Country Exposure Report for U.S. Branches and Agencies of Foreign Banks

INSTRUCTIONS FOR PREPARATION OF

Country Exposure Report
for U.S. Branches and Agencies
of Foreign Banks
FFIEC 019

General Instructions
Who Must Report
This report is required each quarter for each branch or
agency of a foreign bank domiciled in the 50 states of
the United States and the District of Columbia that
has total direct claims (including those of its IBF) on
“foreign residents,” as defined later in these instructions, in excess of $30 million or more on the quarterly
report date. (For purposes of this report, Puerto Rican
banks are not considered to be foreign banks; therefore, U.S. branches and agencies of Puerto Rican
banks are not required to submit this report.)
A separate report is to be filed by each branch or
agency that meets the reporting criteria. However,
branches and agencies of the same foreign parent bank
that file the Report of Assets and Liabilities of U.S.
Branches and Agencies of Foreign Banks
(FFIEC 002) on a consolidated basis may also file this
report on that basis.

Scope
This report requires information on the distribution by
country of claims on non-U.S. residents held by U.S.
branches and agencies (including their IBFs) of foreign
banks. Each reporting branch and agency must report
its gross claims on: (1) residents of its home country
(including related non-U.S. offices of the reporting
institution) and (2) residents of foreign countries for
which its adjusted exposure (i.e., direct claims adjusted
for guarantees and other indirect claims) for the country is greater than or equal to $20 million.
Claims are initially reported by the country of direct
obligor and are then adjusted to reflect any guarantees
FFIEC 019

of parties in other countries. The report covers all
extensions of credit, as well as legally binding loan
commitments and letters of credit. The adjusted claims
on unrelated foreign residents are reported for each
country shown by type of borrower and by the remaining maturity.

Filing of Report
The Federal Reserve acts as the collecting and processing agent of this report for the federal supervisory
authorities. Reporting institutions are required to submit the report quarterly as of the last calendar day each
quarter. Reports must be submitted within 45 calendar
days of the report date. For institutions that do not
wish to submit the report electronically, the original
and two copies of the completed report shall be submitted each quarter to the Federal Reserve Bank in
whose district the reporting branch or agency is
located. Institutions that wish to submit the report
electronically should contact their district Reserve
Bank or go to http://www.frbservices.org/centralbank/
index.html for procedures for electronic submission.
This website also includes a link that reporters may use
to contact the Federal Reserve Bank of New York for
technical assistance.

Valuation
All amounts reported on this form should be valued in
U.S. dollars. Claims denominated in other currencies
should be converted into dollars using the exchange
rate prevailing on the report date.

Rounding
Amounts reported on this form should be rounded to
the nearest million dollars.
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General Instructions

Differences between FFIEC 019 Reporting
and U.S. GAAP
The differences in accounting treatment between
FFIEC 019 reporting and U.S. GAAP are as follows:
Reporting Item
Netting of
Derivative
Contracts

Netting of
Trading Assets

1

U.S. GAAP

FFIEC 019

Offsetting of
positive and
negative fair values is permitted
when a “right of
setoff ” exists
under ASC Subtopic 210-20, Balance Sheet – Offsetting.
Although the
FASB accounting
standards codification (ASC)
does not address
CUSIP netting, it
is industry practice to net trading
assets against
trading liabilities
in the same security (i.e., with the
same CUSIP or
ISIN).1

Offsetting of positive and negative
fair values is permitted, consistent
with U.S. GAAP.
However, only net
positive fair values
are reported on the
FFIEC 019.
CUSIP netting is
allowed for the
FFIEC 019 report.
In addition, short
positions in the
same issuer and
asset class of the
trading asset may
be reported as an
offsetting positions
for trading book.

A Committee on Uniform Securities Identification Procedures
(CUSIP) number or an International Securities Identification
Number (ISIN) is used to uniquely identify a specific security.

Definitions Of Terms Used In The
Report
United States (U.S.)
For purposes of the classification of the reporter’s customers in this report, the term “United States” covers
the 50 states of the United States, the District of
Columbia, Puerto Rico, and territories and possessions of the United States.
Note: This is consistent with the definitions used for
the FFIEC 002 report and for the Treasury International Capital (TIC) Forms.

Foreign Resident/Non-U.S. Resident
For purposes of this report, the terms “foreign resident” and “non-U.S. resident” include any individual,
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partnership, or corporation, and any government or
political subdivision, agency, or instrumentality
thereof, located outside the United States, including
non-U.S. offices related to the reporting branch or
agency. These terms also include any international or
regional organization (or subordinate or affiliated
agency thereof) created by treaty or convention
between sovereign states.
For determining residence, reporting institutions
should use the customer’s principal address. However,
claims on a representative of a foreign government that
operates in an official capacity (e.g. an embassy)
should be considered as direct claims on that foreign
country, regardless of the place of residence of the representative. Claims on international or regional organizations should not be considered as claims on the
country in which such organizations are located;
instead, all such organizations are to be treated as a
single “country” (see list of country names and codes).

