FR2590_20231228_omb

Supporting Statement for the
Single-Counterparty Credit Limits
(FR 2590; OMB No. 7100-0377)
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 Single-Counterparty Credit Limits (FR 2590; OMB No. 7100-0377) reporting form,
associated other reporting requirements, and recordkeeping requirements. The FR 2590 was
implemented in connection with the Board’s single-counterparty credit limits rule (SCCL rule),1
codified in the Board’s Regulation YY - Enhanced Prudential Standards (12 CFR Part 252)2 and
the Board’s Regulation LL – Savings and Loan Holding Companies (12 CFR Part 238).3
The information collected by the FR 2590 reporting form allows the Board to monitor a
covered company’s or a covered foreign entity’s compliance with the SCCL rule. A covered
company is any U.S. bank holding company (BHC) that is subject to Category I, II, or III
standards or any savings and loan holding company (SLHC) that is subject to Category II or III
standards. A covered foreign entity is a foreign banking organization (FBO) that is subject to
Category II or III standards or that has total global consolidated assets of $250 billion or more,
and any U.S. intermediate holding company (IHC) that is subject to Category II or III standards.
In addition to the reporting form, the FR 2590 information collection incorporates notice
requirements pertaining to requests that may be made by a covered company or covered foreign
entity to request temporary relief from specific requirements of the SCCL rule, as well as a
requirement that filers of the FR 2590 reporting form retain an exact copy of each completed
FR 2590.
The Board revised the FR 2590 reporting form to clarify that a foreign banking
organization that meets the large exposure standards on a consolidated basis established by its
home-country supervisor is not required to provide additional documentation as part of its
FR 2590 submission. The Board also clarified that a respondent should use tier 1 capital data and
total consolidated assets data that is concurrent with its FR 2590 submission when calculating
and reporting compliance with the SCCL rule. The Board also clarified that respondents should
retain manually signed and attested copies of the cover page of the FR 2590 form and of the data
submitted for three years, in accordance with similar requirements for other regulatory reports.
The Board also clarified that the order of counterparties should be the same across Schedules
G-1 through G-4, Schedules M-1 through M-2, and the Summary of Net Credit Exposures.
Finally, the Board revised Schedule M-1 by adding an additional table for firms calculating
derivative transaction exposures using the standardized approach for counterparty credit risk
(SA-CCR) to report collateral received in connection with those derivative transactions. These
revisions are effective for the June 30, 2024, as of date.
The current estimated total annual burden for the FR 2590 is 56,719 hours, and would
1

83 FR 38460 (August 6, 2018). See also 84 FR 59032 (November 1, 2019) (finalizing the SCCL rule for SLHCs).
See 12 CFR Part 252, Subparts H and Q.
3
See 12 CFR Part 238, Subpart Q.
2

remain the same with the revisions. The form and instructions are available on the Board’s public
website at https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
As demonstrated during the 2007-2008 financial crisis, large credit exposures to
individual counterparties, particularly between financial institutions, can spread financial distress
and undermine financial stability. Section 165(e) of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (Dodd-Frank Act)4 directed the Board to prescribe regulations that
prohibit covered companies and covered foreign entities from having a credit exposure to any
unaffiliated company that exceeds 25 percent of the capital stock and surplus of the covered
company or covered foreign entity, or such lower limit as the Board may determine by regulation
to be necessary to mitigate risks to the financial stability of the United States. In order to
implement section 165(e) of the Dodd-Frank Act, the Board adopted the SCCL final rule in the
third quarter of 2018. The Board then adopted the SCCL rule for SLHCs in 2019, pursuant to
section 10(g) of the Home Owners’ Loan Act (HOLA).5
The Board’s SCCL rule applies a single-counterparty credit limit to covered companies
and covered foreign entities, generally using a base of tier 1 capital, and, for U.S. global
systemically important bank holding companies (G-SIBs), applies an additional singlecounterparty credit limit for exposures between major counterparties.6 The SCCL rule requires
each covered company and covered foreign entity to calculate its aggregate net credit exposure to
a counterparty using the methods set forth in the rule and sets limits on the aggregate net credit
exposure that each covered company and covered foreign entity may have to the counterparty. In
addition, certain provisions in the SCCL rule permit a covered company or covered foreign
entity to request temporary relief from specific requirements of the rule.
The FR 2590 reporting form collects information necessary to allow the Board to monitor
respondents’ compliance with the SCCL rule. Additionally, aside from the FR 2590 reporting
form, the FR 2590 information collection incorporates certain notices required by the SCCL rule
and a recordkeeping requirement. This information is not available from other sources.
Description of Information Collection
Reporting Requirements
FR 2590 Reporting Form
The FR 2590 reporting form is designed comprehensively to capture the credit exposures
of a respondent organization to its counterparties in accordance with the SCCL rule. The rule
prohibits any covered company from having an aggregate net credit exposure to an unaffiliated
counterparty in excess of 25 percent of its tier 1 capital and prohibits a G-SIB from having
4

