FRY6_FRY7_FRY10_FRY10E_20241223_omb

Supporting Statement for the
Structure Reporting and Recordkeeping Requirements for
Domestic and Foreign Banking Organizations
(FR Y-6, FR Y-7, FR Y-10, and FR Y-10E; OMB No. 7100-0297)
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 Structure Reporting and Recordkeeping Requirements for Domestic and Foreign
Banking Organizations (OMB No. 7100-0297). This information collection comprises the
following four reports:
• Annual Report of Holding Companies (FR Y-6), which collects financial and
organizational information from holding companies (HCs) and foreign banking
organizations (FBOs) that are not “qualifying” FBOs under section 211.23 of the Board’s
Regulation K - International Banking Operations (12 CFR Part 211),1
• Annual Report of Foreign Banking Organizations (FR Y-7), which collects financial and
organizational information from qualifying FBOs,
• Report of Changes in Organizational Structure (FR Y-10), which is an event-generated
report that captures changes in organizational structure or regulated investments and
activities of various Board-supervised entities, and
• Supplement to the Report of Changes in Organizational Structure (FR Y-10E),2 which is
a formless supplement to the FR Y-10 that the Board may use to collect additional
structural information on an emergency basis.
The Board revised the FR Y-7 report by adding an electronic submission option and
adding standard templates for reporting (1) financial statements, (2) organizational charts,
(3) information about shares and shareholders, (4) a firm’s eligibility as a qualified FBO, and
(5) a firm’s compliance with prudential standards. The proposal also made minor clarifications
and conforming edits to the FR Y-7 forms and instructions. The proposal included no changes to
the FR Y-6, FR Y-10, or FR Y-10E. The effective dates are: the option for electronic submission
and the due date change is December 31, 2024; the standard templates is December 31, 2025;
and the automation of the FR Y-7 report is December 31, 2026.
The current estimated total annual burden for the FR Y-6, FR Y-7, FR Y-10, and
FR Y-10E reports is 54,695 hours, and would increase to 55,979 hours. The revisions would
1

See 12 CFR 211.23(a).
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 a current Privacy Act notice). In addition, for each information collection
instrument, respondent burden will be tracked and submitted to OMB.
2

result in an increase of 1,284 hours. The forms and instructions for the FR Y-6, FR Y-7, and
FR Y-10 are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms. There is no formal reporting form for the
FR Y-10E.
Background and Justification
The Board has collected organizational structure reports in some form since the
implementation of the Bank Holding Company Act of 1956 (BHC Act). The information
collected through the FR Y-6, FR Y-7, FR Y-10, and FR Y-10E reports is not available from
other sources.
The Board uses the FR Y-6 to collect financial and structural information from top -tier
HCs and certain FBOs to ensure operations are conducted in a safe and sound manner and to
assess compliance with applicable laws and regulations, including the BHC Act, Change in Bank
Control Act, Home Owners’ Loan Act (HOLA), and the Board’s Regulation Y - Bank Holding
Companies and Change in Bank Control (12 CFR Part 225), Regulation LL - Savings and Loan
Holding Companies (12 CFR Part 238), and Regulation YY - Enhanced Prudential Standards
(12 CFR Part 252). With regard to FBOs, the FR Y-6 collects information from any FBO that
does not meet the requirements of and is not treated as a qualifying FBO under section 211.23 of
Regulation K (12 CFR 211.23). As discussed below, the FR Y-6 collects, among other things,
information about the principal owners and directors of an HC. This information is of
supervisory importance because these individuals can have a significant effect on the policies
and condition of banking organizations. The FR Y-6 also collects data on outside business
interests of directors and officers, including information that indicates whether an individual
owns 25 percent or more of any other banking organizations; this information aids the Federal
Reserve in identifying chain-banking organizations. Information on the outside business interests
of insiders is useful to identify situations that involve a conflict of interest or preferential
treatment in granting credit. In addition, the FR Y-6 serves as a source of HC structure
information for the public. The FR Y-6 data are available to other federal financial supervisory
agencies for use in their supervision of their respective supervised entities.
With respect to FBOs that are bank holding companies (BHCs), the Board uses the
FR Y-7 to collect financial and structural information from qualifying FBOs to assess each
FBO’s ability to be a continuing source of strength to its U.S. operations. In addition, the Board
uses the information to assess whether an FBO is a qualifying FBO and determine compliance
with U.S. laws and regulations.
The Board uses the information collected on the FR Y-10 to monitor that the activities of
reporting financial institutions are safe and sound and to assess compliance with applicable laws
and regulations, including the BHC Act, Gramm-Leach-Bliley Act, Federal Reserve Act (FRA),
HOLA, and the Board’s Regulation K, Regulation Y, Regulation LL, and Regulation YY.
The Board uses the FR Y-10E when there is an immediate need to collect critical
organizational information at the earliest practicable date. The Board uses these supplemental
requests to meet time-sensitive legislative requirements, answer Congressional inquiries, or

