FR2956_20241125_omb

Supporting Statement for the
Treasury Securities and Agency Debt and Mortgage-Backed Securities
Reporting Requirements
(FR 2956; OMB No. 7100-0383)
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 Treasury Securities and Agency Debt and Mortgage-Backed Securities Reporting
Requirements (FR 2956; OMB No. 7100-0383). The FR 2956 collects detailed data on
depository institutions’ daily transactions trading of marketable U.S. Treasury securities and
transactions trading of the debt and mortgage-backed securities (MBS) issued by U.S. federal
government agencies including government-sponsored enterprises (agencies). The report has two
parts: Part 1 collects data on transactions in U.S. Treasury debt, and Part 2 collects transactions
in debt and MBS issued by agencies. Every national bank, state member bank, state non-member
bank, savings association, or U.S. branch and agency of a foreign bank filing a Notice by
Financial Institutions of Government Securities Broker or Government Securities Dealer
Activities (Form G-FIN; OMB No. 7100-0224) with average daily transaction volumes of over
$100 million, for U.S. Treasury debt, or over $50 million, for agency-issued debt and MBS,
during the prior fiscal year is subject to the these reporting requirements. Depository institutions
subject to the reporting requirements of the FR 2956 electronically report transactions through
the Board’s data collection vendor, the Financial Industry Regulatory Authority (FINRA),
utilizing its Trade Reporting and Compliance Engine (TRACE). The Board receives data on
transactions executed by FINRA’s broker-dealer members from FINRA, but the depository
institutions subject to the FR 2956 are not members of FINRA and are not subject to its rules.
The Board revised Part 1 of the FR 2956 report, which pertains to the reporting of
transactions in U.S. Treasury securities, by updating (1) the timeframe within which a depository
institution subject to the reporting requirements of Part 1 of the FR 2956 must report transactions
in U.S. Treasury securities, and (2) for transactions executed electronically, the minimum
increment of time that must be used for reporting the execution times. The Board also made
certain technical and clarifying revisions to Part 2 of the FR 2956 report. Specifically, the
revisions are intended to make the definitions clearer and to correct an error.
The current estimated total annual burden for the FR 2956 is 33,000 hours, and would
decrease to 22,000 hours. The revisions would result in a decrease of 11,000 hours. While there
is no formal reporting form, detailed instructions on how to report, along with a link to TRACE,
is available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
The U.S. Treasury securities market is the deepest and most liquid government securities
market in the world. Treasury securities play a critical and unique role in the global economy,
serving as the primary means of financing the U.S. federal government, a significant investment

instrument and hedging vehicle for global investors, a risk-free benchmark for other financial
instruments, and an important market for the Federal Reserve’s implementation of monetary
policy. Treasury securities are traded by broker-dealers that are registered with the U.S.
Securities and Exchange Commission (SEC) and are members of FINRA, as well as by
commercial bank dealers and principal trading firms (PTFs) that are not registered as brokerdealers with the SEC or members of FINRA. Several agencies under a range of authorities are
responsible for regulating various components of the Treasury securities market and its
participants.
The FR 2956 is a product of the continued efforts to develop efficient and effective ways
of collecting comprehensive Treasury market transaction information from depository
institutions subject to the Board’s reporting requirements. Collecting this information in an
event-driven manner from depository institutions that are not FINRA members but that are active
in the Treasury market allows a more complete analysis of the Treasury trading data and helps
identify and address potential anomalies in the market for Treasury securities.1 This helps the
Board and the Federal Open Market Committee (FOMC) understand frictions and disruptions in
the market that would affect the implementation of monetary policy.
In connection with these efforts, the Board also collects data on transactions in debt and
MBS securities issued by agencies. Along with Treasury securities and excess reserves, agency
debt and MBS are included as high-quality liquid assets for purposes of liquidity requirements
adopted by the Federal banking agencies,2 and these securities play a key role in housing finance,
one of the more interest-rate sensitive sectors of the U.S. economy and an important channel of
monetary policy transmission. Collecting this transaction data in an event-driven manner helps
the Board and FOMC better monitor and interpret fluctuations in supply and demand as well as
interest rate movements in these key credit aggregates.
The collection of transaction data is on an event-driven basis; the requirement to report is
driven by the execution of transactions by a depository institution. Currently, under Part 1 of the
FR 2956, transactions executed on a business day must be reported on the same day, with certain
exceptions. Under Part 2 of the FR 2956, transactions executed on a business day must be
reported no later than 15 minutes after execution, with certain exceptions. Accordingly,
depository institutions may have to report transactions under Part 2 more than once per day. This
information, as it pertains to transactions executed by depository institutions, is not available
from other sources.
Description of Information Collection
The FR 2956 currently collects detailed data on depository institutions’ daily transactions
of marketable U.S. Treasury securities and of the debt and MBS issued by U.S. agencies. The
report has two parts. Part 1 collects data on transactions in U.S. Treasury debt and Part 2 collects
transactions in debt and MBS issued by agencies. Depository institutions subject to the reporting
requirements of the FR 2956 report transactions through the Board’s data collection vendor,
1

FINRA began collecting similar transaction data from its members in 2017. See FINRA, Regulatory Notice 16-39
https://www.finra.org/rules-guidance/notices/16-39 (October 19, 2016).
2 See 12 CFR 249.20.

