confidential treatment, the Board will determine whether the information is
entitled to confidential treatment on a case-by-case basis. To the extent a reporting institution
submits confidential commercial or financial information in connection with the FFIEC 101,
which is both customarily and actually treated as private by the reporting institution, the
reporting institution may request confidential treatment pursuant to exemption 4 of the FOIA.
Finally, the Board uses data from the FFIEC 101 to supplement on-site examination
processes. Therefore, this information can be kept confidential under FOIA exemption 8,
because it is matter contained in or related to examination, operating, or condition reports
prepared by, on behalf of, or for the use of an agency responsible for the regulation or
supervision of financial institutions.
11.

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

12.

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

As shown in the table below, the estimated total annual burden for the FFIEC 101 is
35,288 hours. These reporting requirements represent less than 1 percent of the Board’s total
paperwork burden.

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Estimated
number of
respondents
4
9

FFIEC 101
SMBs
BHCs and SLHCs
BHCs and SLHCs
(SLR Tables 1 and 2 only)
IHCs

5
6

Estimated
Estimated
annual
average hours
frequency per response
4
674
4
677
4
4

3
3

Total

Estimated
annual burden
hours
10,784
24,372
60
72
35,288

The estimated total annual cost to the public for the FFIEC 101 is $2,337,830.
Total cost to the responding public is estimated using the following formula: total burden
hours, multiplied by the cost of staffing, where the cost of staffing is calculated as a percent of
time for each occupational group multiplied by the group’s hourly rate and then summed (30%
Office & Administrative Support at $22, 45% Financial Managers at $80, 15% Lawyers at $79,
and 10% Chief Executives at $118). Hourly rates for each occupational group are the (rounded)
mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment and
Wages, May 2022, published April 25, 2023, https://www.bls.gov/news.release/ocwage.t01.htm.
Occupations are defined using the BLS Standard Occupational Classification System,
https://www.bls.gov/soc/.
13.

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

14.

Provide estimates of annualized costs to the Federal government.

The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 101 is $157,700.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.
There are no changes or adjustments.

16.

Provide information regarding plans for publication of data.

For report dates before a reporting institution has completed its parallel run period,
Schedule A will be available to the public, except for items 78 (total eligible credit reserves
calculated under the advanced approaches rules), 79 (amount of eligible credit reserves
includable in tier 2 capital), 86 (expected credit loss that exceeds eligible credit reserves);
87 (advanced approaches risk-weighted assets), 88 (common equity tier 1 capital ratio calculated
using the advanced approaches), 89 (additional tier 1 capital ratio calculated using the advanced
approaches), and 90 (total capital ratio using the advanced approaches). Information reported in

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all other schedules of the FFIEC 101 are confidential. For report dates after a reporting
institution has completed its parallel run period, all items reported in Schedules A and B (except
for Schedule B, items 31.a and 31.b, column D) and items 1 and 2 of Schedule S are available to
the public. All other items reported in the FFIEC 101 are confidential. Note that for both before
and after an institution has completed its parallel run period, all items reported on Schedule A,
SLR Tables 1 and 2, are available to the public.
Individual respondent data, excluding confidential information, are available on the
National Information Center public website.
17.

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

18.

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

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