FRY9_20241226_omb

Supporting Statement for the
Financial Statements for Holding Companies
(FR Y-9; OMB No. 7100-0128)
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 Financial Statements for Holding Companies (FR Y-9; OMB No. 7100-0128). This
information collection comprises the following five reports:
• Consolidated Financial Statements for Holding Companies (FR Y-9C),
• Parent Company Only Financial Statements for Large Holding Companies (FR Y-9LP),
• Parent Company Only Financial Statements for Small Holding Companies (FR Y-9SP),
• Financial Statements for Employee Stock Ownership Plan Holding Companies
(FR Y-9ES), and
• Supplement to the Consolidated Financial Statements for Holding Companies
(FR Y-9CS).
The Board requires bank holding companies (BHCs), most savings and loan holding
companies (SLHCs), securities holding companies, and U.S. intermediate holding companies
(IHCs) (collectively, HCs) to provide standardized financial statements through one or more of
the FR Y-9 reports.1 The information collected on the FR Y-9 reports is necessary for the Board
to identify emerging financial risks and monitor the safety and soundness of HC operations.
The Board revised the FR Y-9C and FR Y-9LP reporting forms and instructions to be
consistent with changes to U.S. generally accepted accounting principles (GAAP) related to
troubled debt restructurings (TDRs). All changes to the FR Y-9C and FR Y-9LP take effect as of
the December 31, 2024, report date. There are no revisions at this time for the FR Y-9SP,
FR Y-9ES, or FR Y-9CS.
The current estimated total annual burden for the FR Y-9 is 114,489 hours, and would
remain the same. The FR Y-9 forms and instructions are available on the Board’s public website
at https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
The FR Y-9 reports are the Board’s primary source of financial data from HCs. Federal
Reserve System examiners rely on the FR Y-9 reports to supervise HCs between on-site
inspections. The Board uses the collected data to detect emerging financial problems, conduct
pre-inspection analysis, monitor and evaluate capital adequacy, evaluate mergers and
acquisitions, and analyze an HC’s overall financial condition to monitor the safety and soundness
1

The following SLHCs are exempt: (1) a unitary savings and loan holding company with primarily commercial
assets that meets the requirements of section 10(c)(9)(c) of the Home Owners’ Loan Act (HOLA), for which thrifts
make up less than 5 percent of its consolidated assets and (2) an SLHC that primarily holds insurance-related assets
and does not otherwise submit financial reports with the Securities and Exchange Commission pursuant to sections
13 or 15(d) of the Securities Exchange Act of 1934.

of its operations. The information collected by the FR Y-9 reports is not available from other
sources.
Description of Information Collection
The FR Y-9C consists of standardized financial statements for HCs similar to the Call
Reports filed by commercial banks. The FR Y-9C collects consolidated data and is filed
quarterly by top-tier HCs with total consolidated assets of $3 billion or more.2
The FR Y-9LP, which collects parent company only financial data, must be submitted
quarterly by each HC that files the FR Y-9C, as well as by each of its subsidiary HCs.3 The
report consists of standardized financial statements, including the following schedules: Income
Statement, Cash Flow Statement, Balance Sheet, Investments in Subsidiaries and Associated
Companies, Memoranda, and Notes to the Parent Company Only Financial Statements.
The FR Y-9SP is a parent company only financial statement filed semiannually by HCs
with total consolidated assets of less than $3 billion. In a banking organization with total
consolidated assets of less than $3 billion that has tiered HCs, each HC in the organization must
submit, or have the top-tier HC submit on its behalf, a separate FR Y-9SP. This report collects
basic balance sheet and income data for the parent company, as well as data on its intangible
assets and intercompany transactions.
The FR Y-9ES is filed annually by each employee stock ownership plan (ESOP) that is
also an HC. The report collects financial data on the ESOP’s benefit plan activities. The
FR Y-9ES consists of four schedules: Statement of Changes in Net Assets Available for
Benefits, Statement of Net Assets Available for Benefits, Memoranda, and Notes to the Financial
Statements.
The instructions to each of the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES state that
respondent HCs should retain workpapers and other records used in the preparation of the reports
for a period of three years following submission. In addition, HCs must maintain in their files a
manually signed and attested printout of the data submitted under each form for a period of three
years.
The FR Y-9CS is a voluntary, free-form supplemental report that the Board may utilize to
collect critical additional data deemed to be needed from HCs in an expedited manner. The
FR Y-9CS data collections are used to assess and monitor emerging issues related to HCs, and
the report is intended to supplement the other FR Y-9 reports. The data requested by the
FR Y-9CS would depend on the Board’s data needs in any given situation. For example, changes
made by the Financial Accounting Standards Board (FASB) may introduce into GAAP new data
items that are not currently collected by the other FR Y-9 reports. The Board could use the