Related Non-U.S. Offices
These include:
(1) the head office of the reporting branch or agency
and the bank’s branches and agencies that are
located outside the United States;
(2) the foreign holding company of the bank;
(3) other foreign banks (including their branches and
agencies outside the United States) that are
majority-owned by organizations described in
either (i) or (ii) above, or by their majority-owned
subsidiaries; and
(4) any other majority-owned subsidiaries of 1, 2, or
3 above.
Note: This definition of related non-U.S. offices covers
the same institutions as the term “related institutions
domiciled outside the United States” used in the
FFIEC 002 report.

Unrelated Foreign Residents
Includes all non-U.S. residents, both bank and nonbank, other than “related non-U.S. offices” as defined
above.
FFIEC 019

General Instructions

Foreign Public Borrowers

Claims

The term “foreign public borrowers” covers the following institutions: central governments and departments
of central governments of foreign countries and their
possessions; foreign central banks, stabilization funds,
exchange authorities, and government-owned banks
that perform the functions of a central bank or a bank
of issue; corporations and other agencies of central
governments, including development banks, development institutions, and nonbank commercial enterprises whose shares are majority-owned by the central
government or its departments; and state, provincial
and local governments of foreign countries and their
departments and agencies. “Foreign public borrowers”
also includes any international or regional organization
(or subordinate or affiliated agency thereof) created by
treaty or convention between sovereign states.

In this report, a distinction is made between “direct
claims” on given countries and “indirect claims.”A
“direct claim” on a given country is one in which the
immediate obligor is a resident of that country; an
“indirect claim” occurs when a resident of another
country, through guarantees or other means, is the
“ultimate” obligor upon whom the reporting institution can make claims in the event the immediate obligor is unable to satisfy the claim. Claims on related
U.S. branches should not be reported as a direct or
indirect claim on the country of the head office.
The term “claims” follows the definition for assets in
the instructions for preparation of the FFIEC 031 and
FR Y-9C and includes, but is not limited to, the following types of assets:
• Vault Cash

Unrelated Foreign Banks
For purposes of this report, the term “unrelated foreign banks,” which is a component of “unrelated foreign residents” (see above), covers the following institutions domiciled in foreign countries except those that
are “related non-U.S. offices” (see above): commercial
banks, savings banks, discount houses, and other similar institutions accepting short-term deposits. “Unrelated foreign banks” includes such banking institutions
that are owned by foreign governments unless such
institutions function as central banks or banks of issue,
in which case they are treated as “foreign public borrowers.” (See above.) Also included as unrelated foreign banks are the foreign branches of U.S. commercial
banks.

• Deposit balances, both interest bearing and noninterest bearing, held at banks
• Balances with central banks and official institutions
• Securities
• Federal funds sold
• Loans
• Holdings of acceptances of banks
• Direct lease financing
• Investments in unconsolidated subsidiaries and associated companies
• Positive fair value of interest rate, foreign exchange,
equity, commodity and other derivative contracts

Note: This definition of unrelated foreign banks is the
same as the definition of “banks in foreign countries”
used for the FFIEC 002 report.

• Customers’ liability on acceptances outstanding

Other Unrelated Foreign Residents

• Resale agreements and other financing agreements
(reported net if permitted under ASC Subtopic
210-20)

The term “Other unrelated foreign residents” covers
persons, businesses and institutions other than those
defined as either “foreign public borrowers” (above) or
as “unrelated foreign banks” (above).
FFIEC 019

• Accrued income receivables (including interest, commissions and income earned or accrued and applicable to current or prior periods, but not yet
collected)

• Asset sales with recourse
• Participations and syndications of loans
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General Instructions

• Deferred tax assets

• Securities held for the respondent’s own account

Exclude: Premises, right-of-use assets, other real estate
owned, bank-owned life insurance, company-owned
life insurance, physical commodities held in inventory,
pension assets, goodwill, and other intangible assets.

• Federal funds sold and securities purchased under
agreements to resell

Adjusted Claims

• Holdings of acceptances of non-U.S. banks

The adjustment referred to in this report requires the
respondent to deduct from the direct claims on each
country those claims that are guaranteed by parties in
another country and to add to the direct claims on
each country those direct claims on other countries
(including the United States) that parties in the country have guaranteed. Total “adjusted claims” or total
“adjusted exposure” refers to the total figure for a
given country that results from making these adjustments. Claims on unrelated parties that are guaranteed
by the reporter’s head office or a related branch or
agency should not be shifted to the country of the head
office, branch or agency.

