FR3036_20250430_omb

Supporting Statement for the
Central Bank Survey of Foreign Exchange and Derivatives Market Activity
(FR 3036; OMB No. 7100-0285)
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 Central Bank Survey of Foreign Exchange and Derivatives Market Activity
(FR 3036; OMB No. 7100-0285). The FR 3036 is a component of the U.S. portion of a global
data collection that is conducted by central banks once every three years and captures
information relating to the volume of foreign exchange (FX) transactions. 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. More than 50 central
banks plan to conduct this global data collection (the BIS survey) in 2025 (the 2025 Survey).
Aggregated data from the FR 3036 is compiled and forwarded to the BIS, which uses the data to
produce and publish these statistics. The FR 3036 is voluntary; respondents are not required to
participate in the information collection.
The BIS survey has two parts: a turnover (volume of transactions) survey and a
derivatives outstanding survey. The Board revised the FR 3036, the turnover portion of the BIS
survey, to incorporate clearer guidance on what is reportable vs non-reportable turnover. Further
clarifying language has also been included regarding non-market facing trades, namely relatedparty and back-to-back trades, as well as expanding the reporting granularity in these categories
for a limited number of currencies (USD, EUR, JPY) in both FX and interest rate derivatives.
Also, the Board added a new FX settlement risk schedule, replacing the revisions
incorporated in 2022. The BIS’s 2025 Survey FX settlement guidelines (which we will
reference) differ from those in 2022 in that the reporting methodology has been streamlined on a
global group basis, whereby the reporting dealers submit settlement data that includes majority
owned subsidiaries and branches both at home and abroad. The data now include the value of all
deliverable two-way trades settled by the legal entities pertaining to the reporting dealer that
conduct active business with large customers. Under the new methodology, reporting dealers will
be submitting consolidated settlement data only to the jurisdiction where they are headquartered,
and accordingly, only reporting dealers headquartered in the U.S. will be required to submit
settlement data to the Federal Reserve. Additional changes to the reporting guidelines are also
included. The effective date of these revisions would be April 2025.
The current estimated total annual burden for the FR 3036 is 1,365 hours, and would
increase to 1,458 hours. The revisions would result in an increase of 93 hours. The form and
instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms.

Background and Justification
The BIS survey is a comprehensive source of global information on the volume of FX
and derivatives trading and, as such, is useful to the Federal Reserve System and other
government agencies in understanding market developments and trends, particularly with respect
to the U.S. dollar. The data provide the Manager of the Federal Reserve System Open Market
Account, among others, with information for analyzing market developments and conducting
Federal Reserve and U.S. Treasury FX operations. Survey data are also used by market
participants to gain data on the market that is not available from firm-level data. Academics and
the general public also use the survey’s data for research and analysis.
The FR 3036 covers only the turnover portion of the BIS survey and is collected during
the month of April. The derivatives outstanding portion of the BIS survey is covered by the June
2025 Semiannual Report of Derivatives Activity (FR 2436; OMB 7100-0286).
This information collected by the FR 3036 is not available from other sources. The
collection is part of a global effort that includes the contributions of over 50 central banks. The
Federal Reserve System, in its role to monitor and analyze global financial market developments,
relies on such data to support its monitoring efforts. Given the importance of the U.S. dollar in
global markets, there would be a global reporting impact to the 2025 Survey in the circumstance
where the Federal Reserve System would elect not to participate in the collection.
Description of Information Collection
The FR 3036 survey will collect information on the size and structure of the FX and overthe-counter (OTC) derivatives markets. It is submitted to the Federal Reserve Bank of New York
(FRBNY). The survey will cover the turnover in the FX market on Tables A1-A6 (spot,
forwards, FX swaps, currency swaps, and OTC options) and table A7 (FX settlement), and in
interest rate derivatives markets on Tables B1-B2 (forward rate agreements, overnight index
swaps, other interest rate swaps, and OTC options).
Notional amounts of FX turnover (Tables A1, A2, A3, A4, A5, and A6). Respondents
should report the notional value of FX turnover in the given month for 21 major U.S. dollar
currency pairs, 12 major non-dollar Euro pairings, and six major non-dollar Yen pairings.
Residual columns for non-specified currency pairs are also collected for an additional 37
specified foreign currencies.
Notional amounts of settlement of FX transactions (Table A7). Respondents report the
notional value of FX transactions settled during the month.
Notional amounts of single currency interest rate derivatives (Tables B1 and B2).
Respondents should report the notional value of single currency interest rate derivatives turnover
in April 2025 for the U.S. dollar and 39 additional currencies. A residual column for turnover in
non-specified currencies is also collected.