Under certain circumstances described in the FR Y-9C’s General Instructions, HCs with assets under $3 billion
may be required to file the FR Y-9C.
3
A top-tier HC may submit a separate FR Y-9LP on behalf of each of its lower-tier HCs.
2

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FR Y-9CS report to collect these data until the items are implemented into the other FR Y-9
reports.4
Respondent Panel
The FR Y-9 panel comprises HCs. Specifically, the FR Y-9C panel comprises top-tier
HCs with total consolidated assets of $3 billion or more; the FR Y-9LP panel comprises each HC
that files the FR Y-9C, as well as by each of its subsidiary HCs; the FR Y-9SP panel comprises
HCs with total consolidated assets of less than $3 billion;5 the FR Y-9ES panel comprises each
ESOP that is also an HC; and the FR Y-9CS panel consists of any HC the Board selects.6 Most
small HCs file the streamlined parent only FR Y-9SP report semiannually.
Frequency and Time Schedule
The FR Y-9C and FR Y-9LP are filed quarterly as of the last calendar day of March,
June, September, and December. The filing deadline for the FR Y-9C is 40 calendar days after
the March 31, June 30, and September 30 as of dates and 45 calendar days after the December 31
as of date. The filing deadline for the FR Y-9LP is 45 calendar days after the quarter-end as of
date. The FR Y-9SP is filed semiannually as of the last calendar day of June and December, and
the filing deadline is 45 calendar days after the as of date. The annual FR Y-9ES is collected as
of December 31, and the filing deadline is July 31 of the following year, unless an extension to
file by October 15 is granted. Respondents will be notified of the filing deadline for the
FR Y-9CS if it is utilized by the Board.
If the above submission deadlines for the FR Y-9C, FR Y-9LP, FR Y-9SP, and
FR Y-9ES fall on a weekend or holiday, the reports must be received on the first business day
after the Saturday, Sunday, or holiday. The reports are due by the end of the reporting day on the
submission date (i.e., 5:00 P.M. at each of the Reserve Banks).

4

The FR Y-9CS was most recently used by the Board on June 30, 2008. In that collection, data were requested from
banking organizations implementing an Advanced Measurement Approach to calculate operational risk capital
under the Basel II Risk-Based Capital Framework. The report was used to conduct a voluntary Loss Data Collection
Exercise relating to operational risk.
5
The following HCs do not have to file holding company financial statements under the FR Y-9C, FR Y-9LP, and
FR Y-9SP: (1) HCs that has been granted an exemption under section 4(d) of the Bank Holding Company Act of
1956 and (2) a “qualified foreign banking organization” as defined by section 211.23(a) of Regulation K (12 CFR
211.23(a)) that controls a U.S. subsidiary bank.
6
The Reserve Bank with whom a reporting HC files its reports may require that a HC with total consolidated assets
of less than $3 billion submit the FR Y-9C and the FR Y-9LP reports to meet supervisory needs. In addition, any
HC that is not subject to the Federal Reserve’s Capital Adequacy Guidelines, but nonetheless elects to comply with
the guidelines, are required to file a complete FR Y-9C and FR Y-9LP report, and generally would not be permitted
to revert back to filing the FR Y-9SP report in any subsequent periods. See footnote 2 of the general instructions for
the FR Y-9C for more information.