Codified at 12 U.S.C. § 5365(e).
12 U.S.C. § 1467a(g).
6
Under the SCCL rule, a “major counterparty” is defined as a covered company that is a G-SIB, certain large FBOs,
and any nonbank financial company supervised by the Board (12 CFR 252.71(x), 252.171(y)).
5

2

aggregate net credit exposures to any major counterparty in excess of 15 percent of its tier 1
capital. The SCCL rule applies similar single-counterparty credit limits to covered foreign
entities. However, the SCCL rule allows an FBO to comply with the rule by certifying to the
Board that it meets, on a consolidated basis, a single-counterparty credit limit established by its
home country supervisor that is consistent with the Basel Committee on Banking Supervision’s
large exposure standard (BCBS Large Exposure Standard).
The FR 2590 reporting form requests general information about the respondent
organization (e.g., the respondent organization’s amount of its capital stock and surplus, and
whether the respondent is considered a major counterparty under the rule). The form also asks
any respondent that is an FBO whether that FBO is certifying to the Board that it meets large
exposure standards on a consolidated basis established by its home country supervisor that are
consistent with the BCBS Large Exposure Standard. The form requires identification of
counterparties by name and by entity type (e.g., sovereign, securitization). The form then
requests data needed to calculate the respondent organization’s credit exposures, which are
reported on nine schedules. Five of these schedules (Schedules G-1 through G-5) collect
information related to the gross exposures of the respondent organization to various
counterparties. A respondent organization must add the exposure amounts in the five G
schedules to calculate its aggregate gross credit exposure. A respondent organization would then
calculate its net credit exposure by adjusting its gross credit exposures using Schedules M-1 and
M-2, which collect information related to eligible collateral and other eligible credit risk
mitigants (e.g., eligible guarantees), respectively. The respondent organization must take into
account special provisions in the SCCL rule that require aggregation of certain connected
counterparties due to economic interdependence—meaning the underlying risk of one
counterparty’s financial distress or failure would cause the financial distress or failure of another
counterparty, as indicated by the presence of certain enumerated factors in the SCCL rule—or
due to the presence of certain control relationships described in the rule.7 Data relevant to
understanding the presence of any relationships that require such aggregation are reported in
Schedules A-1 and A-2. In filling out the schedules described above, the respondent organization
must report exposures by counterparty, with a single counterparty in each row. The form requires
each respondent organization to report its top 50 counterparties.
Schedule G-1: General Exposures. This schedule contains seven general gross credit
exposure categories that are described in the SCCL rule:8 (1) deposits, (2) loans and leases,
(3) debt securities or investments, (4) equity securities or investments, (5) committed credit lines,
(6) guarantees and letters of credit, and (7) securitization arising from the look-through
approach.9 These gross exposures are summed together, by counterparty, in the final column of
Schedule G-1.

7

The requirement to aggregate counterparties based on these relationships can be found in sections 252.76 and
252.176 of the Board’s Regulation YY, and section 238.156 of the Board’s Regulation LL.
8
See sections 252.73, 252.75, 252.173, and 252.175 of Regulation YY, and sections 238.153 and 238.155 of
Regulation LL.
9
Calculation of gross credit exposure as a result of item (7) (securitization arising from the look-through approach)
is described in sections 252.75 and 252.175 of Regulation YY and section 238.155 of Regulation LL. Gross credit
exposure to a securitization that does not require application of the look-through approach would be reported as
either item (3) (debt securities or investments) or item (4) (equity securities or investments), as applicable.