2

respond to critical market events that otherwise could not be addressed in a sufficiently timely
manner.
Description of Information Collection
The FR Y-6 is filed by all top-tier HCs and non-qualifying FBOs. The report collects an
organizational chart and annual verification of domestic branches within the organization and
includes information on the identity, percentage ownership, and business interests of principal
shareholders, directors, and executive officers. The FR Y-6 can be filed via a paper or electronic
(Portable Document Format) submission to the appropriate Federal Reserve Bank. Holding
companies must maintain in their files a physical copy of the manually signed FR Y-6 cover
page for a period of three years following submission .
The FR Y-7 is an annual report by qualifying FBOs that have a U.S. banking presence.
The report collects financial statements, organizational information, shares and shareholder
information, and data on the eligibility to be a qualified FBO as defined by the Board’s
Regulation K. The FR Y-7 can be filed via a paper submission mailed to the appropriate Federal
Reserve Bank.
The FR Y-10 is an event-generated information collection that captures changes in
organizational structure or the regulated investments and activities of various entities. The
FR Y-10 can be filed electronically or via a paper, email, or fax submission to the appropriate
Federal Reserve Bank. Holding companies must maintain in their files a physical copy of the
manually signed FR Y-10 cover page for a period of three years following submission.
The FR Y-10E is a free-form supplement to the FR Y-10 that the Board uses to collect
additional structural information as needed on an emergency basis. Responses for the FR Y-10E
are voluntary. Submission methods vary depending on the nature and time-sensitivity of the data
requests.3
Respondent Panel
The FR Y-6 panel comprises top-tier BHCs, savings and loan holding companies
(SLHCs), employee stock ownership plans (ESOPs) and employee share ownership trusts
(ESOTs) or trusts that are BHCs or SLHCs, securities holding companies, intermediate holding
companies (IHCs), and any FBO that does not meet the requirements of and is not treated as a
qualifying FBO under Regulation K.
The FR Y-7 panel comprises all qualifying FBOs that engage in banking in the United
States, either directly or indirectly.
The FR Y-10 and FR Y-10E panels comprise top-tier BHCs (including ESOPs or ESOTs
that are BHCs and financial holding companies); top-tier SLHCs, including ESOPs, ESOTs, or
trusts that are SLHCs pursuant to Regulation LL; FBOs; state member banks that are not
controlled by an HC; Edge and agreement corporations that are not controlled by a member
3

The FR Y-10E has not been used since the last clearance cycle.

3

bank, a domestic HC, or an FBO; and nationally chartered banks that are not controlled by a
BHC or an FBO (with regard to their foreign investments only); and securities holding
companies.
Frequency and Time Schedule
Respondents submit the FR Y-6 annually, no later than 90 calendar days after the end of
the top-tier HC’s fiscal year. Qualifying FBOs submit the FR Y-7 annually as of the end of the
FBO’s fiscal year, and the data are due no later than four months after the reporter’s fiscal yearend. The FR Y-10 is event-generated, and covered financial institutions submit the data within
30 calendar days of a reportable transaction or event. The FR Y-10E is event-generated, and the
Board collects the data from covered financial institutions on an as-needed basis.
Revisions to the FR Y-7
FR Y-7 Report Due Date
The Board changed the due date of the FR Y-7 report from four months after the
reporter’s fiscal year end to 120 calendar days. This change provides more clarity around the
actual due date of the report for respondents and end users of the data. The use of the actual
number of days is also consistent with most other Federal Reserve reports, including the FR Y-6
report.
FR Y-7 Report Form Standard Templates
The Board added an electronic filing option for the FR Y-7, and to automate and add
standard templates for a portion of reporting item one, financial statements; a portion of item
two, organization chart; all of item three, shares and shareholders; all of item four, eligibility as a
qualified foreign banking organization; and all of item five, prudential standards compliance.
Unlike other Board reports, the FR Y-7 is not currently submitted electronically. Instead,
respondents mail their initial report and any subsequent revisions to the appropriate Reserve
Bank. The manual processes around the collection and maintenance of this report can be costly
and burdensome for respondents. Adding the capability to submit and maintain the report
electronically would reduce reporter burden and support costs over time. Moreover, an electronic
filing option would streamline the report submission process and make it easier to revise reports.
Additionally, the FR Y-7 form, which primarily consists of a checklist, is in a relatively
unstructured format that allows respondents to submit required data items in different formats.
For example, respondents may submit shareholder information in a Microsoft Word document or
in an Excel spreadsheet. In other cases, respondents submit their annual report with an attac hed
cover memo referencing the appropriate page numbers where Federal Reserve analysts can
locate the relevant FR Y-7 report information. The templates outline the specific information
required and would eliminate the need for respondents to create multiple documents to submit
data. It would also provide more clarity around reporting requirements and help eliminate
extraneous information, which is often submitted along with the required data.