3

Proposed Revisions to the FR Y-9C
Accounting Standards Update 2022-02, “Financial Instruments - Credit Losses
(Topic 326): Troubled Debt Restructurings and Vintage Disclosures (ASU 2022-02)”
On March 31, 2022, the FASB issued ASU 2022-02 which eliminates the TDR
recognition and measurement guidance for entities that have adopted ASU 2016-13, “Financial
Instruments - Credit Losses (Topic 326): Measurement of Credit Losses on Financial
Instruments.” Instead of identifying and accounting for TDRs separately from other loan
modifications, all loans modified from the beginning of the fiscal year in which the new standard
is adopted by an HC would be accounted for in accordance with Accounting Standards
Codification (ASC) 310-20-35, “Receivables - Nonrefundable Fees and Other Costs Subsequent Measurement”, as amended by ASU 2022-02. In addition, the new standard
enhances financial statement disclosure requirements for certain loan modifications to borrowers
experiencing financial difficulty. These disclosures include qualitative information regarding
how initial modifications and subsequent performance of such modifications impact the
allowance for credit losses.
Under ASU 2022-02, HCs would only include loans that were modified to borrowers
experiencing financial difficulty from the beginning of the fiscal year of adoption and in
subsequent periods in their disclosures for financial statement purposes. TDRs or modifications
made prior to the beginning of the fiscal year of adoption would not be included in these
enhanced disclosures in the period of adoption or in any subsequent periods.
Additionally, per ASU 2022-02, an HC would not be required to use a discounted cash
flow (DCF) approach to measure the allowance for credit loss on the modified loans. However, if
an HC chooses to use a DCF approach, it would be required to use the post-modification
expected interest rate to discount expected cash flows. Modified loans for which repayment is
expected to be provided substantially through the operation or sale of the collateral when the
borrower is experiencing financial difficulty would still be considered to be collateral-dependent.
For regulatory reporting purposes, the allowance for credit losses for a collateral-dependent loan
would continue to be measured using the fair value of collateral (less cost to sell, when
appropriate), regardless of whether foreclosure is probable.
ASU 2022-02 was effective for all HCs as of December 31, 2023, and eliminates the
recognition and measurement accounting guidance for TDRs. HCs should no longer report TDRs
on FR Y-9C Schedules HC-C, Loans and Leases, and HC-N, Past Due and Nonaccrual Loans,
Leases, and Other Assets, as well as on FR Y-9LP Schedule PC-B, Memoranda. To be consistent
with GAAP recognition and disclosure requirements, the Board proposes to revise the FR Y-9C
and FR Y-9LP form and instructions to align with the definition of loan modifications to
borrowers experiencing financial difficulty. Specifically, the Board is proposing to replace, as
appropriate, references to “troubled debt restructurings” with “loan modifications to borrowers
experiencing financial difficulty” in the FR Y-9C and FR Y-9LP form and instructions, and to
update the Glossary to reflect the change in accounting for modifications to borrowers
experiencing financial difficulty. The instructional changes would be consistent with the