3

Schedule G-2: Repurchase Agreement Exposures. This schedule collects gross credit
exposures arising from repurchase agreements and reverse repurchase agreements as provided in
the SCCL rule.10 It requires the respondent organization to identify the assets transferred and
received in the transaction. Examples include sovereign debt, non-sovereign debt, main index
equities, and cash. The penultimate column asks for the total gross credit exposure under
bilateral netting agreements. The final column tallies the total gross credit exposure resulting
from these transactions by counterparty.
Schedule G-3: Securities Lending Exposures. This schedule collects similar information
to that collected in Schedule G-2 with respect to securities lending and securities borrowing
transactions. Again, the final column tallies the total gross credit exposure resulting from these
transactions by counterparty.
Schedule G-4: Derivatives Exposures. Schedule G-4 requires the respondent organization
to report the gross notional value of its derivatives transactions by counterparty, consistent with
the SCCL rule.11 If the respondent organization has been authorized by the Board to use internalmodels-based methodologies, then it can report its exposures using the “Internal Model Method”
columns.12 Another column in Schedule G-4 is available for a respondent organization to report
gross credit exposures resulting from qualifying master netting agreements.13 All respondent
organizations are required to complete the total gross credit exposure column.
Schedule G-5: Risk Shifting Exposures. Schedule G-5 collects information related to
gross credit exposures that have been affected by the risk shifting requirements of the SCCL
rule.14 Risk shifting is required when a respondent organization employs six types of credit risk
mitigants: (1) eligible collateral, (2) eligible guarantees, (3) eligible credit and equity derivatives,
(4) other eligible hedges, (5) unused portion of certain extensions of credit, and (6) credit
transactions involving excluded and exempt entities. The final column aggregates the total gross
exposure, by counterparty, due to risk shifting.
Schedule M-1: Eligible Collateral. The SCCL rule permits a respondent organization to
subtract the value of any eligible collateral provided by a counterparty in connection with a
particular transaction from its gross credit exposure for that transaction.15 The value of all such
eligible collateral is reported in Schedule M-1. Eligible collateral includes, but is not limited to,
sovereign debt, non-sovereign debt, main index equities, other publicly traded equities, and cash.
The final column sums the total credit risk mitigation impact due to eligible collateral, by
counterparty.
Schedule M-2: General Risk Mitigants. Schedule M-2 collects information related to
credit risk mitigation techniques other than the receipt of collateral used by the firm to reduce its
10

See sections 252.73 and 252.173 of Regulation YY and section 238.153 of Regulation LL.
Id.
12
If the respondent organization has not been authorized by the Board to use internal-models-based methodologies,
the organization should leave these columns blank.
13
“Qualifying master netting agreement” is defined in sections 252.71(cc) and 252.171(dd) of Regulation YY and
section 238.151(aa) of Regulation LL.
14
See sections 252.74 and 252.174 of Regulation YY and section 238.154 of Regulation LL.
15
Id.
11

4

gross credit exposure in a given transaction. Permitted credit risk mitigation methods described
in the SCCL rule are (1) eligible guarantees, (2) eligible credit and equity derivatives, (3) other
eligible hedges, (4) unused portion of certain extensions of credit, and (5) credit transactions
involving excluded and exempt entities.16 The final column sums the total credit risk mitigation
effected by use of these techniques, by counterparty.
Summary of Net Credit Exposures. The reporting form contains a summary sheet that
sums the respondent organization’s aggregate gross credit exposure (as reported in the final
columns of each of the five G schedules); calculates the respondent organization’s aggregate net
credit exposures by reducing its aggregate gross credit exposure by its aggregate credit risk
mitigants (calculated by taking the sum of the final columns of the two M schedules); and
divides the respondent organization’s aggregate net credit exposure by its tier 1 capital. The
resulting ratio shows whether the respondent organization’s aggregate net credit exposures
comply with the limits of the SCCL rule.
Schedule A-1: Economic Interdependence. The SCCL rule17 requires a covered company
or covered foreign entity to aggregate its net credit exposures to counterparties that are
economically interdependent—meaning that the underlying risk of one counterparty’s financial
distress or failure would cause financial distress or failure of another counterparty—if its
aggregate net credit exposure to a counterparty exceeds 5 percent of its tier 1 capital. The SCCL
rule enumerates specific factors that those covered companies or covered foreign entities must
consider in order to assess whether counterparties are economically interdependent. Such factors
include whether 50 percent or more of one counterparty’s gross revenue is derived from the other
counterparty, or whether two or more counterparties rely on the same source for the majority of
their funding, and, in the event of the common provider's default, an alternative provider cannot
be found.18 The SCCL rule requires that counterparties that must be aggregated be treated as a
single counterparty (reported in Schedule A-1 as an “interconnected counterparty group”) for
purposes of the aggregate net credit exposure limits of the rule. Schedule A-1 requires the
respondent organization to provide its aggregate net credit exposure to each member of the
interconnected counterparty group (one per column). The final column of Schedule A-1 sums the
total net credit exposure of the respondent organization to each connected counterparty group.
Schedule A-2: Control Relationships. The SCCL rule requires a covered company or
covered foreign entity to aggregate exposures to counterparties due to the presence of certain
control relationships.19 The rule requires that counterparties that are connected by certain
specified control relationships be treated as a single counterparty (reported in Schedule A-2 as a
“control counterparty group”) for purposes of the aggregate net credit exposure limits of the
SCCL rule. Schedule A-2 requires the respondent organization to provide its aggregate net credit
16