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FINRA, utilizing TRACE. Each reporting depository institution needs to comply with the
TRACE technical specifications and requirements necessary for reporting the required
transactions. The Board understands that respondents use information technology to make these
submissions, as respondents may submit transaction data to TRACE via Financial Information
eXchange (FIX) protocol or via a web-based application, as provided by FINRA.
The following depository institutions are subject to reporting requirements on the
FR 2956:
1) Every national bank, state member bank, state non-member bank, savings association, or
U.S. branch and agency of a foreign bank filing a Form G-FIN with an average of dollar
volumes of transactions in U.S. Treasury debt above $100 million per day over the period
from October 1 of the previous year through September 30 of the current year. Entities
meeting this threshold report Part 1 of the FR 2956.
2) Every national bank, state member bank, state non-member bank, savings association, or
U.S. branch and agency of a foreign bank filing a Form G-FIN with an average of dollar
volumes of transactions in debt and MBS issued by agencies above $50 million per day
over the period from October 1 of the previous year through September 30 of the current
year. Entities meeting this threshold report Part 2 of the FR 2956.
Prime brokers or depository institutions who file Form G-FIN and are FINRA members
acting as an executing broker and that therefore already are subject to TRACE reporting pursuant
to FINRA rules are exempt from this reporting requirement.
Reportable Transaction Information under Parts 1 and 2
Depository institutions subject to reporting under Parts 1 and 2 of the FR 2956 are
required to report all the transaction details, information, and fields as described in the applicable
TRACE technical documentation, FAQs, and guides (collectively, TRACE documentation)
located at https://www.finra.org/filing-reporting/trace. This information will include, but is not
limited to, the Committee on Uniform Securities Identification Procedures (CUSIP) number or
similar identifier, the transaction size (volume), price of the transaction, date of trade execution,
time of execution, and date of settlement.
Respondent Panel
The FR 2956 panel comprises depository institutions that meet the above reporting
thresholds. Prime brokers or depository institutions who file Form G-FIN and are FINRA
members acting as an executing broker and that therefore already are subject to TRACE
reporting pursuant to FINRA rules are excluded from this respondent panel.
Frequency and Time Schedule
Reporting transactions are event-generated based on the execution of transactions in
covered securities. Depository institutions are required to assess annually whether they meet the
reporting criteria. If a depository institution meets the event-generated threshold to report based
on the average of its daily transactions from October 1 of the previous year through September

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30, the depository institution will be required to begin to report the FR 2956 effective January 1
of the following year and continue reporting such transactions throughout that calendar year. If a
depository institution that reports on the FR 2956 falls below the threshold based on the average
of its daily transactions from October 1 of the previous year through September 30, the
depository institution will be required to continue to report through December 31 of that year but
will not be required to report for the next calendar year.
Daily collection improves the ability of the Board to monitor and control monetary and
credit aggregates, consistent with the responsibility of the Board and FOMC to maintain long run
growth of 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
prices, and moderate long-term interest rates.3
Revisions to the FR 2956
The Board revised Part 1 of the FR 2956 to update (1) the timeframe within which a
depository institution subject to the reporting requirements of Part 1 of the FR 2956 must report
transactions in U.S. Treasury debt, and (2) for transactions executed electronically, the minimum
increment of time that must be used for reporting the execution times.
The revisions generally require a depository institution subject to the reporting
requirements of Part 1 to report a transaction executed during TRACE system hours no later than
60 minutes after execution. Transactions executed on a business day before the TRACE system
opens would be required to be reported the same day no later than 60 minutes after the TRACE
system opens. Transactions executed on a business day less than 60 minutes before 6:30 p.m.
Eastern Time, or on a non-business day, would be required to be reported no later than 60
minutes after the next time the TRACE system opens. In addition, with respect to any transaction
executed electronically, the revisions would require the time of execution to be reported in an
increment that is (1) no longer than one second and no shorter than one microsecond , and
(2) within that range, the finest increment of time captured by the execution system.
The revisions further the goals that the Board articulated when the Board initially adopted
the FR 2956. As the Board noted in 2021, collecting information through the FR 2956 would
allow a more complete analysis of Treasury trading data and helps identify and address potential
anomalies in the market for Treasury securities. 4 Updating the timeframe within which
transactions must be reported, as well as the minimum time increment for reporting execution
time, will provide a more complete audit trail of transactions executed by depository institutions
that are subject to reporting under Part 1 of the FR 2956.