4

references to “loan modifications to borrowers experiencing financial difficulty” on the report
forms.
These changes would assist the Board in gaining a better understanding of banks’ credit
exposures. Specifically, the loan modifications to borrowers experiencing financial difficulty
data reported in FR Y-9C Schedule HC-C, Memorandum item 1, and Schedule HC-N,
Memorandum item 1 would enable the Board to better understand the level of loan modification
activity at HCs and the categories of loans involved in this activity. The Board would benefit
from having reliable data about modification activity that is captured outside of the on-site
examination process. This data would provide the Board with information to assess the loan
quality and performance of modified loans.
The proposed revisions to specific data items resulting from the elimination of the TDR
recognition and measurement guidance would be revised in the FR Y-9C and FR Y-9LP forms
and instructions as of the December 31, 2024, report date.
Through March 31, 2024, the quarterly Supplemental Instructions for the FR Y-9C will
include guidance on reporting the data items related to loan modifications to borrowers
experiencing financial difficulty.
The Board proposes to revise the FR Y-9C as discussed in detail below.
A. Schedule HC-C, Loans and Leases, Memorandum item 1, and Schedule HC-N, Past
Due and Nonaccrual Loans, Leases, and Other Assets, Memorandum item - HCs
would report detail on loan modifications to borrowers experiencing financial difficulty
in Schedule HC-C, Memorandum item 1, and Schedule HC-N, Memorandum item 1. The
modifications reported in these Memoranda items would need to meet the definition of
“loan modifications to borrowers experiencing financial difficulty” as described in ASU
2022-02, which includes only those modifications which occurred in the previous 12
months.7 Loan modifications to borrowers experiencing financial difficulty include
financing receivables that had been modified in the form of principal forgiveness, an
interest rate reduction, an other-than-insignificant payment delay or a term extension (or
a combination thereof). The FR Y-9C report form and instructions would be updated to
include, in the item descriptions and instructions, references to “loan modifications to
borrowers experiencing financial difficulty” and remove references to the TDR
framework.
B. Schedule HC-M, Memoranda, Item 13 - HCs would report other real estate owned in
Schedule HC-M, Memoranda, item 13. However, instructional references to ASC
Subtopic 310-40, “Receivables-Troubled Debt Restructurings by Creditors” would be
updated to ASC Subtopic 310-20, “Receivables-Nonrefundable Fees and Other Costs.”
The FR Y-9C instructions would be updated to include the updated codification
references.
ASU 2022-02 requires disclosures on modifications to borrowers experiencing financial difficulty made “within
the previous 12 months preceding the payment default when the debtor was experiencing financial difficulty at the
time of the modification”. See ASC 310-10-50-44.
7

5

C. Glossary - To address the elimination of the TDR recognition and measurement guidance
in ASU 2022-02, the Board proposes to revise, as appropriate, the following Glossary
entries to provide additional information for those HCs that have adopted ASU 2022-02
and to remove redundant entries: (1) Allowance for Credit Losses, (2) Foreclosed Assets,
(3) Loan Fees, (4) Nonaccrual Status, (5) Renegotiated Troubled Debt, (6) Troubled Debt
Restructurings, (7) Loan Impairment, and (8) Purchased Credit-Debt Securities.
Additionally, a new entry for “Loan Modifications to Borrowers Experiencing Financial
Difficulty” would be included in the Glossary.
Proposed Revisions to the FR Y-9LP
The Board proposes to make changes to the FR Y-9LP instructions to mirror the
FR Y-9C related to ASU 2022-02.
HCs would report detail on “loan modifications to borrowers experiencing financial
difficulty” in Schedule PC-B, Memoranda, item 8. The modifications reported in this item would
need to meet the definition of “loan modifications to borrowers experiencing financial difficulty”
as described in ASU 2022-02. The FR Y-9LP form and instructions would be updated to include
references to “loan modifications to borrowers experiencing financial difficulty and remove
references to the TDR Framework. These changes would take effect beginning with the
December 31, 2024, as of date.
The Board invites comment on this proposal and acknowledges that this proposal to
report “loan modifications to borrowers experiencing financial difficulty” may diverge from the
proposed changes to the Call Report.8 Therefore, the Board is specifically interested in the
following:
1. What challenges, if any, would HCs face if the FR Y-9C and FR Y-9LP reporting
definitions were out of sync with the Call Report?
2. What challenges, if any, would HCs face if loan modifications to borrowers experiencing
financial difficulty were reported on the FR Y-9C and FR Y-9LP using a 12-month
lookback, and different lookback criteria were used on the Call Report? If the Call Report
used different lookback criteria, would it be preferable for the FR Y-9C and FR Y-9LP to
adopt the same definition?
Public Availability of Data
Data from the FR Y-9 reports that are not granted confidential treatment as described
below are publicly available on the FFIEC website: https://www.ffiec.gov/NPW.
Legal Status
The reporting and recordkeeping requirements associated with the FR Y-9 are authorized
for BHCs pursuant to section 5 of the Bank Holding Company Act of 1956 (BHC Act)
8

See 88 FR 66933 (September 28, 2023).

