FFIEC 019 18 Question Format OMB Supporting Statement

Supporting Statement for the
Country Exposure Report for U.S. Branches and Agencies of Foreign Banks
(FFIEC 019; OMB No. 7100-0213)
1.

Explain the circumstances that make the collection of information necessary.

The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, without revision, the
Federal Financial Institutions Examination Council (FFIEC) Country Exposure Report for U.S.
Branches and Agencies of Foreign Banks (FFIEC 019; OMB No. 7100-0213). The Board
submits this request on behalf of the Board, Federal Deposit Insurance Corporation (FDIC), and
Office of the Comptroller of the Currency (OCC) (the agencies). No separate submission will be
made by the FDIC or OCC. The report is required and must be submitted quarterly by all
individual U.S. branches and agencies of foreign banks that have total direct claims on foreign
residents in excess of $30 million. Each reporting branch or agency provides information for
supervisory purposes on its direct and indirect claims, total adjusted claims on foreign residents,
and information on commitments.
2.

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

The FFIEC 019 is an important and unique tool for surveillance and oversight that
collects the minimal amount of information needed for supervisory purposes under the
International Banking Act of 1978 (IBA). The FFIEC implemented the FFIEC 019 report in June
1986 in response to supervisory concerns relating to funding practices of certain U.S. branches
and agencies of foreign banks that were raising funds in the United States and other nations’
interbank markets, and then lending the bulk of the funds to home-country residents. Major
funding problems emerged for these U.S. offices when the governments of the parent banks’
home countries encountered severe difficulties in servicing their external debt. In 1985 the
Board, FDIC, and OCC proposed collection of country exposure information from U.S. branches
and agencies in order to supervise their operations more effectively. 1
Quarterly information on significant country risk exposures is very important in
measuring and supervising liquidity positions of the branches and agencies of foreign banks,
which fund themselves primarily in the U.S. domestic money markets by taking large uninsured
deposits from banks, corporations, and individuals. Those branches that are insured by the FDIC
also raise funds from retail customers. The financial regulatory agencies need to be able to assess
the institutions’ ability to repay these deposits.
One important indicator of potential underlying problems is an excessive concentration
by the U.S. branch or agency in assets due from parties in a single country or a small number of
countries. The regulatory agencies need access to information regarding the level of country
In addition, the agencies’ collection of this information is consistent with the Basel Concordat. See Basel
Committee on Banking Supervision, Core Principles for effective banking supervision,
https://www.bis.org/bcbs/publ/d573.htm (April 2024).
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concentrations within a specific branch or agency, to ensure that these institutions, like domestic
banking institutions, are practicing reasonable country risk diversification. The FFIEC 019
assists the agencies in monitoring the extent to which the U.S. branches and agencies are
pursuing prudent diversification policies and limiting potential liquidity pressures.
In addition, FDIC-insured branches of foreign banks are subject to an asset maintenance
requirement (12 CFR 347.210). Under this requirement, in general, an insured branch must
maintain on a daily basis eligible assets in an amount not less than 106 percent of the preceding
quarter’s average book value of the branch’s liabilities, exclusive of liabilities due to related
offices of the foreign bank. The FDIC may require that a higher ratio of eligible assets be
maintained if the financial condition of the insured branch warrants such action. Among the
factors that the FDIC considers in requiring a higher ratio is the concentration of transfer risk to
any one country, including the country in which the foreign branch’s head office is located. The
data from the FFIEC 019 report assist the FDIC in evaluating the existence of such
concentrations and determining whether to require that an insured branch maintain a higher ratio
of eligible assets than the 106 percent minimum.
In order to limit reporting burden, the FFIEC 019 has been designed to collect the
minimum amount of information needed to assess country exposure. The report currently
requires each of the U.S. branches and agencies with claims on foreign parties exceeding $30
million to report (1) its exposure to borrowers in its home country and (2) each country exposure
exceeding $20 million. These requirements are considerably less burdensome than the
information required of domestic banking institutions on the Country Exposure Report
(FFIEC 009; OMB No. 7100-0035), which requires information on all country exposures and
requires considerably greater maturity detail. Because smaller institutions are often more likely
to encounter funding problems than larger ones, the agencies do not believe that it is appropriate
to increase the minimum exposure level that must be reported.
The FFIEC 019 report must be filed by each U.S. branch or agency of a foreign bank that
has total direct claims (including those of its International Banking Facility (IBF))2 on foreign
residents in excess of $30 million. Currently, the branch or agency reports its gross claims on
(1) to residents of its home country (including related non-U.S. offices of the reporting
institution) and (2) residents of foreign countries for which the branch or agency’s adjusted
exposure for the country at least $20 million. The home country exposure must be reported
regardless of the size of the total claims for that nation.
Each reporting branch or agency must report, by country as appropriate information on
its (1) direct claims (claims in which the immediate obligor is a resident of the relevant country),
(2) indirect claims (claims arising because a resident of the relevant country is the ultimate
obligor, through guarantees or other means, of the relevant claim if the immediate obligor is
2

An IBF is a set of asset and liability accounts, which are segregated on the books and records of the establishing
entity and which reflect international transactions. An IBF is established in accordance with the terms of the Federal
Reserve’s Regulation D and after appropriate notification to the Federal Reserve. The establishing entity may be a
U.S. depository institution, a U.S. office of an Edge or agreement corporation, or a U.S. branch or agency of a
foreign bank pursuant to the Federal Reserve’s Regulations D and Q. An IBF is permitted to hold only certain assets
and liabilities. In general, IBF accounts are limited to non-U.S. residents of foreign countries, residents of Puerto
Rico and U.S. territories and possessions, other IBFs, and U.S. and non -U.S. offices of the establishing entity.