• Direct lease financing

For example, a loan to a resident of Country A that is
guaranteed by a resident of Country B is a direct claim
on Country A and an indirect claim on Country B. In
the totals of direct claims, the amount of the loan
would be included in the figure for Country A; in the
totals of adjusted claims, it would be excluded from the
figure for Country A and included in the figure for
Country B. The examples on pages 12–17 illustrate this
process. In the examples, as in the report form, Column
1 shows direct claims on each country to be reported;
Column 2 shows the amount of direct claims on each
country that is guaranteed by parties in other countries
and that must be deducted to calculate adjusted claims;
and Column 3 shows the amount of direct claims on
residents of other countries that residents of each
country have guaranteed. Finally, Column 4 shows the
total adjusted claims on each country and reflects the
adjustments for such “external” guarantees.

Direct Claims
The term “direct claims” refers to the following types
of gross claims (denominated either in U.S. dollars or
in foreign currencies):
• Balances with banks
• Balances with foreign central banks and official
institutions
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• Loans, as defined in the instructions to the
FFIEC 002 report

• Customers’ liability on acceptances outstanding
(excludes own acceptances purchased which are
shown as loans and prepaid acceptances
(anticipations)).
(Note: If the reporting branch or agency is an accepting institution and has contracted with other institutions for them to participate in its acceptance liability
in any way, the total amount of the customer’s liability
on the acceptance, with no deduction for the participation, is to be treated in this report (similar to the
requirements for the FFIEC 002) as a claim held by the
accepting bank. Correspondingly, the participating
institutions do not treat their participation in the
acceptance as a claim in this report.)
• Accrued income including interest, commissions,
and income earned or accrued and applicable to current or prior periods, but not yet collected.
• Any other asset that results in a claim on a foreign
resident.
When distributing direct claims by country, claims on a
branch (or agency) of a bank are to be treated as direct
claims on the country where the branch is located,
regardless of the location of the branch’s head office.
(Such claims, however, are also treated as indirect
claims on the country of the head office, as described
in the next paragraph.)

Indirect Claims
For purposes of this report, the term “indirect claims”
covers “guarantees”and other indirect claims for which
adjustments (additions and subtractions) to direct
claims are required to be made in Columns 2–3.
“Guarantees,” for purposes of this report, consist of
those claims of the reporting institution for which a
third party formally and legally obligates itself to repay
the reporting institution’s claims on the direct obligor
if the latter fails to do so. Documents—such as comFFIEC 019

General Instructions

fort letters, letters of awareness, or letters of intent—
that do not establish firm legal obligations are not considered guarantees for the purpose of this report.
Guarantees of direct claims on foreign residents must
explicitly pass the transfer risk to the guarantor.
(Direct claims on U.S. residents have no transfer risk,
by definition.) Limited guarantees, such as those that
just cover political risk, do not qualify as guarantees
for the purposes of this report. The term “guarantees”
covers the collateralization of claims if the collateral is
both (1) tangible and liquid, including readily marketable shares of stocks or bonds; and (2) is held “and realizable outside of the country of residence of the borrower. In cases involving collateral, the residence of the
“guaranteeing” party, for purposes of the report, is the
country in which the collateral is held unless the collateral is stocks or bonds, in which case it is the country of
residence of the party issuing the security.
The term “guarantees” also includes credit derivative
contracts in the form of off-balance sheet, bilateral
over-the-counter (OTC) swaps and options (including
credit default swaps and options, total return swaps
and sovereign risk options) when the reporting institution is the beneficiary of a contract that it considers to
be an effective guarantee based on its internal criteria
and, for a direct claim on a foreign resident, the contract contains provisions to pass the transfer risk to the
counterparty. In such cases, the reporting institution’s
internal criteria should, at a minimum, include provisions that:
• ensure the terms of credit derivatives provide an
effective guarantee, even in the case of a maturity
mismatch,
• prohibit clauses that reduce the effectiveness of the
guarantee in the case of default,
• contain effectual events of default, and
• reference the same legal entity.
For purposes of this report, claims on a branch or
agency (but not a subsidiary unless explicitly guaranteed as defined in the first paragraph of this section),1
located in one country whose parent bank is headquartered in another country are considered to be “guaran1. However, if the subsidiary is a related non-U.S. institution as
defined in “unrelated non-U.S. offices,” that amount should be reported
in Column 3 and Column 5.

