FRY7N_FRY7NS_FRY7Q_20231211_omb

Supporting Statement for the
Reports of Foreign Banking Organizations
(FR Y-7N, FR Y-7NS, and FR Y-7Q; OMB No. 7100-0125)
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 Reports of Foreign Banking Organizations (FR Y-7N, FR Y-7NS, and FR Y-7Q;
OMB No. 7100-0125). The FR Y-7N and FR Y-7NS collect financial information for certain1
non-functionally regulated U.S. nonbank subsidiaries held by foreign banking organizations
(FBOs) other than through a U.S. bank holding company (BHC), financial holding company
(FHC), or U.S. bank. For purposes of these reports, an FBO is a foreign bank that operates a
branch, agency, or commercial lending company subsidiary in the United States; controls a bank
in the United States; or controls an Edge corporation acquired after March 5, 1987.2 FBOs file
the FR Y-7N quarterly or annually or the FR Y-7NS annually predominantly based on asset size
thresholds. The FR Y-7Q collects consolidated regulatory capital information from all FBOs
either quarterly or annually.
The Board revised the FR Y-7Q report to (1) add a line item on Part 1A, Capital and
Asset Information for the Top-tier Foreign Banking Organization, to collect the total combined
U.S. assets net of intercompany balances and transactions, based on a quarterly average,
(2) require the three items that capture U.S. assets (total combined U.S. assets net of
intercompany balances and transactions (Part 1A, items 6(a) and 6(b)) and total U.S. non-branch
assets (Part 1A, item 7)) be filed by all respondents on a calendar quarter-end or year-end basis,
(3) as of December 31, 2023, change the due date from 90 days to 70 days after the report date
for all FR Y-7Q filers that also file the Systemic Risk Report (FR Y-15; OMB No. 7100-0352)
and as of December 31, 2024, change the due date from 90 days to 70 days after the report date
for the remaining FR Y-7Q filers who are not eligible to file the FR Y-15, and (4) make other
minor clarifications and conforming edits to the form and instructions. The revisions are
effective for December 31, 2023, for FR Y-7Q respondents that are also required to file the
FR Y-15 report. For all other FR Y-7Q respondents, the revisions are effective December 31,
2024. The FR Y-7N and FR Y-7NS were not revised.
The current estimated total annual burden for the FR Y-7N, FR Y-7NS, and FR Y-7Q is
2,100 hours, and would increase to 2,610 hours. The revisions would result in an increase of 510
hours. The form and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
The International Banking Act of 1978 (IBA) establishes a framework for federal
regulation of foreign banks operating in U.S. financial markets. Section 8(a) of the IBA states that
Filing thresholds for each respective report are defined within the “Description of Information Collection” section
of this document.
2
12 CFR 211.21(o).
1

foreign banks that engage in banking in the United States through a U.S. branch, agency or
subsidiary commercial lending company and companies that control such foreign banks are
subject to the provisions of the Bank Holding Company Act of 1956 (BHC Act). The Federal
Reserve uses the data collected on the FR Y-7N, FR Y-7NS, and FR Y-7Q to assess an FBO’s
ability to be a continuing source of strength to its U.S. operations and to determine compliance
with applicable U.S. laws and regulations. This information is not available from other sources.
Description of Information Collection
The FR Y-7N consists of an income statement and a balance sheet; schedules that collect
information on changes in equity capital, changes in the allowance for loan and lease losses, offbalance-sheet data items, and loans; and a memoranda section. All FBOs file the FR Y-7N
quarterly for their significant nonbank subsidiaries that do not have a primary U.S. regulator
other than the Federal Reserve System. Subsidiaries are defined as significant if they have total
assets of at least $1 billion or off-balance-sheet activities (including commitments to purchase
foreign currencies and U.S. dollar exchange, all other futures and forwards contracts, option
contracts, and the notional value of interest rate swaps, exchange swaps and other swaps) of
$5 billion or more, as of the end of a quarter. FBOs must commence quarterly reporting for a
subsidiary at the end of the quarter in which the subsidiary meets the significance threshold, and
must continue to file quarterly for the remainder of a calendar year even if the subsidiary no
longer satisfies the size requirement for quarterly filing of the FR Y-7N.3 The FR Y-7N is filed
annually, as of December 31, for each individual nonbank subsidiary that does not meet the
criteria for filing quarterly and that has total assets of at least $500 million.
The FR Y-7NS is an abbreviated reporting form that collects net income, total assets,
equity capital, and total off-balance-sheet data items. The FR Y-7NS is filed annually, as of
December 31, by top-tier FBOs for each individual nonbank subsidiary that does not have a
primary U.S. regulator other than the Federal Reserve System (and does not meet the filing
criteria for filing the FR Y-7N) with total assets greater than or equal to $250 million.
The FR Y-7Q collects consolidated capital and asset information from all FBOs. Part 1 of
the reporting form currently collects the following information: tier 1 capital; total risk-based
capital; risk-weighted assets; total consolidated assets; total combined assets of U.S. operations;
net of intercompany balances and transactions between U.S. domiciled affiliates, branches, and
agencies; and total U.S. non-branch assets. In addition, an FBO that files the FR Y-7Q because it
has made an effective election to be treated as an FHC also must provide separate capital
schedules on Part 2 of the FR Y-7Q quarterly for each lower-tier FBO operating a branch,
agency, Edge or agreement corporation, or commercial lending company in the United States.
Part 1A of the FR Y-7Q is filed quarterly by FBOs if the top-tier FBO or any FBO in its tiered
structure has made an effective election to be treated as an FHC and by FBOs with total
consolidated assets of $50 billion or more, regardless of FHC status. Part 1B of the FR Y-7Q is
filed quarterly by FBOs with combined U.S. assets of $100 billion or more, or combined U.S.
assets of less than $100 billion but total consolidated assets of $250 billion or more. The