4

FR Y-7 Clarifications and Conforming Edits
Lastly, the Board made other minor clarifications and conforming edits to the FR Y-7
forms and instructions
Public Availability of Data
Limited structural data from the information collection are published on the National
Information Center’s public website at https://www.ffiec.gov/NPW. Unless granted confidential
treatment, additional respondent data are available to the public upon request through the
appropriate Reserve Bank.
Legal Status
The FR Y-6 is authorized by section 5(c)(1) of the BHC Act (12 U.S.C. § 1844(c)(1)) for
BHCs, section 10(b)(2) of HOLA (12 U.S.C. § 1467a(b)(2)) for SLHCs, and section 618 of the
Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd -Frank Act) (12 U.S.C. §
1850a(c)(1)) for securities holding companies. The Board has authority to require IHCs file the
FR Y-6 pursuant to section 5(c) of the BHC Act (12 U.S.C § 1844(c)) and sections 102(a)(1) and
165 of the Dodd-Frank Act (12 U.S.C. §§ 5311(a)(1) and 5365).4 The Board has the authority to
require any top-tier HC that is organized under foreign law but is not a FBO, and any FBO that
does not meet the requirements of and is not treated as a qualifying FBO under Regulation K, to
file the FR Y-6 under sections 8(a) and 13(a) of the International Banking Act of 1978 (IBA)
(12 U.S.C. §§ 3106(a) and 3108(a)) and section 5(c)(1) of the BHC Act (12 U.S.C. §
1844(c)(1)). Section 8(a) of the IBA makes certain FBOs subject to the provisions of the BHC
Act, and section 13(a) of the IBA authorizes the Board to “issue such rules, regulations, and
orders as” it may deem necessary in order to perform its “respective duties and functions under
this chapter and to administer and carry out the provisions and purposes of this chapter and
prevent evasions thereof.”
The FR Y-7 is authorized by sections 8(a) and 13(a) of the IBA and section 5(c)(1) of the
BHC Act for qualifying FBOs.
The FR Y-10 and FR Y-10E are authorized by section 5(c)(1) of the BHC Act for bank
holding companies, section 10(b)(2) of HOLA for savings and loan holding companies, and
section 618 of the Dodd-Frank Act for securities holding companies. The Board is authorized to
require state member banks and agreement and Edge corporations to file the FR Y-10 by
reporting authorities located in sections 9(6), 25, and 25A of the FRA (for state member banks,
agreement corporations, and Edge corporations, respectively) (12 U.S.C. §§ 324, 602, and 625,
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 FBOs that are treated as bank holding companies under section 8(a) of
the IBA (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 FBOs subject to section 165 of the Dodd-Frank Act to form U.S. IHCs.
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 authority to require U.S. IHCs to report the information contained
in the FR Y-6 report.
4