FFIEC 019

teed” by the head office. Accordingly, a reporting institution having a direct claim on such a branch or agency
is considered to have an indirect claim on the foreign
parent bank. For example, a claim on a U.S. branch of
a Swiss bank would be a direct claim on a U.S. resident
and an indirect claim on a Swiss resident.
Examples of Indirect Claims
Required Risk Transfers
The outward and inward redistribution of claims from
an “immediate-counterparty” basis to an
“ultimate-risk.”
If full credit protection is provided by more than one
source, e.g., from multiple guarantors or multiple
forms of collateral, the ultimate-risk claim should be
determined by the sector and residence of the highest
rated credit enhancer (using the reporter’s internal rating system). For instance, for a claim on a bank branch
for which eligible collateral is posted, it should be
determined whether the counterparty’s parent bank or
the collateral has a higher credit rating. The claim
should then be reported, accordingly, on an ultimaterisk basis.
(1) Guarantees
Guarantees are legally binding commitments by a
third party to repay a debt if the direct obligor
fails to do so. Guarantees include financial and
performance standby letters of credit and acceptances (for the amount of the participation sold).
Documents that do not establish legal obligations, such as “comfort” letters, letters of awareness, or letters of intent, are not guarantees for
the purpose of this report.
Guarantees provided by the reporter’s head office
or other consolidated units of the reporter should
not be considered guarantees for the purposes of
this report.
Guarantees providing protection to the reporter
should result in the reallocation of the claim from
the sector and country row of the immediate
Ownership of fund shares in an unconsolidated
investment entity should be reported on an
immediate-counterparty and ultimate-risk basis
according to the country and sector of the investGEN-5

March 2022

General Instructions

ment entity. The underlying assets of the investment fund do not provide an effective guarantee
for purposes of the FFIEC 019 report.
(2) Insurance Policies
Insurance policies that guarantee payment of a
claim if the borrower defaults or if nonconvertibility occurs should be reallocated to the nonbank sector of the country of residence of the
entity providing the insurance. However, limited
purpose policies, such as “political risk insurance” policies should not be used as a basis for
reallocation. Conversely, if a reporter issues an
insurance policy guaranteeing the payment of a
claim if a foreign borrower defaults, the amount
of the protection sold.
(3) Head Offices
For the purposes of this report, claims on a bank
branch (but not on a subsidiary) of a banking
organization are considered to be guaranteed by
the head office of the organization, even without
a legally binding agreement. Therefore, claims on
bank branches should be reallocated to the bank
sector in the country in which the parent institution is chartered.
(4) Reporting Credit Derivatives
a. Risk Transfers
Reporters should report credit derivative contracts purchased (including, but not limited
to, credit default swaps and options, total
return swaps and sovereign risk options), as
guarantees for purposes of this report, provided the institution considers the arrangement to be an effective credit risk mitigant
based on its internal criteria and provided the
contract contains provisions to pass the credit
risk to the counterparty. A reporter’s internal
criteria should, at a minimum, include provisions that ensure the terms of credit derivatives provide an effective guarantee, even in
the case of a maturity mismatch, prohibit
clauses that reduce the effectiveness of the
guarantee in the case of default, contain
effectual events of default, and reference the
same legal entity as the obligor.
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Claims for which credit derivatives form an
effective risk transfer should be reallocated to
the sector and country of residence of the
entity that is providing the protection.
Credit protection purchased to guarantee a
claim reported on an immediate-counterparty
basis should be reported.
If the notional amount of the credit protection purchased is less than the amount of the
immediate claim, the notional amount of the
guaranteed portion should be reallocated to
the sector and country of the credit protection seller, and the nonguaranteed portion
should be reported opposite the sector and
country of the immediate obligor.
For contracts with variable notional principal
amounts, report the notional principal
amounts as of the report date.
b. Treatment of Multi-Name Credit Derivatives
Purchases and sales of credit derivatives guaranteeing multiple underlying reference entities
(i.e., multi-name instruments, including portfolio or basket credit default swaps (CDS),
CDS indexes, and “tranched” CDS contracts)
should be reported on the FFIEC 019. However, only non-tranche index and single name
CDS contracts may be used to risk transfer an
immediate claim.
Regardless of whether reported on, if the
underlying basket is composed of reference
entities located in one country, report the full
notional amount of the contract opposite the
country of the reference entity. If the underlying basket is composed of several securities
from several countries, the underlying reference entities should be reported on a pro-rata
basis.
CDS tranches and bespoke CDS, such as
Nth-to-default contracts, and similar credit
derivative contracts, should be reported on.
For these types of contracts, if the underlying
reference entities are domiciled in multiple
countries and payments to the protection
buyer are not triggered by a credit event in a
particular reference entity, but are triggered
FFIEC 019

