FFIEC002_FFIEC002S_20250729_omb

Supporting Statement for the
Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks
(FFIEC 002; OMB No. 7100-0032)
and the
Report of Assets and Liabilities of a Non-U.S. Branch that is Managed or Controlled by a
U.S. Branch or Agency of a Foreign (Non-U.S.) Bank
(FFIEC 002S; OMB No. 7100-0032)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Report of Assets and Liabilities of
U.S. Branches and Agencies of Foreign Banks (FFIEC 002; OMB No. 7100-0032) and Report of
Assets and Liabilities of a Non-U.S. Branch that is Managed or Controlled by a U.S. Branch or
Agency of a Foreign (Non-U.S.) Bank (FFIEC 002S; OMB No. 7100-0032). The Board submits
this request on behalf of itself, the Federal Deposit Insurance Corporation (FDIC), and the Office
of the Comptroller of the Currency (OCC) (collectively, the agencies). No separate submission
will be made by the FDIC or OCC.
The FFIEC 002 must be submitted quarterly by U.S. branches and agencies of foreign
banks. The report requests detailed schedules of assets and liabilities as a condition report with a
variety of supporting schedules. This information is used to fulfill the agencies’ supervisory and
regulatory requirements pursuant to the International Banking Act of 1978 (IBA). In addition,
the Board uses the information collected by the FFIEC 002 to conduct monetary and financial
analysis essential for the conduct of monetary policy. The FFIEC 002S is a mandatory
supplement to the FFIEC 002 that collects information on assets and liabilities of any non-U.S.
branch that is managed or controlled by a U.S. branch or agency of a foreign bank.1 A separate
FFIEC 002S supplement is completed by the managing or controlling U.S. branch or agency for
each applicable foreign branch. The FFIEC 002S collects data on U.S. deposits, credit, and
international indebtedness, and assists U.S. bank supervisors in determining the assets managed
or controlled by the U.S. agency or branch of the foreign bank.
On September 28, 2023, the agencies, under the auspices of the FFIEC, requested public
comment for 60 days on a proposal to revise the FFIEC 002.2 The proposed revisions included
changes to the form and instructions that were in response to the Financial Accounting Standards
Board’s (FASB) Accounting Standards Update (ASU) 2022-02, “Financial Instruments - Credit
Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures” (ASU 2022-02).
After considering the comments received on the proposal, the FFIEC and the agencies on May
22, 2024, finalized certain proposed revisions resulting from ASU 2022-02, but deferred action
related to the length of time that loan modifications to borrowers experiencing financial

1

“Managed or controlled” means that a majority of the responsibility for business decisions, including, but not
limited to, decisions with regard to lending, asset management, funding, liability management, or the responsibility
for recordkeeping with respect to assets or liabilities for that foreign branch resides at the U.S. branch or agency.
2
88 FR 66933 (September 28, 2023).

difficulty would be reported in the FFIEC 002.3 The agencies have now completed their review
and are revising the instructions to align the regulatory reporting of loan modifications to
borrowers experiencing financial difficulty with U.S. generally accepted accounting principles
(GAAP). These revisions would be effective as of the December 31, 2025, report date. However,
the agencies do not object if an institution chooses to implement this revised reporting in
advance of the effective date for the September 30, 2025, report date.
The current estimated total annual burden for the FFIEC 002 and FFIEC 002S is 18,490
hours, and would not change with the proposed revisions. The forms and instructions are
available on the FFIEC’s public website at https://www.ffiec.gov/resources/reporting-forms.
Background and Justification
Report of Assets and Liabilities of U.S. Branches and Agencies of Foreign Banks
(FFIEC 002)
The IBA specifies that foreign banks’ branches and agencies in the United States are
subject to the supervisory authority of the U.S. federal banking agencies and that responsibility
for federal supervision is to be shared among the agencies. As one step in carrying out the
supervisory and regulatory responsibilities imposed by the IBA, the agencies instituted the
FFIEC 002 in June 1980. The report collects from the U.S. branches and agencies of foreign
banks information that is similar to that collected from U.S. commercial banks and savings
associations by the Call Reports, although the FFIEC 002 collects fewer data items.
In addition to its supervisory and regulatory uses, the Board uses the information
collected by the FFIEC 002 to conduct monetary and financial analysis essential for the conduct
of monetary policy. The data are used to analyze credit developments, identify sources and uses
of funds in the banking sector, and assess financial developments within the U.S. banking
system. The data help to interpret the bank credit and deposit information that the Board uses
when making monetary policy decisions and assists the Board in gauging the response to those
decisions. The information collected by the FFIEC 002 is not available from other sources.
Report of Assets and Liabilities of a Non-U.S. Branch that is Managed or Controlled
by a U.S. Branch or Agency of a Foreign (Non-U.S.) Bank (FFIEC 002S)
Foreign banks often conduct business at branches that are domiciled in countries other
than the United States, but which are largely run out of the banks’ U.S. agency or branch office,
with a separate set of books but often with overlapping management responsibilities. Such
branches often engage in transactions with U.S. residents.
The information reported on the FFIEC 002S is collected for several reasons: (1) to
collect information helpful for the supervision of U.S. offices of foreign banks, which often are
managed jointly with these branches, (2) to monitor deposit and credit transactions of U.S.
residents, (3) to monitor the impact of policy changes such as changes in reserve requirements,
(4) to analyze structural issues concerning foreign bank activities in U.S. markets, and (5) to
3

