FR3052_20250223_omb

Supporting Statement for the
Supervisory and Regulatory Survey
(FR 3052; OMB No. 7100-0322)
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,
without revision, the Supervisory and Regulatory Survey (FR 3052; OMB No. 7100-0322). The
FR 3052 collects from financial institutions information specifically tailored to the Federal
Reserve’s supervisory, regulatory, and operational responsibilities. The frequency and content of
the questions may depend on economic, regulatory, supervisory, and legislative developments.
The surveys are conducted on a voluntary basis. Respondents may include bank holding
companies (BHCs), state member banks (SMBs), savings and loan holding companies (SLHCs),
intermediate holding companies (IHCs), U.S. branches and agencies of foreign banking
organizations (FBOs), Edge Act and agreement corporations, non-bank financial companies that
the Financial Stability Oversight Council (FSOC) has determined should be supervised by the
Board, or the combined domestic operations of FBOs.
The estimated total annual burden for the FR 3052 is 60,000 hours. There is no formal
reporting form for this information collection.
Background and Justification
The Board has long conducted surveys to help fulfill its statutory responsibilities of
supervising and regulating financial institutions. In some cases, surveys have provided the only
available source of information with regard to certain financial conditions and business activities.
Surveys are driven by the specific needs of the Board, but aggregated findings have also been
used extensively by researchers outside the Federal Reserve System and other financial industry
regulators.
The Board occasionally needs to gather time-sensitive data from the banking and
financial industries on financial conditions or particular business activities outside of the
standard regulatory reporting process. The data may be particularly needed in times of critical
economic or regulatory changes or when issues of immediate concern arise from supervisory
initiatives, requests from the Board of Governors, or other matters of significant public interest.
The Board implemented the FR 3052 in 2009 to facilitate certain supervisory and regulatory
surveys in such circumstances. Past surveys have collected information related to energy lending
exposure, cloud-based data exchange services, regulatory capital, the Comprehensive Capital
Analysis and Review, operational risk loss event history, transactions by government securities
dealers, and small debit card issuers.
Over the past three years, the Board has used the FR 3052 to conduct surveys fewer than
10 times in total. These surveys related to the energy sector, London Inter-Bank Offered Rate,
interest rate risk, and heightened monitoring related to the March 2023 bank failures.

The Board will not use the FR 3052 to collect information that is available from other
sources. When conducting surveys using the FR 3052, the Board makes a determination that the
frequency and format are reasonable and that there are not less burdensome means available for
obtaining the information.
Description of Information Collection
The Board utilizes the FR 3052 survey process, as needed, to collect information on
specific issues that affect its statutory responsibilities. A principal value of the FR 3052 is the
flexibility it provides the Federal Reserve to respond quickly to the need for data due to
unanticipated economic, financial, supervisory, or regulatory developments. The Board cannot
predict what specific information will be needed, but such needs are generally very timesensitive. Because the relevant questions may change with each survey, there is no fixed
reporting form.
Written qualitative questions or questionnaires may include categorical questions, yes-no
questions, ordinal questions, and open-ended questions. Written quantitative surveys may request
dollar amounts, percentages, numbers of items, interest rates, and other similar information.
Institutions may also be asked to provide copies of existing documents (for example, pertaining
to practices and performances for a particular business activity). Before conducting a survey, the
Board reviews any information to be collected to determine if the information is available by
other means. In soliciting participation for a survey, the Board would explain to respondents the
purpose of the survey and how the data would be used.
The Board welcomes feedback from firms on surveys conducted under the FR 3052, both
formally, through frequently asked questions, and informally via outreach sessions, ad-hoc
discussions, and e-mails. When a survey template is available in advance of the planned
distribution date, the Board works to distribute the template to respondents early for
informational purposes, and when time allows, to incorporate any feedback. Following a survey,
the Board will make the survey instrument publicly available on the Board’s OMB Public
Docket.
Information technology requirements have varied for surveys. In each case, the Board
studies the availability of submission methodologies and leverages existing reporting
mechanisms to the extent feasible. The Board has collected FR 3052 surveys in the past by
secure email address, written questionnaire, telephone, SharePoint, and a variety of existing
reporting applications maintained by the Federal Reserve.
Respondent Panel
The FR 3052 panel may include BHCs, SMBs, SLHCs, IHCs, U.S. branches and
agencies of FBOs, Edge Act and agreement corporations, nonbank financial companies that the
FSOC has determined should be supervised by the Board, and the combined domestic operations
of FBOs.