General Instructions

by a default past a predetermined threshold,
the notional value of the contract should be
reported in the “Unallocated” row.
(5) Collateralized Claims
Eligible collateral for risk transfers on the
FFIEC 019 includes collateral that is:
(1) Liquid and readily realizable, and
(2) Is realizable outside of the country of residence of the borrower.
Eligible collateral includes:
Cash
If collateral is in the form of cash, the sector and
country of the “guaranteeing” party is the sector
and country of residence of the legal entity where
the cash is held (i.e., the legal entity that has the
liability for the cash collateral). Cash collateral
posted to the same sector and country as the
immediate claim should result in no risk transfer.
Debt and Equity Securities
If collateral is in the form of investment grade
debt or marketable equity securities, the sector
and country of the “guaranteeing” party is the
sector and country of residence of the party issuing the security.
However, in the case of resale agreements, securities lending arrangements, and other similar
financing agreements, the claims should be allocated based on the counterparty, not the underlying
collateral (i.e., no risk-transfer should be made).
These should be reported at the value of the outstanding claim, regardless of the amount of collateral provided. Resale agreements should also be
reported by country of the counterparty.
If the collateral consists of a basket of convertible
currencies or investment grade securities of different countries in an amount equal to the immediate claim, break out the underlying exposures
on a pro-rata basis and report opposite the appropriate country and sector.
Collateral provided in the form of cash or securities in excess of the amount of the outstanding
claim (e.g., a margin loan collateralized by securities with a fair value that exceeds the amount of
FFIEC 019

the margin loan) should only be risk-transferred
up to the amount of the underlying claim
Collateral provided by obligors to offset positive
fair value positions of derivative contracts using
the same methodology for reporting securities
and cash collateral as stated above. If the reporter
has a derivative contract with a positive fair value,
and cash (or securities) collateral is provided,
according to the sector and country of the institution holding (or issuing) the collateral, and the
uncollateralized portion should be reported
according to the sector and country of the
counterparty.
Assets such as real estate are not liquid or readily
realizable and thus cannot be used for a risk
transfer.
(6) Risk Participations
Loans and acceptances, where the reporting bank
has sold a legally binding risk participation, are
considered to be guaranteed by the purchaser of
the participation for the amount of the participation sold.
Netting and Offsetting
Netting and offsetting of long and short positions is
not permitted on the FFIEC 019 report with the exception of the following:
“CUSIP netting”:2

(1) CUSIP netting should only be applied when the
office of the reporter with the position, the
country of the issuer of the underlying security,
and the counterparty to a short position are in
the same country.
(2) as appropriate, the net notional value of credit
derivative contracts purchased from and sold to
the same counterparty and on the same underlying reference entity. Netting may be done only
when all the following apply: (1) there are offsetting purchased and sold positions on the same
reference entity (on a legal entity basis), (2) the
contracts are with the same counterparty, (3) the
2. “CUSIP netting” refers to the industry practice where trading
assets and trading liabilities in the same security (based on its unique
security identifier) may be reported on a net basis.

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General Instructions

contracts are subject to a legally enforceable
master netting agreement. The positive fair values of derivative contracts may be offset against
negative fair values of derivatives contracts if,
and only if, the positions were executed with the
same counterparty under a legally enforceable
master netting agreement and the offsetting
meets the ASC Subtopic 210-20 criteria. Otherwise, positive fair values must be reported gross.
In addition, reverse repurchase agreements may
be offset by repurchase agreements if, and only
if, the transactions were executed with the same
counterparty under a legally enforceable master
repurchase agreement (including multi-jurisdictional and multi-branch master netting agreements) and the offsetting meets the criteria in
ASC Subtopic 210-20, Balance Sheet— Offsetting. When repurchase agreements are covered
by master repurchase agreements, net claim
positions should be reported. In addition, for
purposes of the FFIEC 019, net claims resulting
from repurchase agreements under multijurisdictional and/or multi-branch master repurchase agreements are considered guaranteed by
counterparty’s head office, or the designated
office (“the counterparty”) subject to the agreement and should be reported in the country of
the counterparty on both an immediatecounterparty and ultimate-risk basis.

Remaining Maturity
For loans on which the entire principal is to be repaid
on a single date, the term “remaining maturity” refers
to the time remaining from the “as of ” report date to
the expiration date of the loan. For loans on which
portions of the principal are scheduled to be repaid on
several different dates that may fall into more than one
maturity category, the loan should be allocated to the
appropriate maturity categories on the basis of the
time remaining to each payment date from the “as of ”
report date. Revolving credits should be classified by
the date on which repayment of principal may be
required. If a loan or obligation has been refinanced or
rescheduled and has a new maturity date, the new
maturity date should be used to determine the proper
maturity category.
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Specific Instructions for Allocating Claims to
the Rows
This report form contains rows for the home country
and individual foreign countries. Data should be allocated to the rows as described below.
Home Country
Home country is determined by the principal residence
address of an individual, partnership, or corporation,
and any government or political subdivision, agency,
or instrumentality thereof.
Foreign Countries
A foreign country is any country other than the United
States as defined on page GEN-2. For claims reported
on an immediate-counterparty basis, report claims for
the corresponding country of legal residence (i.e., the
country of incorporation or charter or, for a bank
branch, the country where the branch is licensed) of
the immediate counterparty. For claims reported on an
ultimate-risk basis, report claims in the row corresponding to the country of legal residence (i.e., the
country of incorporation or, for a bank branch, the
country where the parent bank is chartered) of the ultimate obligor. (See the definition of Claims on page
GEN-3 for more information.)
Exposures on non-bank financial institutions (NBFIs)
should be reported for the country where the institution is incorporated, or otherwise chartered. Institutions such as hedge funds and Special Purpose Vehicles
(SPV) should be reported according to the country of
legal residence (country of incorporation) of the fund/
vehicle, not according to the location of the fund managers or beneficial owners of the fund/vehicle.