3

Certain filing thresholds related to the FR Y-7N and FR Y-7NS were modified for reporting periods through
December 31, 2021. See 85 FR 77345 (December 2, 2020).

2

FR Y-7Q is filed annually if the FBO or any FBO in its tiered structure has not effectively
elected to be an FHC and the FBO has total consolidated assets of less than $50 billion.
Respondent Panel
The FR Y-7N, FR Y-7NS, and FR Y-7Q panels comprise top-tier FBOs that are required
to submit the FR Y-7N and FR Y-7NS reports for their nonbank subsidiaries based on the filing
criteria discussed above, as well as top-tier FBOs that file the FR Y-7Q report based on the filng
criteria discussed above.
Frequency and Time Schedule
FBOs are required to file the FR Y-7N (quarterly or annual) and FR Y-7NS reports 60
calendar days after the report date. All FBOs are currently required to file the FR Y-7Q within 90
calendar days after the report date, which would be revised to be 30 days after the report date for
quarterly filers and 45 days after the report date for annual filers.
Proposed Revisions to the FR Y-7Q
The Board proposed to add an additional line item (item 6(b)) on Part 1A, Capital and
Asset Information for the Top-tier Foreign Banking Organization, to collect the total combined
U.S. assets net of intercompany balances and transactions on a quarterly average basis. This line
item would be used for analytical purposes to track the growth of FBOs in the U.S. and to make
reporting more consistent with the reporting of total combined assets of U.S. operations, net of
intercompany balances and transactions in the FR Y-15, which is filed by some FBOs.
The Board also proposed revisions to the FR Y-7Q report to remove the option of filing
on a fiscal year basis and to instead require the respondent to file on a calendar period basis. As
of December 31, 2020, only approximately five percent of respondents submitted the FR Y-7Q
on a fiscal year basis. The elimination of the fiscal filing basis would be consistent with other
Federal Reserve regulatory reports. The change also would enhance the Board’s ability to
monitor FBOs that may be approaching the asset threshold to file the FR Y-15, as well as to
provide data on the same filing frequency basis as with the U.S. legal entity regulatory report
forms (i.e., Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No.
7100-0128) and Consolidated Reports of Condition of Income (FFIEC 031, FFIEC 041, and
FFIEC 051; OMB No. 7100-0036)). In addition, the change would enable calculations for
Regulation TT - Supervision and Regulation Assessments of Fees (12 CFR Part 246)
assessments to be made at the same speed and efficiency as for domestic-only holding
companies, which file the FR Y-9C.
Additionally, the Board proposed revisions to the filing deadline from 90 days after
quarter-end to 30 days after quarter-end for quarterly filers and from 90 days after quarter-end to
45 days for annual filers. Shortening the reporting deadline would allow for more timely analysis
needed for effective FBO supervision. The efficiency gain would also allow for a more expedient
process for Supervision staff to have a full picture of the FBO’s financial structure from parent
company global and U.S. assets, consistent with the FBO’s legal entities. The instructions were