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Additional detail. The tables above collect the following additional detail on the notional
amounts of turnover in the given month:
Product types: FX spot, outright forwards, FX swaps, currency swaps, and sum of bought
and sold OTC FX options (Tables A1, A2, A3, A4, A5, and A6); forward rate agreements,
overnight indexed swaps, other interest rate swaps, and OTC interest rate options (Tables B1 and
B2).
Counterparty types: Reporting dealers, other financial institutions, and non-financial
customers. Counterparties are further broken out into local and cross-border. For FX turnover
(Tables A1, A2, A3, A4, A5, and A6), other financial institutions are further broken out into (1)
non-reporting banks, (2) institutional investors, (3) hedge funds and proprietary trading firms, (4)
official sector financial institutions, (5) others, and (6) undistributed.
Prime brokerage: Total FX turnover for each product type (Tables A1, A2, A3, A4, A5,
and A6) collects a memorandum item, “of which prime brokered”, to capture turnover conducted
through a dealer’s prime brokerage accounts. Prime brokers are institutions facilitating trades for
their clients (often institutional funds, hedge funds and other proprietary trading firms). Prime
brokers enable their clients to conduct trades with a group of predetermined third-party banks in
the prime broker’s name. These transactions have accounted for a large part of the growth in FX
turnover in recent years.
Retail turnover: Total FX turnover for each product type (Tables A1, A2, A3, A4, A5,
and A6) collects a memorandum item, “of which retail-driven”, to capture turnover associated
with retail clients. Retail-driven transactions are defined as reporting dealers’ transactions with
“wholesale” financial counterparties that cater to retail investors and direct transactions with
“non-wholesale” investors. In recent years, retail investors have increased their participation in
the FX market, facilitated by internet-based trading platforms.
Non-deliverable forwards: Total turnover in FX outright forwards (Tables A1, A2, and
A3) collects a memorandum item, “of which non-deliverable forwards” (NDF), to capture
turnover in six major U.S. dollar currency pairs (USD/BRL, USD/CNY, USD/INR, USD/KRW,
USD/RUB and USD/TWD) with significant non-deliverable forward turnover. Turnover in NDF
for other less well-traded pairs will also be captured in aggregate. NDF differ from deliverable
forwards in that there is no physical delivery of the two underlying currencies at maturity and
instead are settled in cash.
Non-market facing trades: Total turnover in FX spot (Table A2) collects a grand total in
“o/w back-to-back trades”. Turnover in FX outright forwards, FX swaps, currency swaps, OTC
options, other products, and total FX contracts (Tables A2 and A5), as well as turnover in
forward rate agreements, overnight indexed swaps, other swaps, total OTC options, other
products and total interest rate contracts (Tables B1 and B2) collects a grand total in “o/w backto-back trades” and “o/w compression trades”.
Original maturities: Total turnover in FX outright forwards and FX swaps capture
original maturities according to the following maturity bands (1) one day, (2) over one day and

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up to seven days, (3) over seven days and up to one month, (4) over one month and up to 3
months, (5) over 3 months and up to 6 months, and (6) over six months.
Execution method for FX contracts (Table C2). The survey includes the execution
method used for transacting FX contracts reported on Tables A1-A6 (spot, forward, swaps, and
options) and the associated counterparty (reporting dealers, other financial institutions, and nonfinancial customers). Execution is currently reported as (1) Voice Direct, (2) Voice Indirect, (3)
Electronic Direct single-bank proprietary trading system, (4) Electronic Direct Other, (5)
Electronic Indirect Anonymous Venues, (6) Electronic Indirect Disclosed Venues and (7)
Unallocated (for turnover that fails to be allocated into one of the aforementioned execution
method categories).
The Board understands that respondents use information technology to comply with the
provisions of FR 3036, including submitting the survey using the Reporting Central application.
Respondent Panel
The FR 3036 panel comprises large commercial banks, brokers and dealers, and U.S.
offices of foreign banking offices with dealing operations in the United States. Respondents were
identified for the survey based on their participation in another survey, the Survey of North
American Foreign Exchange Volume, which is conducted by the FRBNY in collaboration with
the New York Foreign Exchange Committee (FXC), an industry trade group sponsored by the
FRBNY.
Frequency and Time Schedule
The FR 3036 is submitted every three years. Reporting includes all trading conducted
during the month of April 2025, with the data due in June 2025. The choice of April for
Turnover data continues the practice of previous surveys. April was selected to avoid strong
seasonal effects in the foreign exchange market at other times of the year. In addition, April is
the month other central banks will be conducting their surveys and adoption of this date is
critical for the aggregation of consistent global statistics.
Proposed Revisions to the FR 3036
The Board proposes to 1) provide clearer guidance on what is reportable turnover
(explicit exclusion of intra-dealer trades), 2) add breakdown by currency totals (USD/EUR/JPY)
and instrument (Forwards and Swaps) for ‘o/w related party trades’ in both Foreign Exchange
Contracts and Interest Rate Derivatives in Tables A1, A2, A4, B1 and B2, and 3) add breakdown
by currency totals (USD/EUR/JPY) for all instruments for ‘o/w back-to-back trades’ in both
Foreign Exchange Contracts and Interest Rate Derivatives in Tables A1, A2, A4, A5, B1 and B2.
The proposed changes would provide insight into an important facet of the FX market
that examines specific trading relationships and would be particularly valuable to the Board and
other data users given that both transaction types have been cited by reporting dealers to
comprise an increasing share of market turnover. The 2025 Survey introduces a limited currency