Instructions For Specific Columns
of the Report
Columns 1 through 12 are to be filled out for the home
country and for foreign countries to which the adjusted
exposure of the reporting institution, as calculated in
Column 4 is at least $20 million. (The United States is
not to be reported as one of the foreign countries.) However, if the total adjusted exposure of the respondent is
less than $20 million, the values reflected in the correFFIEC 019

General Instructions

sponding columns to that country (other than the
home country) should be left blank.

Column 1: Total Direct Claims on Foreign
Residents
Report in this column, by country (for the home country and the foreign countries indicated above), the total
of the reporting institution’s direct claims on “foreign
residents” as defined above. Do not report direct
claims on any other countries.
Note: For each country to which its exposure is at least
$20 million, this total should be equal to or greater
than the sum of the following items for that country on
the TIC reports: Column 6, form BC, and Columns 3
and 4, form BQ-2. (Because the TIC reports exclude
foreign long-term securities and accrued income, the
amounts reported on this form will exceed those
reported on the TIC forms to the extent that the totals
reported here include such items.)

Column 2: Claims in Column 1 on Borrowers
with a Head Office or Guarantor in Another
Country
For each country on which direct claims are reported
in Column 1, report in Column 2 the amount that:
(1) is guaranteed by residents of another country
(including residents of the United States)
or
(2) represents claims on agencies or branches of a
bank with a head office in a country (including
the United States) other than the one named on
the line.
The amount shown in this column should be reported
against the country for which the direct claim is
reported in Column 1, not against the country of the
guarantor or head office, which might not even be
among the countries listed in the report.

Column 3: Guarantees and Other Indirect
Claims for which the Country Listed in the
Country Column Is the Country of the Head
Office or Guarantor
For each country on which direct claims are reported
in Column 1, report in Column 3 the amount of:
FFIEC 019

(1) any indirect claims on residents of this country,
which arise from their guarantees of claims on
residents of other countries; and
(2) any claims on branches or agencies located outside the country named on the line but whose
head office is located in this country.
In Column 3, the amounts of such indirect claims are
to be reported against the country of the guarantor or
head office (if that country is one of those listed by the
respondent) not against the country of the direct
claims.
The country against which the exposure constitutes a
direct claim may or may not be one of the countries
listed in the report by a given respondent; therefore, for
any given respondent, the amount reported in Column
3 for the country of the guarantor or head office may
or may not be reflected in Columns 1 and 2. This
would be the case, for example, with direct claims on
U.S. borrowers that are guaranteed by residents of a
country listed in the report.
The amount guaranteed should be included in Column
3 but would not be reported in Columns 1 and 2. (See
examples B and L, below.) However, claims on U.S.
branches and agencies of the respondent’s own bank
(i.e., on those offices that are domiciled in the 50 states
of the United States and the District of Columbia) are
not to be reported in Column 3, in order to avoid
counting claims on these affiliated U.S. offices as indirect home-country exposure.

Column 4: Total Adjusted Claims on Foreign
Residents
For each country on which direct claims are reported
in Column 1, the amount reported in Column 4 is
determined by subtracting the amount in Column 2
from Column 1 and then adding the amount shown in
Column 3.

Column 5: Adjusted Claims on Related
Non-U.S. Offices
The amount reported in Column 5, which pertains to
the home country only, is that portion of Column 4
that represents adjusted claims on related offices in the
home country. As suggested above, these adjusted
claims would include claims on the reporting branch’s
GEN-9

March 2022

General Instructions

or agency’s head office, on its non-U.S. branches and
agencies, and on other “related non-U.S. offices.”
However, they exclude claims of the reporter on any
related U.S. offices.

Examples of Entries of Columns 1–5

Column 6: Total Adjusted Claims on Unrelated
Foreign Residents
For the home country, enter in Column 6 the amount
reported in Column 4 minus the amount reported in
Column 5. For each other country listed, enter in this
column the same amount reported in Column 4.