89 FR 45046 (May 22, 2024).

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understand indebtedness and flows of banking funds in developing countries, in connection with
data collected by the International Monetary Fund and the Bank for International Settlements,
which are used in economic analysis.
The FFIEC 002S collects details on transactions with U.S. residents and with residents of
the banks’ home countries. In most cases, these data cover a large proportion of the subject
branches’ total activities since most of these branches have heavy exposures to their home
countries and deal largely with U.S. customers. This collection allows for more complete data on
U.S. deposits, credit, and international indebtedness and assists U.S. bank supervisors in
determining the assets managed or controlled by the U.S. agency or branch of the foreign bank.
The information collected by the FFIEC 002S is not available from other sources.
Description of Information Collection
The reporting panel for the FFIEC 002 includes all U.S. branches and agencies (including
their International Banking Facilities (IBFs))4 of foreign banks, whether federally licensed or
state chartered, insured or uninsured. The FFIEC 002 consists of a summary schedule of assets
and liabilities (Schedule RAL) and several supporting schedules. Each schedule requires
information on balances of the entire reporting branch or agency. On the schedules for cash
(Schedule A), loans (Schedule C), and deposits (Schedule E), separate details are reported on
balances of IBFs. Unlike the Call Reports for domestic banks and savings associations, the
FFIEC 002 collects no income data.
A separate FFIEC 002S must be completed by any U.S. branch or agency of a foreign
bank that manages or controls a banking branch of its parent bank in a foreign country. The
FFIEC 002S covers all of the foreign branch’s assets and liabilities, regardless of the currency in
which they are payable. The supplement also covers transactions with all entities, both related
and nonrelated, regardless of location. All due from/due to relationships with related institutions,
both depository and nondepository, are reported on a gross basis, that is, without netting due
from and due to data items against each other.
Respondent Panel
The FFIEC 002 panel comprises all U.S. branches and agencies (including their IBFs) of
foreign banks, whether federally licensed or state chartered, insured or uninsured. The
FFIEC 002S panel comprises any U.S. branch or agency of a foreign (non-U.S.) bank that
manages or controls a banking branch of its parent bank that is licensed outside the 50 states of
the United States or the District of Columbia.

4

An IBF is a set of asset and liability accounts, which are segregated on the books and records of the establishing
entity and which reflect international transactions. An IBF is established in accordance with the terms of the Federal
Reserve’s Regulation D and after appropriate notification to the Federal Reserve. The establishing entity may be a
U.S. depository institution, a U.S. office of an Edge or agreement corporation, or a U.S. branch or agency of a
foreign bank, pursuant to the Federal Reserve’s Regulations D and Q. An IBF is permitted to hold only certain assets
and liabilities. In general, IBF accounts are limited to non-U.S. residents of foreign countries, residents of Puerto
Rico and U.S. territories and possessions, other IBFs, and U.S. and non-U.S. offices of the establishing entity.