6

(12 U.S.C. § 1844); for SLHCs pursuant to section 10(b)(2) and (3) of the HOLA (12 U.S.C. §§
1467a(b)(2) and (3)); for IHCs pursuant to section 5 of the BHC Act, as well as pursuant to
sections 102(a)(1) and 165 of the Dodd-Frank Wall Street and Consumer Protection Act (DoddFrank Act) (12 U.S.C. §§ 5311(a)(1) and 5365);9 and for securities holding companies pursuant
to section 618 of the Dodd-Frank Act (12 U.S.C. § 1850a(c)(1)(A)). Except for the FR Y-9CS
report, which is collected on a voluntary basis, the obligation to submit the remaining reports in
the FR Y-9 series of reports and to comply with the recordkeeping requirements set forth in the
respective instructions to each of the other reports is mandatory.
Certain information collected on the FR Y-9C and FR Y-9SP reports is kept confidential
by the Board. The following items are kept confidential under exemption 4 of the Freedom of
Information Act (FOIA) because these data items reflect commercial and financial information
that is both customarily and actually treated as private by the respondent (12 U.S.C. § 552(b)(4)):
• FR Y-9C, Schedule HI, memoranda item 7(g), FDIC deposit insurance assessments,
• FR Y-9C, Schedule HC-P, item 7(a), Representation and warranty reserves for 1-4 family
residential mortgage loans sold to U.S. government agencies and government sponsored
agencies,
• FR Y-9C, Schedule HC-P, item 7(b), Representation and warranty reserves for 1-4 family
residential mortgage loans sold to other parties,
• FR Y-9C, Schedule HC-C, Part I, memorandum items 16.a and 16.b, for eligible loan
modifications under Section 4013 of the 2020 Coronavirus Aid, Relief, and Economic
Security Act, and
• FR Y-9C, Schedule HC and FR Y-9SP, Schedule SC, Memoranda item 2.b, the name and
email address of the external auditing firm’s engagement partner.10
In some circumstances, disclosing these data items may also reveal confidential
examination and supervisory information protected from disclosure under exemption 8 of the
FOIA (12 U.S.C. § 552(b)(8)). The Board has previously assured submitters that these data items
will be treated as confidential.
In addition, the Chief Executive Officer Contact Information section of both the FR Y-9C
and FR Y-9SP is kept confidential pursuant to FOIA exemption 6, which applies to personnel
and medical files the disclosure of which would constitute a clearly unwarranted invasion of
personal privacy (5 U.S.C. § 552(b)(6)), and exemption 8, which applies to information
Section 165(b)(2) of Title I of the Dodd-Frank Act (12 U.S.C. § 5365(b)(2)), refers to “foreign-based bank holding
company.” Section 102(a)(1) of the Dodd-Frank Act (12 U.S.C. § 5311(a)(1)), defines “bank holding company” for
purposes of Title I of the Dodd-Frank Act to include foreign banking organizations that are treated as bank holding
companies under section 8(a) of the International Banking Act of 1978 (12 U.S.C. § 3106(a)). The Board has
required, pursuant to section 165(b)(1)(B)(iv) of the Dodd-Frank Act (12 U.S.C. § 5365(b)(1)(B)(iv)), certain
foreign banking organizations subject to section 165 of the Dodd-Frank Act to form U.S. intermediate holding
companies. Accordingly, the parent foreign-based organization of a U.S. IHC is treated as a BHC for purposes of the
BHC Act and section 165 of the Dodd-Frank Act. Because section 5(c) of the BHC Act authorizes the Board to
require reports from subsidiaries of BHCs, section 5(c) provides additional authority to require U.S. IHCs to report
the information contained in the FR Y-9.
10
The Board has assured respondents that this information will be treated as confidential since the collection of this
data item was proposed in 2004, under the assumption that the identity of the engagement partner is treated as
private information by HCs.
9