The specific treatment of a given claim, including
whether or not it is reported, generally depends upon
two factors. They are:

Distribution of Adjusted Claims on
Unrelated Foreign Residents, as Reported
in Column 6

(1) whether the obligor (either direct or indirect) is a
resident of the reporter’s home country or of one
of the foreign countries on which direct claims
are reported in Column 1 on the report, and

This section distributes the adjusted claims reported in
Column 6 by the type of obligor (in Columns 7–9) and
by the remaining maturity (in Columns 10 and 11).

(2) whether the direct claim is guaranteed by a resident of another country.
Other more specialized considerations affect the
reporting of claims on related institutions, as indicated
in the instructions.
The following examples illustrate how claims with certain characteristics would be reflected in the report.
The examples all assume that the respondent is a New
York branch of a foreign bank and that the foreign
countries listed are those on which its total adjusted
claims are at least $20 million for each country. The
countries used in the examples are for illustration purposes only. The countries shown in the report by any
given respondent will be different, depending on the
respondent’s own pattern of adjusted claims. In each
example, the only entries shown are those that pertain
to the specific claim described. Note that no entries
should be made (and no examples are shown) when
neither the country of the direct obligor nor the country of the guarantor is one of the (potentially) six
countries listed.
Direct claims on residents of a listed country that are
not guaranteed by parties in any other countries are
reflected only in Columns 1 and 4. See Example A for
such claims on a country other than the home country
and Example H for such claims on the home country.
All of the other examples involve “external” guarantees and show the entries required in Columns 2 and 3
(and when appropriate in Column 5) to reflect these
guarantees and to make the necessary adjustments.
GEN-10

March 2022

Columns 7–9: By Type of Borrower or
Guarantor
For each country on which direct claims are reported
in Column 1, distribute the amount entered in Column 6 by type of borrower or guarantor: Column 7,
Foreign Public Borrowers; Column 8, Unrelated Foreign Banks; and Column 9, Other Unrelated Foreign
Residents. (See definitions above.) The sum of Columns 7, 8, and 9 must equal Column 6.

Columns 10–11: By Remaining Maturity
For each country on which direct claims are reported
in Column 1, distribute the amounts shown in Column 6 by length of remaining maturity: Column 10,
one year or less; and Column 11, more than one year.
The sum of Columns 10 and 11 must equal Column 6.

Column 12: Commercial and Standby Letters of
Credit and Legally Binding Loan Commitments
Report in this column on the appropriate country line
the respondent’s outstanding and unused letters of
credit (both commercial and standby) that have been
issued for account parties that are residents of the
countries listed in the respondent’s report. Include letters of credit issued to related non-U.S. parties. (For
further discussion of letters of credit refer to the
instructions for Schedule L, items 3 and 4, of the form
FFIEC 002, “Report of Assets and Liabilities of U.S.
Branches and Agencies of Foreign Banks.”) Report
letters of credit opposite the country of the direct obligor and do not adjust for any guarantees.
FFIEC 019

General Instructions

The respondent should also report in this column the
unused portions of commitments that obligate the
reporting branch or agency to extend credit in the form
of loans or participation in loans, lease financing

FFIEC 019

receivables, or similar transactions. Report only those
commitments for which the branch or agency has
charged a commitment fee or other consideration, or
otherwise has a legally binding commitment.

GEN-11

December 2003

General Instructions

Examples
A. U.S. branch of a Japanese bank has a $100 million claim on a Swiss branch of a Swiss bank, with no guarantees
involved. Entries would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

Indirect Claims
Col. 2

Col. 3

100

Adjusted
Total

Claims
Related

Col. 4

Col. 5

100

B. U.S. branch of a Japanese bank has a $100 million claim on a U.S. branch of a Swiss bank. Entries would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

1

Adjusted
Total

Claims
Related

Col. 3

Col. 4

Col. 5

100

100

Indirect Claims
Col. 2

The countries shown in these examples are for purposes of illustration only. The countries listed and reported by each respondent will
depend upon that respondent’s own home country and pattern of total adjusted claims and will therefore vary from respondent to
respondent.

GEN-12

March 2022

FFIEC 019

General Instructions

C. U.S. branch of a Japanese bank has a $100 million claim on a U.K. branch of a Swiss bank. Entries would be:
Country1

Country
Code

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

Direct
Claims

Adjusted
Total

Claims
Related

Col. 3

Col. 4

Col. 5

100

100

Indirect Claims

Col. 1

Col. 2

100

100

D. U.S. branch of a Japanese bank has a $100 million claim on a U.K. branch of a Mexican bank. Entries would be:
Country1

Country
Code

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

1

Direct
Claims

Indirect Claims

Col. 1

Col. 2

100

100

Col. 3

Adjusted
Total

Claims
Related

Col. 4

Col. 5

0

The countries shown in these examples are for purposes of illustration only. The countries listed and reported by each respondent will
depend upon that respondent’s own home country and pattern of total adjusted claims and will therefore vary from respondent to
respondent.