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unable to satisfy the claim), and (3) adjusted claims (total claims once direct claims are reduced
by claims that are guaranteed by parties in another country and increased by direct claims on
parties in other countries that parties in the country have guaranteed). In addition, respondents
must provide information on their outstanding and unused letters of credit that have been issued
for account parties that are residents of the relevant countries. Respondents must also report
claims on related non-U.S. offices that are included in total adjusted claims. Finally, respondents
must provide a breakdown of claims on unrelated foreign residents by the type of borrower or
guarantor (foreign public, unrelated foreign banks, or unrelated foreign residents), and by
maturity (in two categories: one year or less, and over one year).
3.

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

All affected institutions may submit their completed reports electronically using the
Federal Reserve’s Reporting Central application at https://www.frbservices.org/centralbank/reporting-central.
4.

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

The data collected through the FFIEC 019 are unique and cannot be replaced by data
already collected by the federal government.
5.

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

Of the respondents to the FFIEC 019, 24 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 entities.
6.

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

The FFIEC 019 is filed quarterly as of the last business day of March, June, September,
and December. Each reporting branch or agency must file its report with the appropriate Reserve
Bank within 45 days of the report date. Quarterly information on significant country risk
exposures is very important in measuring and supervising liquidity positions of the branches and
agencies of foreign banks, which fund themselves primarily in the U.S. domestic money markets
by taking large uninsured deposits from banks, corporations, and individuals. Those branches
that are insured by the FDIC also raise funds from retail customers. The financial regulatory
agencies need to be able to assess the institutions’ ability to repay these deposits.

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7.

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

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

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

On March 4, 2024, the Board published an initial notice in the Federal Register (89 FR
15575) requesting public comment for 60 days on the extension, without revision, of the
FFIEC 019. The comment period for this notice expired on May 3, 2024. The Board did not
receive any comments. On July 30, 2024, the Board published a final notice in the Federal
Register (89 FR 61119) requesting public comment for 30 days on the extension, without
revision, of the FFIEC 019. The comment period for this notice expires on August 29, 2024.
9.

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

10.

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

The information submitted in the FFIEC 019 may be exempt from public disclosure
pursuant to the Freedom of Information Act (FOIA), under exemptions 4 and/or 8 (12 U.S.C. §§
552(b)(4), (b)(8)). Exemption 4 applies to confidential commercial or financial information that
is both customarily and actually treated as private by its owner (12 U.S.C. § 552(b)(4)).3 If a
respondent believes that any of the public portions of its FFIEC 019 report would be exempt
from disclosure under exemption 4 of the FOIA, the respondent may request confidential
treatment for such information. Exemption 8 exempts from disclosure 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” (12 U.S.C. §
552(b)(8)). As documents related to the branches and agencies’ condition prepared for the use of
the agencies, which are responsible for the regulation and supervision of financial institutions,
FFIEC 019 reports may also be exempt from disclosure under exemption 8.
11.

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

3

See Food Marketing Institute v. Argus Leader Media, 588 U.S. 427, 440 (2019).

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12.

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

As shown in the table below, the estimated total annual burden for the FFIEC 019 is
5,560 hours. The estimated total number of respondents is based on the number of respondents
that submitted a FFIEC 019 report as of March 31, 2024. These reporting requirements represent
less than 1 percent of the Board’s total paperwork burden.

FFIEC 019
Current

Estimated
number of
respondents
139

Estimated
annual
frequency
4

Estimated
Estimated
average hours annual burden
per response
hours
10
5,560

The estimated total annual cost to the public for the FFIEC 019 is $388,366.
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 $23, 45% Financial Managers at $84, 15% Lawyers at $85,
and 10% Chief Executives at $124). Hourly rates for each occupational group are the (rounded)
mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment and
Wages, May 2023, published April 3, 2024, https://www.bls.gov/news.release/ocwage.t01.htm.
Occupations are defined using the BLS Standard Occupational Classification System,
https://www.bls.gov/soc/.
13.

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

14.

Provide estimates of annualized costs to the Federal government.

The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 019 is $13,100. The Federal Reserve System collects and processes the data for all three
of the federal bank regulatory agencies.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.

The reduction in estimated burden is the result of removing the one-time startup burden
from the previous revision, and an adjustment to the respondent count.
16.

Provide information regarding plans for publication of data.

The agencies do not routinely publicly release information collected through the
FFIEC 019.

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17.

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

18.

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

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