Id.
See sections 252.76(b) and 252.176(b) of Regulation YY and section 238.156(b) of Regulation LL.
18
A covered company or covered foreign entity is required to conduct an assessment for economic interdependence
only if its aggregate net credit exposure to a counterparty exceeds 5 percent of its tier 1 capital. See sections
252.76(a) and 252.176(a) of Regulation YY and section 238.156(a) of Regulation LL. If none of the enumerated
factors is met, then the covered company or covered foreign entity need not aggregate exposures to those
counterparties unless the Board determines that one or more other counterparties of the covered company or covered
foreign entity are economically interdependent. Id.
19
See sections 252.76(c) and 252.176(c) of Regulation YY and section 238.156(c) of Regulation LL.
17

5

exposure to each member of the interconnected counterparty group (one per column). The final
column of Schedule A-2 sums the total net credit exposure of the respondent organization to
each control counterparty group.
Notice Requirements in the SCCL Rule
Certain provisions in the SCCL rule permit a covered company or covered foreign entity
to request temporary relief from specific requirements of the rule. Specifically, the SCCL rule
permits a covered company or covered foreign entity to request temporary relief from
requirements to aggregate one or more counterparties even if one or more factors indicating
economic interdependence or control relationships are met, subject to certain conditions,
including that such relief be in the public interest and consistent with the purpose of the rule.20
The SCCL rule also permits a covered company or covered foreign entity that is not in
compliance with the requirements of the rule to request a special temporary credit exposure limit
exemption from the Board to permit continued credit transactions with that counterparty, based
upon a finding that those transactions are necessary or appropriate to preserve the safety and
soundness of the covered company or U.S. financial stability.21 These notices must be submitted
to the Board and are not part of the FR 2590 report.
Recordkeeping Requirements
Respondents must maintain in their files an electronic version of the signature page and
of the data submitted.
Respondent Panel
The FR 2590 panel comprises U.S. BHCs that are subject to Category I, II, or III
standards, FBOs that are subject to Category II or III standards or that have total global
consolidated assets of $250 billion or more, and SLHCs and U.S. IHCs that are subject to
Category II or III standards.
Frequency and Time Schedule
The FR 2590 form is submitted and retained quarterly. Requests for exemptions to certain
aspects of the SCCL rule are submitted on an event-generated basis. Respondent organizations
are generally required to file the FR 2590 report form on a quarterly basis, consistent with the
SCCL rule’s compliance requirements.22 Respondents file the FR 2590 report quarterly, as of the
close of business on March 31, June 30, September 30, and December 31. Submissions are due
40 calendar days after March 31, June 30, and September 30, and 45 calendar days after
December 31. However, if the submission deadline falls on a weekend or holiday, the report
20

See sections 252.76(b)(3), 252.76(c)(2), 252.176(b)(3), and 252.176(c)(2) of Regulation YY and sections
238.156(b)(3) and 238.156(c)(2) of Regulation LL.
21
See sections 252.78(c)(2) and 252.178(c)(2) of Regulation YY and section 238.158(c)(2) of Regulation LL.
22
A respondent organization must report compliance on a quarterly basis, unless the Board determines and notifies
the covered company or covered foreign entity in writing that more frequent compliance is required. See sections
252.78(a)(2) and 252.178(a)(3) of Regulation YY and section 238.158(a)(2) of Regulation LL.