3

See 12 U.S.C. § 225a. Treasury Securities, agency and GSE debt, and MBS are an important channel of monetary
policy transmission. Collecting these transaction data helps the Board and FOMC better monitor and interpret
fluctuations in supply and demand as well as interest rate movements in these key credit aggregates.
4 See Board of Governors of the Federal Reserve System, Supporting Statement for the Treasury Securities and
Agency Debt and Mortgage-Backed Securities Reporting Requirements
https://www.reginfo.gov/public/do/PRAViewDocument?ref_nbr=202110 -7100-003.

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The revisions to Part 1 will also improve the ability of the Board and others in the official
sector to integrate data from the FR 2956 with TRACE data reported by broker-dealers to
FINRA, and thus have a more comprehensive view of the Treasury market. Effective
November 6, 2023, FINRA’s TRACE reporting rules, applicable to FINRA members, were
revised to include the same reporting timeframes and time increments as those contained in the
Board’s proposed revisions. The Board’s proposed revisions will bring the FR 2956 and
FINRA’s TRACE rules into alignment.
In addition, the Board made certain technical, non-substantive revisions to Part 2 of the
FR 2956. The changes are intended to make the definitions clearer, clarify the paragraph
numbering, and correct an error in current paragraph (D)(ii). With respect to both Parts 1 and 2,
the Board made clarifying revisions to certain defined terms and to add definitions to certain
terms that were previously undefined.
Public Availability of Data
The data received from this information collection will be included in the various current
or future TRACE data products offered by FINRA, such as data feeds, the end-of-day TRACE
transaction file, TRACE enhanced historical data, market aggregate statistics, and TRACE Fact
Book.
Legal Status
The FR 2956 is authorized by sections 2A and 11 of the Federal Reserve Act (FRA).
Section 2A of the FRA requires that the Board and the 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 prices, and
moderate long-term interest rates (12 U.S.C. § 225a).5 Section 11 of the FRA authorizes the
Board to require reports from depository institutions 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 obligation to respond to the FR 2956 is mandatory.
The information collected through the FR 2956 would generally be considered
confidential under exemption 4 of the Freedom of Information Act as confidential commercial or
financial information that is both customarily and actually treated as private by the respondent
(5 U.S.C. § 552(b)(4)).
Consultation Outside the Agency
As part of an interagency workgroup discussed above, the Board has consulted with the
Treasury, SEC, Commodity Futures Trading Commission, and FINRA on this collection.
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Treasury Securities, agency and GSE debt, and MBS are an important channel of monetary policy transmission.
The information to be collected by the FR 2956 is not available from other sources, and collecting these transaction
data would help the Board and FOMC better monitor and interpret fluctuations in supply and demand as well as
interest rate movements in these key credit aggregates.

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Public Comments
On July 1, 2024, the Board published an initial notice in the Federal Register (89 FR
54462) requesting public comment for 60 days on the extension, with revision, of the FR 2956.
The comment period for this notice expired on August 30, 2024. The Board did not receive any
comments. The Board adopted the extension, with revision, of the FR 2956 as originally
proposed. On November 15, 2024, the Board published a final notice in the Federal Register (89
FR 90286).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2956 is 33,000
hours, and would decrease to 22,000 hours with the revisions. The burden estimate was produced
using the standard Board burden calculation methodology and was also informed by the Board’s
increased experience and understanding of how respondents report transaction information to
TRACE.6 Specifically, the Board now understands that nearly all submissions are made
automatically by respondents, without manual input. These reporting requirements represent less
than 1 percent of the Board’s total paperwork burden.
Estimated
number of
respondents7

FR 2956

Estimated
Estimated
Estimated
annual
average hours annual burden
frequency per response
hours

Current
Part 1: Treasury securities
Part 2: Agency debt and MBS

22
22

250
250

3
3

Current Total

16,500
16,500
33,000

Proposed
Part 1: Treasury securities

22

250

2

11,000

Part 2: Agency debt and MBS
Proposed Total

22

250

2

11,000
22,000

Change

(11,000)

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The estimated burden hours include the time to operationalize, report, ongoing compliance, management, and other
time necessary for reporting under this collection.
7 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.

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The estimated total annual cost to the public for the FR 2956 is $2,305,050, and would
decrease to $1,536,700 with the revisions.8
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
report utilizing FINRA as its data collection vendor is approximately $650,000 in annual costs.

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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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