FR2023_20240826_omb

Supporting Statement for the
Senior Financial Officer Surveys
(FR 2023; OMB No. 7100-0223)
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 Senior Financial Officer Surveys (FR 2023; OMB No. 7100-0223).1 The Board uses
the surveys in this collection to gather qualitative and limited quantitative information about
liability management, the provision of financial services, and the functioning of key financial
markets from a selection of up to 80 large commercial banks and other depository institutions
(or, if appropriate, from other major financial market participants). This voluntary survey is
completed by a senior officer at each respondent institution. In recent years, the Board has
conducted two surveys per year, but it may conduct up to four surveys per year when significant
informational needs arise that cannot be met from existing data sources.
The Board revised the FR 2023 by increasing the respondent panel size from 80 to 100
and changing the method of collection from email to an online survey tool.
The current estimated total annual burden for the FR 2023 is 960 hours, based on four
surveys per year, and would increase to 1,200 hours. The revisions would result in an increase of
240 hours. These surveys do not have a fixed set of questions; each survey would consist of a
limited number of questions directed at topics of timely interest.
Background and Justification
The Board uses Senior Financial Officer Surveys to obtain information about bank
reserve management practices, deposit pricing and behavior, liability management, provision of
financial services, and use of Federal Reserve liquidity facilities. The FR 2023 also complements
other deposit reports that, by themselves, provide limited insight into the causes of the changing
behavior of deposit holders and depository institutions. Moreover, the FR 2023 has given the
Board the opportunity to follow periodic developments in financial markets related to
extraordinary events that are beyond the scope of other reports.
The Board conducted several Senior Financial Officer Surveys in the 1980’s and early
1990’s, prior to the passage of the Paperwork Reduction Act, that covered a variety of topics,
Certain criteria apply to information collections conducted via the Board’s ad hoc clearance process. Such
information collections shall (1) be vetted by the Board’s clearance officer, as well as the Division director
responsible for the information collection, (2) display the OMB control number, (3) inform respondents that the
information collection has been approved, (4) be used only in such cases where response is voluntary, (5) not be
used to substantially inform regulatory actions or policy decisions, (6) be conducted only and exactly as described in
the OMB submission, (7) involve only noncontroversial subject matter that will not raise concerns for other Federal
agencies, (8) include a detailed justification of the effective and efficient statistical survey methodology (if
applicable), and (9) collect personally identifiable information (PII) only to the extent necessary (if collecting
sensitive PII, the form must display current Privacy Act notice). In addition, for each information collection
instrument, respondent burden will be tracked and submitted to OMB.
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including deposit pricing and behavior, bank liability management, the provision of financial
services, and bank reserve management practices. From 1994 to 2018, collection of the FR 2023
was sporadic, and based on exigencies and information needs generally focusing on bank reserve
management and funding practices.
Starting in 2018, the Board and the Federal Reserve Bank of New York (FRBNY)
collected Senior Financial Officer Surveys focusing on depository institution reserve
management strategies and practices. Used in this way, the survey allows the Federal Reserve to
systematically gather views and data from a number of depository institutions that provide useful
information in monitoring and interpreting developments in financial markets and the banking
system as the level of reserve balances in the banking system changes. For example, in January
2019, the Federal Open Market Committee (FOMC) reaffirmed its intention to implement
monetary policy in a regime with an ample supply of reserves; in such a regime, information on
reserve market conditions is particularly critical for effective monetary policy implementation.
Additionally, in recent years, the FR 2023 surveys have collected information on other topics,
such as bank balance sheet management, activity in wholesale funding markets, deposit pricing
strategies, and reactions to the creation of Federal Reserve liquidity facilities. Information
collected through these surveys contributes to improved analyses regarding the implementation
of monetary policy and is not available from other sources.
Description of Information Collection
The FR 2023 is a voluntary survey conducted by the Board and FRBNY. Both the
frequency and the content of the Senior Financial Officer Surveys have been, and will continue
to be, determined by exigencies. In recent years, the Board has conducted two surveys per year,
but it may conduct up to four surveys per year when significant informational needs arise that
cannot be met from existing data sources. The surveys do not have a fixed set of questions; each
survey consists of a limited number of both qualitative and quantitative questions directed at
topics of timely interest. To the extent possible, the Federal Reserve notifies respondents by
email in advance as to the topic(s) to be covered in an impending survey. In extraordinary
circumstances, when such notice is not possible, the decision to waive this advance notice
provision would be made only by Federal Reserve officials. Surveys are completed by senior
officers at respondent institutions. Survey questions are sent to, and replies received from,
respondents via email. Follow-up telephone responses may be conducted, as necessary.
The Board understands that respondents use information technology to comply with these
provisions, including email and spreadsheet software. The respondents email completed survey
spreadsheets to FRBNY staff, who address data quality issues and compile the data into a dataset
that is shared with Board Monetary Affairs staff.
Respondent Panel
The FR 2023 panel comprises up to 80 large institutions, which include domestic
depository institutions and foreign banking organizations. The panel of firms for each ad hoc
survey in this collection is selected based on asset size, significance of presence in markets and