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Frequency and Time Schedule
The FFIEC 002 and FFIEC 002S are collected quarterly as of the last calendar day of
March, June, September, and December. U.S. branches and agencies of foreign banks must
submit the FFIEC 002 and FFIEC 002S to the Federal Reserve Bank in whose district the
reporting branch or agency is located within 30 calendar days following the report date. After
processing and editing respondent data, the Board sends the data to the FDIC and OCC for their
use in monitoring the U.S. activities of foreign banks under their supervision.
Proposed Revisions
In the September 2023 notice, the agencies proposed revisions to the FFIEC 002 related
to FASB’s ASU 2022-02. As proposed, institutions would have reported loan modifications to
borrowers experiencing financial difficulty for a minimum period of 12 months after
modification and until an institution performs a current, well documented credit evaluation to
support that the borrower is no longer experiencing financial difficulty, unless the loan is paid
off, charged-off, sold, or otherwise settled. This may have been for a period longer than financial
statement disclosures required by ASU 2022-02. ASU 2022-02 requires that for each period for
which a statement of income is presented, an entity shall disclose by class of financing
receivable, qualitative and quantitative information about receivable performance in the 12
months after a modification of a receivable made to a debtor experiencing financial difficulty.5
The comment period for the September 2023 notice ended on November 27, 2023. The
agencies received six comment letters on the September 2023 notice, four of which included
objections to the proposed length of time for which these modifications would be reported on the
Call Report.6 These commenters indicated that the divergence from GAAP financial statement
disclosure requirements in accordance with ASU 2022-02 would create additional costs,
complexity, and operational challenges without any substantial corresponding benefit to either
the institutions or the agencies. The agencies deferred action on the length of time for which
these modifications would be reported pending additional review of the proposal and the
commenters’ concerns. Current Call Report forms collect data on loan modifications to
borrowers experiencing financial difficulty and the instructions define the types of loan
modifications to be reported but do not prescribe a specific duration for reporting such
modifications.
The agencies have completed their evaluation of the comments received. The agencies
determined that consistency with the GAAP financial statement disclosure requirements under
ASU 2022-02 would provide sufficient supervisory data on loan modifications due to the
debtor’s financial difficulty. Therefore, the agencies will revise the FFIEC 002 instructions to
indicate that institutions should only report those loans that have been modified in the previous
12 months consistent with FASB ASC paragraph 310-10-50-42.
The agencies will revise the FFIEC 002 instructions for Schedule N, Past Due,
5

See FASB ASC paragraph 310-10-50-42.
Comments other than those related to the proposed length of time for which modifications would be reported have
been addressed by FFIEC and the agencies in a prior notice (89 FR 45046, May 22, 2024).
6

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Nonaccrual, and Restructured Loans, as applicable, to align reporting of loan modifications to
borrowers experiencing financial difficulty, as described in ASU 2022-02. Specifically, modified
loans reported in these items should meet the definition of loan modifications to borrowers
experiencing financial difficulty, as described in ASU 2022-02, and include only such
modifications which occurred in the previous 12 months.
Public Availability of Data
Aggregate data for all U.S. branches and agencies that file the FFIEC 002 are available
on the Board’s public website under the Data tab as Assets and Liabilities of U.S. Branches and
Agencies of Foreign Banks and are also used in developing flow of funds estimates and the
estimates published in the Federal Reserve weekly H.8 statistical release, Assets and Liabilities
of Commercial Banks in the United States. Aggregate data for the FFIEC 002S are available to
the public upon request.
Individual respondent data, excluding confidential information, are available to the public
from the National Technical Information Service in Springfield, Virginia, upon request. In
addition, individual respondent data are also available on the FFIEC public website at
https://www.ffiec.gov/NPW.
Legal Status
Section 11(a)(2) of the Federal Reserve Act (FRA) authorizes the Board to require
depository institutions to submit reports of their liabilities and assets as the Board may determine to
be necessary or desirable to enable the Board to discharge its responsibility to monitor and control
monetary and credit aggregates (12 U.S.C. § 248(a)(2)).7 Section 7(c)(2) of the IBA provides that
branches and agencies of foreign banks, other than federal branches and agencies, are subject to the
requirement in section 9(6) of the FRA (12 U.S.C. § 324) to file reports of condition with the
appropriate Federal Reserve Bank (12 U.S.C. § 3105(c)(2)). Section 7(c)(2) of the IBA provides
that federal branches and agencies of foreign banks are subject to the reporting requirements
contained in section 11(a) of the FRA “to the same extent and in the same manner as if the branch
or agency were a state member bank” (12 U.S.C. § 3105(c)(2)). In addition, section 4(b) of the
IBA authorizes the OCC to collect the same information from federal branches and agencies of
foreign banks (12 U.S.C. § 3102(b)). The Board, FDIC, and OCC also are authorized to collect
reports of condition from insured branches of foreign banks pursuant to section 7(a) of the Federal
Deposit Insurance Act (12 U.S.C. §§ 1817(a)(1) and (3)). The obligation to respond is mandatory.
The FFIEC 002 reports are made available to the public, except for Schedule M, “Due
from/Due to Related Institutions in the U.S. and in Foreign Countries,” and Schedule C,
“Loans,” Part I, Memorandum items 5.a and 5.b for eligible loan modifications under section
4013 of the 2020 Coronavirus Aid, Relief, and Economic Security Act, which are considered to
be confidential by the agencies. This confidential information is exempt from public disclosure
pursuant to the Freedom of Information Act (FOIA), under exemption 4 of the FOIA (12 U.S.C.
§ 552(b)(4)).This exemption applies to confidential commercial or financial information that is
7

This provision contemplates that the reports will be made either directly to the Board or to the Board through other
federal regulators (e.g., the FDIC or OCC), depending on the reporting institution’s charter type.