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and instrument breakdown for related party trades to better separate “market facing” turnover
with customers across various breakdowns. The breakdown is also applied to back-to-back trades
in order to maintain consistency in reporting and better monitor the first-time transfer of risk of
the original trade. These proposed line items were circulated to a selection of reporting dealers
and, based on feedback received, have been modified to ensure a more limited impact on
respondent burden.
The Board also proposes a more significant addition in the form of a revised Settlement
of FX Transactions schedule (Table A7. Settlement of Foreign Exchange Transactions) to collect
information on FX settlement, including a breakdown by counterparty and settlement method.
The new schedule would enable the Federal Reserve to more accurately monitor FX settlement
risk. Understanding settlement risk furthers the Federal Reserve’s ability to monitor financial
stability in global markets, conduct Federal Reserve and U.S. Treasury FX operations, supply
international dollar liquidity through facilities operated by the Federal Reserve, and contribute to
the BIS’s efforts to publish global statistics. The newly proposed reporting methodology
developed in collaboration with the FXC and BIS Committee on Payments and Market
Infrastructure aims to improve the monitoring of FX settlement risk mitigants and their
application.
The Board proposes to revise the FR 3036 instructions to be more in alignment with the
BIS’s revamped 2025 Survey FX settlement guidelines. The proposed instructions will provide
more examples and clarification for respondents. Many respondents file this survey in multiple
jurisdictions; aligning more closely with BIS guidelines is designed to ease completion of the
data for respondents across their multiple survey submissions. The reorganization of instructions
also allows the Board to more efficiently track updates when BIS revises the guidelines again.
Public Availability of Data
Aggregated market totals from the survey are published in a data release by the FRBNY
in the fall of 2025 and will also be provided to the BIS for its published report on global trading.
Legal Status
The FR 3036 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).
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 3036 to help fulfill these obligations. The FR 3036 is
voluntary.

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Individual firm information collected on the FR 3036 is considered confidential because
it constitutes nonpublic commercial or financial information, which is both customarily and
actually treated as private by the respondent. Therefore, this information may be kept
confidential under exemption 4 of the Freedom of Information Act, which exempts “trade secrets
and commercial or financial information obtained from a person and privileged or confidential”
(5 U.S.C. § 552(b)(4)). If it should be determined that any information collected on the FR 3036
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. Aggregated FR 3036 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.
Consultation Outside the Agency
This survey is being coordinated by the BIS with other participating central banks. In
particular, the Bank of England along with the BIS surveyed and solicited feedback from its list
of reporting dealers on proposed line items additions as well as changes to the settlement portion
for multiple prior reporting periods.
Public Comments
On December 23, 2024, the Board published an initial notice in the Federal Register (89
FR 104539) requesting public comment for 60 days on the extension, with revision, of the
FR 3036. The comment period for this notice expired on February 21, 2025. The Board received
one comment. The commenter argues that the FR 3036 does not provide timely data for
assessing rapidly evolving risks, such as those arising from repledging in derivative swaps and
the accumulation of off-balance-sheet debt. The Board believes that the triennial cadence and
scope of the survey, considered in conjunction with other data available to the Federal Reserve,
strike an appropriate balance between the purposes of the survey (understanding market
developments and trends and contributing to the BIS’s effort to publish aggregate global
statistics) and the burden on respondents. The commenter also asks the Board to adopt
compulsory real-time capture of foreign exchange transactions and associated stress testing and
scenario analysis to preserve the market’s integrity under Generally Accepted Accounting
Principles. The Board considers this request outside the scope of the proposal. The Board
adopted the extension, with revision, of the FR 3036 as originally proposed. On April 30, 2025,
the Board published a final notice in the Federal Register (90 FR 17935).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3036 is 1,365
hours, and would increase to 1,458 hours with the revisions. The number of respondents is based
on the number of respondents to the Survey of North American Foreign Exchange Volume in
2023. The average hours per response is based on the estimate that it will take 1 additional hour
to complete the incremental information in the turnover portion. For the settlement portion,
reporting dealers use separate systems for trading versus settlement, and settlement systems
group together trades; a higher burden of 9 hours per respondent is estimated as a result. These
reporting requirements represent less than 1 percent of the Board’s total paperwork burden.

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FR 3036

Estimated
number of
respondents1

Current

21

1

65

1,365

13

1

66

858

8

1

75

600
1,458

Proposed
Reporting dealers
Reporting dealers for FX
settlements only
Proposed Total
Change

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

93

The estimated total annual cost to the public for the FR 3036 is $98,485, and would
increase to $105,195 with the revisions.2
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 3036 is $950,000.

1

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.
2
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/.

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