FFIEC 019

GEN-13

March 2022

General Instructions

E. U.S. branch of a Japanese bank has a $100 million claim on a U.K. branch of its own Japanese parent bank.
Entries would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

100

Adjusted
Total

Claims
Related

Col. 3

Col. 4

Col. 5

100

100

100

Indirect Claims
Col. 2

100

0

F. U.S. branch of a Japanese bank has a $100 million claim on a U.K. branch of an unrelated Japanese bank. Entries
would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

1

100

Adjusted
Total

Claims
Related

Col. 3

Col. 4

Col. 5

100

100

Indirect Claims
Col. 2

100

0

The countries shown in these examples are for purposes of illustration only. The countries listed and reported by each respondent will
depend upon that respondent’s own home country and pattern of total adjusted claims and will therefore vary from respondent to
respondent.

GEN-14

March 2022

FFIEC 019

General Instructions

G. U.S. branch of a Japanese bank has a $100 million claim on its own Japanese parent bank. Entries would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

Indirect Claims
Col. 2

Col. 3

100

Adjusted
Total

Claims
Related

Col. 4

Col. 5

100

100

H. U.S. branch of a Japanese bank has a $100 million claim on an unrelated Japanese business with no guarantees
involved. Entries would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

1

100

Indirect Claims
Col. 2

Col. 3

Adjusted
Total

Claims
Related

Col. 4

Col. 5

100

The countries shown in these examples are for purposes of illustration only. The countries listed and reported by each respondent will
depend upon that respondent’s own home country and pattern of total adjusted claims and will therefore vary from respondent to
respondent.

FFIEC 019

GEN-15

March 2022

General Instructions

I. U.S. branch of a Japanese bank has a $100 million claim on a U.K. business guaranteed by a U.S. bank. Entries
would be:
Country1

Country
Code

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

Direct
Claims

Indirect Claims

Col. 1

Col. 2

100

100

Col. 3

Adjusted
Total

Claims
Related

Col. 4

Col. 5

0

J. U.S. branch of a Japanese bank has a $100 million claim on a Swiss business guaranteed by a U.K. bank. Entries
would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

1

100

Adjusted
Total

Claims
Related

Col. 3

Col. 4

Col. 5

100

100

Indirect Claims
Col. 2

100

0

The countries shown in these examples are for purposes of illustration only. The countries listed and reported by each respondent will
depend upon that respondent’s own home country and pattern of total adjusted claims and will therefore vary from respondent to
respondent.

GEN-16

March 2022

FFIEC 019

General Instructions

K. U.S. branch of a Japanese bank has a $100 million claim on a Canadian business guaranteed by the latter’s U.S.
parent corporation. Entries would be:
Country1

Country
Code

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

Direct
Claims

Indirect Claims

Col. 1

Col. 2

100

100

Col. 3

Adjusted
Total

Claims
Related

Col. 4

Col. 5

0

L. U.S. branch of a Japanese bank has a $100 million claim on a U.S. business guaranteed by the latter’s Swiss parent corporation. Entries would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom
France
Brazil
Switzerland

29998
13005
10804
30309
12688

1

Adjusted
Total

Claims
Related

Col. 3

Col. 4

Col. 5

100

100

Indirect Claims
Col. 2

The countries shown in these examples are for purposes of illustration only. The countries listed and reported by each respondent will
depend upon that respondent’s own home country and pattern of total adjusted claims and will therefore vary from respondent to
respondent.

FFIEC 019

GEN-17

March 2022

General Instructions

M. U.S. branch of a Japanese bank has a $15 million claim on a U.S. business guaranteed by the latter’s German
parent corporation. Entries would be:
Country1

Country
Code

Direct
Claims
Col. 1

HOME COUNTRY:
Japan

42609

FOREIGN COUNTRIES:
Canada
United Kingdom

29998
13005

France
Brazil
Switzerland

10804
30309
12688

1

Indirect Claims
Col. 2

Col. 3

Adjusted
Total

Claims
Related

Col. 4

Col. 5

(No Entries for any country shown because, in this example, the country of the
guarantor, Germany, is not one of the foreign countries to which the reporter has
an exposure of at least $20 million.)

The countries shown in these examples are for purposes of illustration only. The countries listed and reported by each respondent will
depend upon that respondent’s own home country and pattern of total adjusted claims and will therefore vary from respondent to
respondent.

GEN-18

March 2022

FFIEC 019