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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
(5 U.S.C. § 552(b)(8)).
Aside from the data items described above, data collected by the FR Y-9 reports
generally are not accorded confidential treatment. However, as provided in the Board’s Rules
Regarding Availability of Information,11 a respondent may request confidential treatment for any
data items the respondent believes should be withheld pursuant to a FOIA exemption. The Board
will review any such request to determine if confidential treatment is appropriate and will inform
the respondent if the request for confidential treatment has been granted or denied.
To the extent that the instructions to the FR Y-9 reports direct the financial institution to
retain the workpapers and related materials used in preparation of each report, such material
would only be obtained by the Board as part of the examination or supervision of the financial
institution. Accordingly, such information is considered confidential pursuant to exemption 8 of
the FOIA (5 U.S.C. § 552(b)(8)). In addition, the workpapers and related materials may also be
protected by exemption 4 of the FOIA, to the extent such financial information is customarily
and actually treated as private by the respondent (5 U.S.C. § 552(b)(4)).
Consultation Outside the Agency
The Board consulted with the FDIC and OCC regarding the proposed revisions.
Public Comments
On June 7, 2024, the Board published an initial notice in the Federal Register (89 FR
48637) requesting public comment for 60 days on the extension, with revision, of the FR Y-9.
The comment period for this notice expired on August 6, 2024. The Board received one
comment letter. After considering the comments received on the proposal, the Board is
proceeding with the revisions as proposed. On November 15, 2024, the Board published a final
notice in the Federal Register (89 FR 90284).
ASU 2022-02, “Financial Instruments-Credit Losses (Topic): Troubled Debt
Restructurings and Vintage Disclosures”
The commenter is supportive of the proposed revisions to align the regulatory reporting
of loan modifications to borrowers experiencing financial difficulty (LMBEFD) on the FR Y-9C,
FR Y-9LP, and FR 2886b in accordance with ASU 2022-02. The commenter noted that, in any
event, the Board should not modify the proposed FR Y-9 revisions to bring the reporting in line
with the outstanding proposal on the Call Reports12. The commenter urged the Board to
implement ASU 2022-02 across all regulatory reporting forms, including the Consolidated
Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB
No. 7100-0036). The commenter stated that aligning all regulatory reports with ASU 2022-02

11
12

12 CFR Part 261.
See 89 FR 45046 (May 22, 2024).

8

would align with current practices by banking organizations and would reduce burden by
eliminating the necessity to develop and maintain dual processes.
In response, the Board is proceeding with these revisions as proposed to the FR Y-9C,
FR Y-9LP, and FR 2886b. Additionally, on June 7, 2024, the Board published in the Federal
Register separate initial notices that invited comment for 60 days on the extension, with revision,
of the Financial Statements of U.S. Nonbank Subsidiaries Held by Foreign Banking Organization
(FR Y-7N; OMB No. 7100-0125),13 Financial Statements of Foreign Subsidiaries of U.S.
Banking Organizations (FR 2314; OMB No. 7100-0073),14 and Financial Statements of U.S.
Nonbank Subsidiaries of U.S. Holding Companies (FR Y-11; OMB No. 7100-0244)14 to propose
aligning the reporting of LMBEFD with ASU 2022-02. Additionally, on June 21, 2024, the
Board published in the Federal Register an initial notice that invited comment for 60 days on the
extension, with revision, of the Capital Assessments and Stress Testing Reports
(FR Y-14A/Q/M; OMB No. 7100-0341),15 to also propose aligning the reporting of LMBEFD
with ASU 2022-02. Separate from this notice, the Board will take any comments under
consideration on the FR Y-7N, FR 2314, FR Y-11, and FR Y-14A/Q/M notices to align with
ASU 2022-02, after the comment period has expired.
With regard to aligning the reporting of LMBEFD in accordance with ASU 2022-02 on
the Call Report, the Office of the Comptroller of the Currency (OCC); Federal Deposit Insurance
Corporation (FDIC); and Board (collectively, the agencies) are continuing to evaluate the
comments on their September 2023 proposal,16 as well, as the comments received on this
proposal. Upon conclusion of their review, the agencies will adopt a standard through a
subsequent Paperwork Reduction Act (PRA) notice with a 30-day public comment period.
The commenter stated that the FR Y-9C’s definition of LMBEFDs should align with the
U.S. GAAP definition, specifically Accounting Standards Codification (ASC) Subtopic 310-10
and not scope in any additional modifications. The commenter noted that ASC Subtopic 310-10
requires disclosure of modifications of receivables to borrowers experiencing financial difficulty
where the modification results in the form of (1) principal forgiveness, (2) an interest rate
reduction, (3) an other-than-insignificant payment delay, or (4) a term extension (or a
combination thereof) to be disclosed for financial reporting purposes. The commenter mentioned
that it would be helpful if the Board would explicitly confirm the definitional alignment with U.S
GAAP and therefore limit the population of LMBEFD for regulatory reporting purposes to those
four modifications. In response to the commenter, the four modifications referenced from ASC
Subtopic 310-10 are explicitly included in the FR Y-9Cs definition of LMBEFD and therefore
limits the population of LMBEFD accordingly.
Other Comments Received
The Board also received comments that were unrelated to the changes in this proposal.
The commenter recommended that the Board should propose and implement changes to the
13