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activities that are the subject of the survey (e.g., overnight unsecured wholesale funding markets,
reserve balance holdings), and responsiveness to previous collections.
This panel of large institutions is appropriate for most survey topics. In some situations,
however, panels based on alternative criteria may be more appropriate or may provide useful
additional information. Consequently, the Board may survey other types of respondents (such as
other depository institutions, bank holding companies, or other financial entities) in addition to
the primary panel. For example, it may be useful to survey credit unions to gain better insight
into the demand for reserves at these institutions, or institutional loan investors to gain a better
understanding of the syndicated loan market. This option enhances the potential scope and utility
of the survey.
Frequency and Time Schedule
The FR 2023 survey may be conducted up to four times per year. In recent years, the
Board has conducted two surveys per year, but believes that the authority to conduct up to four
surveys a year is essential for the Federal Reserve System to maintain the ability to keep abreast
of important market developments.
Revisions to the FR 2023
The Board revised the FR 2023 by increasing the panel size from 80 to 100 and changing
the method of collection from email to an online survey tool. 2 The larger panel size is intended to
obtain more data from relatively smaller depository institutions (those with between $1 billion
and $50 billion in total assets). Compared to the current data collection method (an emailed
Excel spreadsheet), use of an online tool would enhance the survey with interactive features
(such as posing follow-up questions based on respondent inputs), improved automated
safeguards against data quality risks, workflow efficiency features such as response tracking and
version control, and usability on mobile devices. These revisions are effective on September 1,
2024.
Public Availability of Data
Survey responses are tabulated and summarized at the Board and FRBNY. A report
containing summary data is published on the Board’s public website. 3
Legal Status
The FR 2023 is authorized by sections 2A, 12A, and 11 of the Federal Reserve Act
(FRA). Section 2A of the FRA requires that the Board and FOMC maintain long-run growth of
the monetary and credit aggregates commensurate with the economy’s long-run potential to
increase production, so as to promote effectively the goals of maximum employment, stable
2

An example of an online survey tool is a software platform by Qualtrics, a commercial experience management
company that is a Federal Reserve vendor. In the event of an outage or breakdown of the chosen online tool, the
current reporting method, an emailed spreadsheet, would be used as a backup collection method.
3 Survey reports are available at https://www.federalreserve.gov/data/sfos/sfos.htm .

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prices, and moderate long-term interest rates (12 U.S.C. § 225a). Section 12A of the FRA further
requires the FOMC to implement regulations relating to the open market operations conducted
by Federal Reserve Banks with a view to accommodating commerce and business and with
regard to their bearing upon the general credit situation of the country (12 U.S.C. § 263).
Section 11 of the FRA authorizes the Board to require reports from each member bank as it may
deem necessary and authorizes the Board to prescribe reports of liabilities and assets from
insured depository institutions to enable the Board to discharge its responsibility to monitor and
control monetary and credit aggregates (12 U.S.C. § 248(a)). The Board and FOMC use the
information obtained through the FR 2023 to help discharge these responsibilities. Survey
submissions under the FR 2023 are voluntary.
The questions asked on each survey will vary. The Board’s ability to keep confidential
responses to the FR 2023 must therefore be determined on a case-by-case basis. Much of the
information collected is likely to constitute nonpublic commercial or financial information,
which is both customarily and actually treated as private by the respondent, and may be kept
confidential by the Board pursuant to exemption 4 of the Freedom of Information Act (FOIA)
(5 U.S.C. § 552(b)(4)). Some survey responses may also contain information contained in or
related to an examination of a financial institution, which may be kept confidential under
exemption 8 of FOIA (5 U.S.C. § 552(b)(8)). Responses to the FR 2023 are tabulated and
summarized at the Board and the FRBNY. This aggregate information is not considered
confidential, and a report containing summary data is published on the Board’s public website.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On March 7, 2024, the Board published an initial notice in the Federal Register (89 FR
16568) requesting public comment for 60 days on the extension, with revision, of the FR 2023.
The comment period for this notice expired on May 6, 2024. The Board did not receive any
comments. The Board adopted the extension, with revision, of the FR 2023 as originally
proposed. On July 29, 2024, the Board published a final notice in the Federal Register (89 FR
60893).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2023 is 960
hours, based on four surveys per year, and would increase to 1,200 hours with the revisions. The
burden estimate was produced using the standard Board burden calculation methodology. These
reporting requirements represent less than 1 percent of the Board’s total paperwork burden.

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FR 2023
Current
Proposed

Estimated
number of
respondents4

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

80

4

3

960

100

4

3

1,200
240

Change

The estimated total annual cost to the public for the FR 2023 is $67,056, and would
increase to $83,820 with the revisions.5
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 $381,900 per year.

4

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.
5 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/.

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