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Frequency and Time Schedule
The data submission timeline for each survey varies and would be determined before
distribution of the survey materials to respondents.
Public Availability of Data
The Board will choose whether to publish survey data that it obtains from respondents
and will inform the respondents beforehand if the data are to be published on an individualinstitution basis. Depending upon the nature of the data collection, the survey data may be
confidential. Aggregate survey information may be cited in published material such as Board
studies or working papers, professional journals, the Federal Reserve Bulletin, testimony and
reports to the Congress, or other vehicles.
Legal Status
The FR 3052 is authorized by several statutes authorizing the Board to require reports of
condition from institutions subject to its supervision. These include section 9 of the Federal
Reserve Act (FRA) (12 U.S.C. § 324),1 section 5 of the Bank Holding Company Act of 1956
(12 U.S.C. § 1844(c)(1)(A)),2 section 10 of the Home Owners’ Loan Act (12 U.S.C. §
1467a(b)(2)),3 section 7 of the International Banking Act of 1978 (IBA) (12 U.S.C. §
3105(c)(2)),4 section 8 of the IBA (12 U.S.C. § 3106(a)),5 sections 25 and 25A of the FRA
(12 U.S.C. §§ 602 and 625),6 and section 161 of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (12 U.S.C. § 5361).7 Survey submissions under the FR 3052 are
voluntary.
The questions asked on each survey will vary. The Board’s ability to keep confidential
responses to the FR 3052 must therefore be determined on a case-by-case basis. To the extent
that the information that firms submit to the Board is made available to the public, the
information would not be considered confidential and would not raise a question of
confidentiality. However, to the extent that the information firms submit to the Board is not
available to the public (or has not yet been made available to the public, but will be published at
a later date), the information would qualify as confidential. This confidential information may be
exempt from disclosure by the Board, pursuant to the Freedom of Information Act (FOIA).
Exemptions 4 and 8 of the FOIA in particular may be relevant. Exemption 4 covers confidential
Requiring state member banks to make reports of condition “in such form and [containing] such information as the
Board of Governors of the Federal Reserve System may require.”
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Authorizing the Board to require a bank holding company and any subsidiary thereof to submit reports regarding
financial condition and compliance.
3
Authorizing the Board to require a savings and loan holding company and any subsidiary thereof to submit reports
containing such information concerning the operation of the company or its subsidiaries as the Board may require.
4
Subjecting each branch or agency of a foreign bank to the provisions of 12 U.S.C. § 324 requiring reports of
financial condition as if it were a state member bank.
5
Generally subjecting foreign banking organizations to the Bank Holding Company Act.
6
Requiring Edge and agreement corporations to “make reports to the Board of Governors of the Federal Reserve
System at such times and in such form as it may require.”
7
Authorizing the Board to require reports of financial condition and compliance from nonbank financial companies
subject to the Board’s supervision and any subsidiaries thereof.
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commercial or financial information that is customarily and actually treated as private by its
owner and provided to the government under an assurance of privacy (12 U.S.C. § 552(b)(4)).8
To the extent that a firm does customarily and actually keep the information it submits to the
Board in response to a survey confidential, this information would be exempt from disclosure
under exemption 4. Exemption 8 covers matters 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)). The
information submitted to the Board in response to surveys conducted under the FR 3052 may be
related to the reporting firms’ condition. If so, the information submitted would be exempt from
disclosure under exemption 8.
Responses to the FR 3052 are tabulated and summarized at the Board. This aggregate
information is not considered confidential, and aggregate survey information may be cited in
published material such as Board studies or working papers, professional journals, the Federal
Reserve Bulletin, testimony and reports to the Congress, or other vehicles.
Consultation Outside the Agency
At this time, there has been no consultation outside the Federal Reserve System;
however, surveys may be conducted jointly with other agencies. If this were to occur, the Federal
Reserve would consult with other agencies, to the extent practicable, to create a consistent set of
questions or a substantively similar information collection.
Public Comments
On October 2, 2024, the Board published an initial notice in the Federal Register (89 FR
80246) requesting public comment for 60 days on the extension, without revision, of the
FR 3052. The comment period for this notice expired on December 2, 2024. The Board received
one comment from a public interest law firm. The comment supported the proposal to extend,
without revision, the FR 3052. The comment recommended integrating an international auditing
standard and establishing a collaborative working group related to future surveys under the
FR 3052. The Board appreciates feedback and will consider these recommendations in
connection with future surveys. The Board adopted the extension, without revision, of the
FR 3052 as originally proposed. On February 7, 2025, the Board published a final notice in the
Federal Register (90 FR 9157).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3052 is capped
at 60,000 hours. Because the number of surveys and respondents will fluctuate depending on the
number and types of topics being considered, it is not possible to predict exactly how many will
be conducted in a given year. For the purpose of the burden estimate, it is assumed that the
survey will be conducted up to 24 times per year and average 5,000 respondents per survey.
Based on previous data collections, the Board estimates that the average time per response will

8

Food Marketing Institute v. Argus Leader Media, 139 S. Ct. 2356, 2364 (2019).

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be approximately 30 minutes. These reporting requirements represent less than 1 percent of the
Board’s total paperwork burden.

FR 3052

Estimated
number of
respondents9

Estimated
annual
frequency

Current

5,000

24

Estimated
Estimated
average hours annual burden
per response
hours
0.5

60,000

The estimated total annual cost to the public for the FR 3052 is $4,191,000.10
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 cost of the surveys depends on the size of the sample, the number of questions asked,
the type and complexity of the questions asked, and the frequency of the surveys. The estimated
cost to the Federal Reserve System for the FR 3052 is $270,200.

9

Of these respondents, 4,500 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 institutions.
10
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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