3

modified, effective December 31, 2021, to note that respondents would have the option to submit
the FR Y-7Q report electronically via Reporting Central. Electronic filing provides respondents
with a more efficient option to submit the FR Y-7Q report, reducing the burden associated with
the revised filing deadlines.
Finally, the Board proposed to remove line item 8, as of financial date, in Part 1A and
line item 6, as of financial date, in Part 2, as the elimination of the fiscal year basis reporting
makes these items unnecessary. The Board also proposed to made other minor clarifications and
conforming edits to the form and instructions.
Public Availability of Data
The Board does not publicly release information collected through the FR Y-7N,
FR Y-7NS, and FR Y-Q reports.
Legal Status
The FR Y-7N, FR Y-7NS, and FR Y-7Q are authorized by the BHC Act (12 U.S.C. §
1844(c))4 and the IBA (12 U.S.C. §§ 3105(c), 3106(c), and 3108).5 The FR Y-7N, FR Y-7NS,
and FR Y-7Q are additionally authorized by section 165 of the Dodd-Frank Wall Street Reform
and Consumer Protection Act (12 U.S.C. § 5365).6 The FR Y-7N, FR Y-7NS, and FR Y-7Q are
mandatory.
The information contained on the FR Y-7N, FR Y-7NS, and FR Y-7Q is generally not
considered confidential unless an applicant requests confidential treatment in accordance with
the Board’s Rules Regarding Availability of Information.7 Requests for confidential treatment of
information are reviewed on a case-by-case basis. Information provided on the FR Y-7N,
FR Y-7NS, and FR Y-7Q may be exempt from disclosure pursuant to exemption 4 of the
Freedom of Information Act (FOIA) if it is nonpublic commercial or financial information,
which is both customarily and actually treated as private by the respondent (5 U.S.C. §
552(b)(4)). Submissions of the FR Y-7N, FR Y-7NS, and FR Y-7Q may also contain personnel,
medical, and similar files the disclosure of which would constitute a clearly unwarranted
invasion of personal privacy, which are protected under exemption 6 of the FOIA (5 U.S.C. §
552(b)(6)) or information 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, which are protected under exemption 8 of the FOIA
(5 U.S.C. § 552(b)(8)).

4

Authorizing the Board to require bank holding companies and subsidiaries to submit reports on their financial
condition and compliance with federal law.
5
Authorizing the Board to extend the reporting requirements of the BHC Act to branches, agencies, and affiliates of
FBOs, including nonbanks.
6
Directing the Board to establish enhanced prudential standards for certain companies, including certain FBOs.
7
12 CFR 261.17.

4

Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On May 27, 2022, the Board published an initial notice in the Federal Register (87 FR
32164) requesting public comment for 60 days on the extension, with revision, of the FR Y-7N,
FR Y-7NS, and FR Y-7Q. The comment period for this notice expired on July 26, 2022. The
Board received a joint comment from two trade associations and a comment from an individual
banking organization, and the Board received additional feedback through industry outreach. The
commenters did not support the proposed revisions.
Commenters expressed concern that the proposed line item for top-tier FBOs to report
total combined U.S. assets net of intercompany balances and transactions on a quarterly average
using daily data would impose significant operational costs on FBOs that do not currently
perform the calculation. Specifically, commenters recommended instead to require the line item
only for FBOs that file the FR Y-15 and are in Categories II and III (and potentially Category
IV) of the enhanced prudential standards applicable to FBOs under Regulation YY – Enhanced
Prudential Standards (12 CFR Part 252). Commenters also recommended a longer
implementation period and allowing averaging for the line item to use monthly data when
calculating the averages.
In response to the comments received, the Board has decided to implement the new line
item 6(b) as an average combined U.S. operations asset calculation using monthly data. The
calculation would consist of providing the average of the three month-end balances within the
quarter. Annual filers would provide the average of the three month-end balances of the fourth
quarter of that filing year. Respondents that currently file the FR Y-15 would have this line item
automatically retrieved to the FR Y-7Q from the FR Y-15. The Board believes the modified
requirement accommodates required updates to FBO reporting systems.
Commenters also recommended retaining the option for FBOs to file the FR Y-7Q on a
fiscal year basis. Commenters stated that FBOs that follow a non-calendar fiscal year base their
home country reporting requirements, internal and external financial reporting, and management
information systems around the 90-day filing deadline for the FR Y-7Q. In response to the
comments received, the Board will move forward with a modified approach so that only the
following three items that capture U.S. assets would be required to be filed on a calendar period
basis: line item 6(a), Total combined U.S. assets net of intercompany balances and transactions,
line item 6(b), Total combined U.S. assets net of intercompany balances and transactions, based
on a quarterly average. and line item 7, Total non-branch Assets. The remaining line items on the
FR Y-7Q will continue to be collected with fiscal filing as an option. The Board has also decided
to retain line item 8, as of financial date, in Part 1A and line item 6, as of financial date, in Part 2,
in order to continue the use of the fiscal filing option, which will only apply to non-U.S. asset
line items. FR Y-7Q respondents that are required to file the FR Y-15 would have already
submitted total combined U.S. assets net of intercompany balances and transactions, given that
the FR Y-15 is due 50 calendar days after March 31, June 30, and September 30, and 65 days

