FR2436_20250430_omb

Supporting Statement for the
Semiannual Report of Derivatives Activity
(FR 2436; OMB No. 7100-0286)
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 Semiannual Report of Derivatives Activity (FR 2436; OMB No.
7100-0286). The FR 2436 collects derivatives market statistics from the eight largest U.S.
dealers of over-the-counter (OTC) derivatives. Data are collected on the notional amounts and
gross fair values of the volumes outstanding of broad categories of foreign exchange, interest
rate, equity, commodity-linked, and credit default swap OTC derivatives contracts across a range
of underlying currencies, interest rates, and equity markets.
The FR 2436 is the U.S. portion of a global data collection conducted by central banks.
The Bank for International Settlements (BIS), of which the Board is a member, compiles
aggregate national data from each central bank to produce and publish global market statistics.
The BIS survey has two parts: a Derivatives Outstanding survey and a Turnover (volume of
transactions) survey. The FR 2436 fulfills the Derivatives Outstanding portion and complements
the triennial Central Bank Survey of Foreign Exchange and Derivatives Market Activity
(FR 3036; OMB No. 7100-0285), which collects data on derivatives turnover for the Turnover
portion of the survey. Together with data from other reporting countries, the Derivatives
Outstanding portion of the BIS survey represents at least 90 percent of global OTC derivatives
positions.
The estimated total annual burden for the FR 2436 is 3,898 hours. The form and
instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
The purpose of the FR 2436 is to obtain comprehensive and internationally consistent
information on the size and structure of the OTC derivatives markets. The statistics are useful to
the Board, other central banks, and other parties who monitor patterns of activity in financial
transactions. Due to the global nature of derivatives activity, cooperative efforts are necessary to
effectively monitor this activity and to collect comprehensive data on it. The Board’s
involvement in this international reporting program, therefore, promotes the availability of
statistics necessary for oversight of international financial markets. Federal Reserve staff use
these data to monitor activity in the OTC derivatives markets and to gauge the concentration in,
and hence, competitiveness of these markets.
A sum of notional amounts outstanding provides a means of approximating the scale and
character of market transactions, in much the same manner as a sum of principal amounts
provides for the cash market. Allocating notional amounts outstanding to market risk,
instrument, maturity, and counterparty categories provides greater insight into the exposures to

price risks transferred between contracting parties. Additionally, regularly published data on
notional amounts enhance market transparency and permit market participants to compare, over
time, the size and composition of their derivatives activities with those taking place in the market
as a whole.
Gross fair values can also be used as a measure of market size; they show, at a given
point in time, the amount of risk that is transferred using derivatives contracts. Although, this
measure requires summing the gross positive fair values of all market participants (not just of
reporters), the gross positive fair value of nonreporting firms can be captured by measuring the
negative fair value of reporting firms’ contracts with nonreporting firms. Thus, market size
statistics based on gross fair value can be constructed while maintaining a limited reporting
population. This information is not available from other sources.
Description of Information Collection
The panel of derivatives dealers provides data on outstanding positions (notional, gross
positive, and gross negative fair values) with breakdowns by broad market risk category, product
type, counterparty type, maturity, and specific underlying market risks (i.e., the currency, equity
market, or reference entity that underlie the contract). In addition, reporters provide data on the
credit exposures and liabilities arising from all outstanding credit default swaps (CDS) contracts,
as well as from the entire portfolio.
The Board understands that respondents use information technology to comply with these
provisions; the data are transmitted to the Federal Reserve Bank of New York (FRBNY) via
Reporting Central.
Respondent Panel
The FR 2436 panel comprises eight of the largest U.S. dealers of OTC derivatives.
Frequency and Time Schedule
The FR 2436 is submitted semiannually. Respondents file the FR 2436 within 75 days of
the as of dates, June 30 and December 31, each year. After editing the data, the FRBNY sends
the aggregated data to the BIS and sends reporter-level and aggregated data to the Board. The
Board uses the reporter-level data to compute aggregated concentration statistics, which it sends
to the BIS. The BIS compiles the aggregated data and the concentration statistics from U.S.
institutions with those from the approximately 60 additional reporters from other G-10 countries;
it then constructs and publishes global derivatives market statistics.
Public Availability of Data
The aggregated FR 2436 data is compiled and forwarded to the BIS, which publishes
global market statistics that are aggregates of national data from the Federal Reserve and other
central banks.

2

Legal Status
The FR 2436 is authorized pursuant to sections 2A and 12A of the Federal Reserve Act
(FRA). Section 2A of the FRA requires that the Board and the Federal Open Market Committee
(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).
In addition, under section 12A of the FRA, the FOMC is required to implement regulations
relating to the open market operations conducted by Federal Reserve Banks. Those transactions
must be governed 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). The Board and
the FOMC use the information obtained from the FR 2436 to help fulfill these obligations. The
FR 2436 is voluntary.
Aggregated FR 2436 data and statistics are compiled and forwarded to the BIS, which
publishes global market statistics that are aggregates of national data from the Federal Reserve
and other central banks. The Federal Reserve generally treats the individual firm information
collected by the FR 2436 as confidential. This individual firm information may be exempt from
public disclosure pursuant to the Freedom of Information Act (FOIA), under exemptions 4
and/or 8. Exemption 4 applies to confidential commercial or financial information that is both
customarily and actually treated as private by its owner (12 U.S.C. § 552(b)(4)).1 The
information submitted on the FR 2436 is commercial or financial information and would
therefore qualify for confidential treatment under FOIA’s exemption 4 if it is confidential
information that is both customarily and actually treated as private by the reporting firm.
Exemption 8 exempts from disclosure information “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)). As documents
related to the reporting firms’ condition prepared for the use of the Board, an agency responsible
for the regulation and supervision of financial institutions, the FR 2436 may also be exempt from
disclosure under exemption 8. If the Board determines that any information collected on the
FR 2436 must be released, other than in the aggregate in ways that will not reveal the amounts
reported by any one institution, respondents will be notified.
Consultation Outside the Agency
The Board and FRBNY consult periodically with the BIS to remain consistent with
international guidelines for collecting these data.
Public Comments
On December 23, 2024, the Board published an initial notice in the Federal Register (89
FR 104538) requesting public comment for 60 days on the extension, without revision, of the
FR 2436. The comment period for this notice expired on February 21, 2025. The Board did not
receive any comments. The Board adopted the extension, without revision, of the FR 2436 as

1

See Food Marketing Institute v. Argus Leader Media, 588 U.S. 427, 440 (2019).

3

originally proposed. On April 30, 2025, the Board published a final notice in the Federal
Register (90 FR 17934).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2436 is 3,898
hours. The number of respondents is based on evaluating data from the most recent FR 3036 (in
2022), determining the size of reporters’ derivatives positions and selecting potential reporters
that represent coverage of 90 percent of all OTC derivatives contracts at U.S.-headquartered
bank holding companies. The burden estimate was adjusted up using the standard Board burden
calculation methodology. These reporting requirements represent less than 1 percent of the
Board’s total paperwork burden.

FR 2436
Current

Estimated
number of
respondents2
8

Estimated
Estimated
Estimated
annual
average hours annual burden
frequency per response
hours
2
243.63
3,898

The estimated total annual cost to the public for the FR 2436 is $281,241.3
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 is $130,000.

2

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.
3
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 $24, 45% Financial
Managers at $87, 15% Lawyers at $88, and 10% Chief Executives at $126). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2024, published April 2, 2025, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

4