See 89 FR 48641 (June 7, 2024).
See 89 FR 48639 (June 7, 2024).
15
See 89 FR 52042 (June 21, 2024).
16
See 88 FR 66933 (September 28, 2023).
14

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reporting of loans to nondepository institutions (NDFIs) and nonpurpose margin loans on the
FR Y-9C to be consistent with the recently finalized Call Report proposal17. The commenter also
recommended that any changes to the definition of ‘Past Due’ should be aligned and
implemented concurrently between the FR Y-9, FR 2886b, and the Call Reports.
In response, the Board may propose and implement revisions to the FR Y-9C related to
the reporting of NDFI loans and nonpurpose margin loans that would be consistent with the
finalized Call Report proposal. Additionally, the Board may also propose changes related to the
definition of “Past Due” in the FR Y-9 and FR 2886b that would be aligned and implemented
concurrent with the Call Reports. Any future changes to the FR Y-9C and FR 2886b related to
the reporting of NDFI loans, nonpurpose margin loans, and the definition of “Past Due” would
be subject to the PRA notice and comment process.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-9 is 114,489
hours, and would remain the same with the revisions. These reporting and recordkeeping
requirements represent approximately 1.7 percent of the Board’s total paperwork burden.

17

See 89 FR 45046 (May 22, 2024).

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Estimated
Estimated
Estimated
number of
annual
average hours
respondents18 frequency per response

FR Y-9
Reporting
FR Y-9C (non AA19 HCs) with
less than $5 billion in total
assets
FR Y-9C (non AA HCs) with
$5 billion or more in total assets
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Recordkeeping
FR Y-9C
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS

Estimated
annual burden
hours

107

4

35.34

15,126

236
9
411
3,596

4
4
4
2

44.54
49.76
5.27
5.45

42,046
1,791
8,664
39,196

73

1

0.50

37

236

4

0.50

472

352
411
3,596
73
236

4
4
2
1
4

1.00
1.00
0.50
0.50
0.50

1,408
1,644
3,596
37
472
114,489

Total

The estimated total annual cost to the public for the FR Y-9 is $7,997,057, and would
remain unchanged with the revisions.20

18

Of these respondents, 5 FR Y-9C (non AA HCs) with less than $5 billion in total assets filers; 212 FR Y-9LP
filers; 3,492 FR Y-9SP filers; and 73 FR Y-9ES filers 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. There are no special accommodations given to
mitigate the burden on small entities. The respondent counts are as of December 31, 2021.
19
A holding company that is subject to the advanced approaches capital rule (i.e., an advanced approaches
institution as defined in the Board’s capital rules) is (1) a global systemically important bank holding company, as
identified pursuant to 12 CFR 217.402, (2) a Category II institution, (3) a subsidiary of a holding company that uses
the advanced approaches pursuant to 12 CFR Part 217 (Board) to calculate its risk-based capital requirements, or
(4) a holding company that elects to use the advanced approaches to calculate its risk-based capital requirements.
Category II institutions include institutions with (1) at least $700 billion in total consolidated assets or (2) at least
$75 billion in cross-jurisdictional activity and at least $100 billion in total consolidated assets. In addition,
depository institution subsidiaries of Category II institutions are considered Category II institutions.
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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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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 the
FR Y-9 reports is $1,922,400.

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