6

must be received on the first business day after the Saturday, Sunday, or holiday.
Revisions to the FR 2590
The Board made four clarifications and one revision to the FR 2590 form and
instructions. The Board clarified that a respondent that is an FBO subject to a large exposure
standard on a consolidated basis established by its home-country supervisor that is consistent
with the framework established by the BCBS may simply report that on line 1 of the FR 2590
and is not required to submit additional documentation of compliance. This clarification is
intended to confirm the intention expressed in the Federal Register notice for the final FR 2590
form, which states that “submission of the FR 2590 report with this [certification] box checked
generally will be sufficient to meet the reporting requirement of the SCCL rule.”23 The revised
instructions specify that a respondent may be required to provide additional information or
reporting concerning its counterparty credit exposures upon written request by the Board,
consistent with the SCCL rule.
The Board further clarified that a respondent organization should use the tier 1 capital
amount reported on the Consolidated Financial Statements for Holding Companies (FR Y-9C;
OMB No. 7100-0128) or on the Capital and Asset Report for Foreign Banking Organization
(FR Y-7Q; OMB No. 7100-0125) for the same reporting period as the FR 2590 form being
submitted when calculating and reporting compliance with the SCCL rule (meaning that the
FR 2590 form reporting compliance for Q1 of a given year should use the tier 1 capital amount
reported by the firm on the FR Y-9C or FR Y-7Q for Q1 of that same year). Similarly, the
amount included for the most recent quarter for calculating total consolidated assets on the
FR Y-9C or FR Y-7Q should be that which is reported for the same reporting period as the
FR 2590 form being submitted. To the extent that a firm’s tier 1 capital or total consolidated
assets change significantly within a given quarter due to unplanned events (e.g., asset
deterioration), the Board believes that it would be appropriate for a respondent organization to
manage and to limit its net credit exposure to counterparties based on its actual tier 1 capital or
assets, including, if necessary, by reducing net credit exposure to a specific counterparty. This
would be consistent with the purpose of the SCCL rule, which is to limit the risks posed to
covered companies by the failure of any individual firm.24
The Board also clarified that a respondent organization must maintain in their files a
physical or electronic scanned copy of the manually signed and attested printout of the data
being submitted for a period of three years after submission, with the signed cover page of the
FR 2590 being sufficient to fulfill the signature and attestation requirement. This requirement is
aligned with other regulatory reporting forms and is intended to ensure appropriate oversight and
accountability regarding submitted data. Currently, FR 2590 respondents are required to
maintain these records, but the instructions do not specify the duration of the recordkeeping
requirement.
The Board also clarified in the FR 2590 form that the order of counterparties should be
the same across Schedules G-1 through G-4, M-1 through M-2, and the Summary of Net Credit
23
24

84 FR 64070, 64071 (November 20, 2019).
83 FR 38460, 38461 (August 6, 2018); see also 12 U.S.C. § 5365(e)(1).

7

Exposures.
The Board also revised Schedule M-1 of the FR 2590 to allow respondents calculating
derivative transaction exposures using SA-CCR to report collateral received in connection with
those derivative transactions in a new Table B. Table B would not be included in the
respondent’s summary of net credit exposures. For valuing credit exposures resulting from
derivative transactions, firms are authorized to use any method they would be authorized to use
for purposes of calculating compliance with the Board’s risk-based capital requirements,
including the internal models method (IMM), the current exposure method (CEM), or
SA-CCR.25 Firms using either CEM or IMM are currently able to report accurate derivative
exposures.26 Firms calculating derivative exposures under SA-CCR, however, have experienced
difficulties under the FR 2590 and current instructions in reporting accurately their gross credit
exposure, collateral, and net credit exposure because collateral is factored directly into the
SA-CCR calculation and cannot truly be separated out into the elements specified on FR 2590.27
For example, a respondent reporting both its gross credit exposure as calculated using SA-CCR
and collateral received as separate items would cause collateral to be double-counted when
calculating its net credit exposures, resulting in artificially lower net credit exposures with
respect to the SCCL rule. To avoid this double-counting, some respondents chose to not report
collateral in such cases.
Because of the importance of collateral as a risk mitigant, especially in exiting defaulted
positions, the Board created a new table (Table B) in Schedule M-1 to allow respondents
calculating derivative transaction exposures using SA-CCR to accurately report their exposure
and collateral in connection with those derivative transactions. This information is consistent
with other information requested by FR 2590 and is not readily available through other
regulatory reporting forms.
Notices associated with requests for temporary relief from specific requirements of the
SCCL rule must be provided to the Board when a firm seeks such a request.
Public Availability of Data
No data collected by this information collection are published.
Legal Status
The FR 2590 is authorized pursuant to section 165(e) of the Dodd-Frank Act (12 U.S.C. §
5365(e)) and section 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. §