5

respectively). Similarly, information collection from national banks under the FR Y-10 and
FR Y-10E with respect to their foreign branches, their investments made under Subpart A of
Regulation K, and foreign branches of their foreign subsidiaries that are investments made under
Subpart A of Regulation K, are authorized by the reporting authorities located in sections 25 and
25A of the FRA. The Board has the authority to require FBOs to file the FR Y-10 under sections
8(a) and 13(a) of the IBA and section 5(c)(1) of the BHC Act. Information collections under the
FR Y-6, FR Y-7, and FR Y-10 are mandatory. Information collections under the FR Y-10E are
voluntary.
Individual respondents may request that information submitted to the Board through the
FR Y-6, FR Y-7, FR Y-10, and FR Y-10E be kept confidential. If a respondent requests
confidential treatment, the Board will determine whether the information is entitled to
confidential treatment on a case-by-case basis. To the extent a respondent submits nonpublic
commercial or financial information, which is both customarily and actually treated as private by
the respondent, the respondent may request confidential treatment pursuant to exemption 4 of the
Freedom of Information Act (FOIA) (5 U.S.C. § 552(b)(4)). To the extent a respondent submits
personal, medical, or similar files, the disclosure of which would constitute an unwarranted
invasion of privacy, the respondent may request confidential treatment pursuant to exemption 6
of the FOIA (5 U.S.C. § 552(b)(6)). Additionally, personal home addresses of securities holders
submitted in response to the FR Y-7 will be treated as confidential pursuant to exemption 6 of
the FOIA.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On March 29, 2024, the Board published an initial notice in the Federal Register (89 FR
22145) requesting public comment for 60 days on the extension, with revision, of the FR Y-6,
FR Y-7, FR Y-10, and FR Y-10E reports. The comment period for this notice expired on May
28, 2024. The Board received one comment letter from an individual.
The commenter remarked that the FR Y-6 allows a BHC to request confidential treatment
regarding insider ownership information and asked that this ability be removed. A reporter may
request confidential treatment for any information submitted on the FR Y-6 that the reporter
believes is exempt from disclosure under FOIA. The Board may grant a request for confidential
treatment if the institution clearly has provided a compelling justification for the request. The
Board generally favors disclosure of principal securities holders’ information, but have granted
past requests for confidential treatment, consistent with FOIA exemptions, when there was
evidence of a well-defined present threat to the liberty or personal security of individuals. For
this reason, the Board is maintaining the current process used to fulfill our obligation to consider
requests for confidential treatment.
The commenter also noted that individual Federal Reserve districts differ from each other
on the ease of public access to FR Y-6 submissions and asks the Board to create a single,

6

publicly accessible, nationwide FR Y-6 database. The Board will take this into consideration
during future technology enhancements for the FR Y-6. Additionally, limited structural data
from the information collection are published on the National Information Center’s public
website at https://www.ffiec.gov/NPW.
Lastly, the Board will delay the effective dates for the standard templates to December
31, 2025, and the automation efforts to December 31, 2026. Delaying these effective dates will
allow sufficient time for the development of the necessary technology to support the changes in
the proposal. Aside from this change, the Board adopted the extension, with revision , of the
FR Y-6, FR Y-7, FR Y-10, and FR Y-10E reports as originally proposed. On December 6, 2024,
the Board published a final notice in the Federal Register (89 FR 96978).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-6, FR Y-7,
FR Y-10, and FR Y-10E reports is 54,695 hours, and would increase to 55,979 hours. The
revisions would result in an increase of 1,284 hours. The average hours per response would
remain the same for the FR Y-6, FR Y-10 and FR Y-10E reports. The Board estimates that the
initial average hours per response for the FR Y-7 report would increase from 8.47 hours to 10.10
hours. This increase is due to the initial implementation of the changes. The estimated average
hours per response after the initial implementation would be 4.63 hours. The burden estimate
was produced using the standard Board burden calculation methodology. These reporting and
recordkeeping requirements represent less than 1 percent of the Board’s total paperwork burden.

7

FR Y-6, FR Y-7, FR Y-10, and
FR Y-10E

Estimated
Estimated
Estimated
Estimated
number of
annual average hours annual burden
respondents5 frequency per response
hours

Current
Reporting
FR Y-6
FR Y-7

3,760
205

1
1

2.5
8.47

9,400
1,736

FR Y-10
FR Y-10E

3,790
3,790

3.50 6
1

2.5
0.5

33,153
1,895

Recordkeeping
FR Y-6

3,760

1

0.5

1,880

FR Y-10

3,790

3.50

0.5

6,631
54,695

3,760

1

2.5

9,400

205
205

1
1

10.10
4.63

2,071
949

Current Total
Proposed
Reporting
FR Y-6
FR Y-7 Initial
FR Y-7 Ongoing
FR Y-10
FR Y-10E

3,790
3,790

3.50
1

2.5
0.5

33,153
1,895

Recordkeeping
FR Y-6

3,760

1

0.5

1,880

FR Y-10

3,790

3.50

0.5

Proposed Total

6,631
55,979

Change

1,284

5

Of these respondents, 2,568 for the FR Y-6; 1 for the FR Y-7; 2,689 for the FR Y-10; and 2,689 for the FR Y-10E
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-tablesize-standards. There are no special accommodations given to mitigate the burden on small institutions.
6
In 2022, there were 13,261 FR Y-10’s processed for the 3,790 reporting institutions. This volume yields an
approximate annual frequency of 3.50.

8

The estimated total annual cost to the public for the FR Y-6, FR Y-7, FR Y-10, and
FR Y-10E reports is $3,820,446, and would increase to $3,910,133 with the revisions.7
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 these
reports is $3,638,700 per year.

7

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/.

9