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both customarily and actually treated as private by its owner.8 In addition, if a respondent
believes that any of the public portions of its FFIEC 002 report would be exempt from disclosure
under exemption 4 of the FOIA, the respondent may request confidential treatment for such
information. The FFIEC 002 reports are made available in their entirety, including the
confidential portions, to state regulators.
The agencies treat the entire FFIEC 002S report as confidential. The information
contained in the report is exempt from public disclosure pursuant to the FOIA under
exemption 4, as confidential commercial or financial information that is both customarily and
actually treated as private by its owner. However, aggregate data from the FFIEC 002S report for
multiple respondents, which does not reveal the identity of any individual respondent, may be
released.
Consultation Outside the Agency
The Board coordinated and consulted with the FDIC and OCC in developing this revision
as part of the FFIEC approval process.
Public Comments
On September 28, 2023, the agencies, under the auspices of the FFIEC, published an
initial notice in the Federal Register (88 FR 66933) requesting public comment for 60 days on
the extension, with revision, of the FFIEC 002 and FFIEC 002S. The comment period for this
notice expired on November 27, 2023. The agencies received six comment letters on the
September 2023 notice, four of which included objections to the proposed length of time for
which these modifications would be reported on the Call Report. These commenters indicated
that the divergence from GAAP financial statement disclosure requirements in accordance with
ASU 2022-02 would create additional costs, complexity, and operational challenges without any
substantial corresponding benefit to either the institutions or the agencies. The agencies deferred
action on the length of time for which these modifications would be reported pending additional
review of the proposal and the commenters’ concerns. Current Call Report forms collect data on
loan modifications to borrowers experiencing financial difficulty and the instructions define the
types of loan modifications to be reported but do not prescribe a specific duration for reporting
such modifications.
The agencies have completed their evaluation of the comments received. The agencies
determined that consistency with the GAAP financial statement disclosure requirements under
ASU 2022-02 would provide sufficient supervisory data on loan modifications due to the
debtor’s financial difficulty. Therefore, the agencies will revise the FFIEC 002 instructions to
indicate that institutions should only report those loans that have been modified in the previous
12 months consistent with FASB ASC paragraph 310-10-50-42.
The agencies will revise the FFIEC 002 instructions for Schedule N, Past Due,
Nonaccrual, and Restructured Loans, as applicable, to align reporting of loan modifications to
borrowers experiencing financial difficulty, as described in ASU 2022-02. Specifically, modified
8

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

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loans reported in these items should meet the definition of loan modifications to borrowers
experiencing financial difficulty, as described in ASU 2022-02, and include only such
modifications which occurred in the previous 12 months. The proposed revisions to the
FFIEC 002 instructions are proposed to become effective with the December 31, 2025, report
date. On July 11, 2025, the agencies, under the auspices of the FFIEC, published a final notice in
the Federal Register (90 FR 31111) requesting public comment for 30 days on the extension,
with revision, of the FFIEC 002 and FFIEC 002S. The comment period for this notice expires on
August 11, 2025.
Estimate of Respondent Burden
As shown in the table below, the estimated annual burden for the FFIEC 002 and
FFIEC 002S is 18,490 hours, and would not change with the proposed revision. This burden
estimate accounts for all filers of the FFIEC 002 and FFIEC 002S, including those supervised by
the FDIC or OCC. These reporting requirements represent less than 1 percent of the Board’s total
paperwork burden.
FFIEC 002 and FFIEC 002S
FFIEC 002
FFIEC 002S

Estimated
number of
respondents9

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

183
18

4
4

24.67
6

18,058
432
18,490

Total

The estimated total annual cost to the public for the FFIEC 002 and FFIEC 002S is
$1,334,054, and would remain the same with the proposed revisions.10
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.

9

Of these respondents, 58 for the FFIEC 002 and 3 for the FFIEC 002S 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.
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 $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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Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 002 and FFIEC 002S is $296,300 per year. The Federal Reserve System collects and
processes the data for all three of the agencies.

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