5

after December 31. Individual respondents that believe the information they are required to
submit under the FR Y-7Q is nonpublic commercial or financial information, which is both
customarily and treated as private by the respondent, may request confidential treatment of such
information under exemption 4 of the FOIA.
Finally, commenters expressed concern about shortening the filing deadline for the
FR Y-7Q because firms may need more than 30 days to provide capital adequacy information to
their home country supervisor before they report it on the FR Y-7Q. Commenters stated that
modifying home country reporting frameworks to file the information on an accelerated
timetable based on the FR Y-7Q would require significant resources. In response to the
comments received, the Board has modified the proposal to stagger implementation filing
deadlines. The modified proposal will be implemented in two phases. Under phase one, effective
as of December 31, 2023, all FR Y-7Q filers that file the FR Y-15 report no later than 70 days
after the report date. The remaining filers would have 90 days to file the FR Y-7Q after calendar
end. Under phase two, effective as of December 31, 2024, all remaining FR Y-7Q filers report no
later than 70 days after the report date. Moving this implementation date to December 31, 2024,
from the original proposed December 31, 2022, allows additional time for respondents to
implement the necessary system enhancements. Further, fiscal filers with a report date after the
calendar quarter-end periods (e.g. January 31, April 30, July 31, and October 31) inherently have
additional time to submit the FR Y-7Q.
Aside from the changes discussed above, the Board adopted the extension, with revision,
of the FR Y-7N, FR Y-7NS, and FR Y-7Q as originally proposed. On December 11, 2023, the
Board published a final notice in the Federal Register (88 FR 85886).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-7N,
FR Y-7NS, and FR Y-7Q is 2,100 hours, and would increase to 2,610 hours with the revisions.
The estimated number of respondents is based on the actual respondent counts as of
December 31, 2020. These reporting requirements represent less than 1 percent of the Board’s
total paperwork burden.

6

FR Y-7N, FR Y-7NS, and
FR Y-Q

Estimated
Estimated
Estimated
number of
annual
average hours
respondents8 frequency per response

Estimated
annual burden
hours

Current
FR Y-7N (quarterly)
FR Y-7N (annual)
FR Y-7NS
FR Y-7Q (quarterly)
FR Y-7Q (annual)
Current Total
Proposed
FR Y-7N (quarterly)
FR Y-7N (annual)
FR Y-7NS
FR Y-7Q (quarterly)
FR Y-7Q (annual)
Proposed Total

28
14
18
120
30

4
1
1
4
1

7.6
7.6
1
2.25
1.5

851
106
18
1,080
45
2,100

28
14
18
120
30

4
1
1
4
1

7.6
7.6
1
3.25
2.5

851
106
18
1,560
75
2,610

Change

510

The estimated total annual cost to the public for the FR Y-7N, FR Y-7NS, and FR Y-7Q
is $139,125, and would increase to $172,913 with the revisions.9
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.

8

Of these respondents, 1 FR Y-7N (quarterly) filer; 12 FR Y-7N (annual) filers; and 13 FR Y-7NS filers 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. There are no special accommodations given to mitigate the burden on small institutions.
9
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/.

7

Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing these
reports is $161,500 per year.

8