25

Note that only advanced approaches firms may request to use internal models. See 12 CFR 217, Subpart E.
Firms using IMM use two dedicated columns on Schedule G-4. A firm using CEM would report the gross credit
exposure of derivative netting sets (pre-collateral exposure at default) on Schedule G-4, report collateral on
Schedule M-1, report net credit exposures by deducting the collateral reported on Schedules M-1 from the gross
credit exposures in Schedule G-4, and report risk-shifted exposures on Schedule G-5 for the adjusted market value
of non-cash collateral.
27
Under SA-CCR, collateral is included in both the recovery cost and the potential future exposure. See 12 CFR
217, Subpart D.
26

8

1844(c)), with respect to BHCs, FBOs, and IHC,28 and sections 10(g) and 10(b) of the HOLA,
with respect to SLHCs (12 U.S.C. §§ 1467a(b)(2) and (g)(1)). The FR 2590 reporting and
recordkeeping requirements are mandatory, and the notice provision related to requests for
temporary relief from specific requirements of the SCCL rule is required to obtain a benefit.
The data collected on the FR 2590 form are generally kept confidential under
exemption 4 of the Freedom of Information Act (FOIA), which protects from disclosure trade
secrets and commercial or financial information (5 U.S.C. § 552(b)(4)), and exemption 8 of
FOIA, which protects from disclosure information related to the supervision or examination of a
regulated financial institution (5 U.S.C. § 552(b)(8)). Regarding notices associated with requests
for temporary relief from specific requirements of the SCCL rule, a firm may request
confidential treatment under the Board’s rules regarding confidential treatment of information at
12 CFR 261.17. The Board will consider whether such information may be kept confidential in
accordance with any applicable FOIA exemption.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System with respect to the
extension, with revision, of the FR 2590.
Public Comments
On September 11, 2023, the Board published an initial notice in the Federal Register (88
FR 62364) requesting public comment for 60 days on the extension, with revision, of the
FR 2590. The comment period for this notice expired on November 13, 2023. The Board did not
receive any comments relevant to the revision of this collection or to the Paperwork Reduction
Act. The Board adopted the extension, with revision, of the FR 2590 as originally proposed. On
December 28, 2023, the Board published a final notice in the Federal Register (88 FR 89691).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2590 is 56,719
hours, and would remain the same with the revisions. The Board understands that banks collect
and monitor SA-CCR data as part of internal monitoring and risk management of derivative
positions. Additionally, SA-CCR collateral reporting is currently part of the FR 2590 reporting
requirement and the new Table B will now enable firms to report exposures and collateral under
SA-CCR accurately. Therefore, the Board expects that no additional burden would be imposed
with these revisions. The estimated number of respondents is based on FR 2590 report form
filings as of December 31, 2022. With regard to the notice requirements pertaining to requests
for temporary relief from specific requirements of the SCCL rule, only firms that seek such
requests need to file any documentation. The burden estimate was produced using the standard
Board burden calculation methodology. These reporting and recordkeeping requirements
represent less than 1 percent of the Board’s total paperwork burden.

28

FBOs (and by extension their IHC subsidiaries) are subject to the requirements of the BHC Act pursuant to
section 8 of the International Banking Act of 1978 (12 U.S.C. § 3106).

9

FR 2590

Estimated
number of
respondents29

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

83

4

170.56

56,626

1
83

1
4

10
0.25

10
83
56,719

Reporting
Sections 252.73, 252.74, 252.75,
252.76(b), 252.76(c), 252.173,
252.174, 252.175, 252.176(b), and
252.176(c) and
Sections 238.153, 238.154,
238.155, and 238.156
FR 2590 Form
Sections 252.76(b)(3),
252.76(c)(2), 252.78(c)(2),
252.176(b)(3), 252.176(c)(2), and
252.178(c)(2) and
Sections 238.156(b)(3),
238.156(c)(2), and 238.158(c)(2)
Requests for temporary relief
Recordkeeping
Total

The estimated total annual cost to the public for the FR 2590 is $3,757,634, and would
remain the same with the revisions.30
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
information collection is $160,500.

29

Of these respondents, 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-size-standards.
30
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/.

10