FFIEC 002 and FFIEC 002S 18 Question Format OMB Supporting Statement

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)
1.

Explain the circumstances that make the collection of information necessary.

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 and 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 to determine 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 form and instructions are available
at the FFIEC’s public website at https://www.ffiec.gov/resources/reporting-forms.
2.

Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current 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.
3.

Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology.

All affected institutions must submit their completed reports electronically using the
Federal Reserve’s Reporting Central application.

3

89 FR 45046 (May 22, 2024).
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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4.

Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.

The data collected through the FFIEC 002 and FFIEC 002S are unique and cannot be
replaced by data already collected by the federal government.
5.

If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.

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.
6.

Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.

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). Less frequent
reporting would diminish the agencies’ capacity to carry out the supervisory and regulatory
responsibilities imposed by the IBA.
7.

Explain any special circumstances that would cause an information collection to be
conducted in a manner inconsistent with 5 CFR 1320.5(d)(2).

This information collection is conducted in a manner consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Describe comments in response to the Federal Register notice and efforts to consult
outside the agency.

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

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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
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.
9.

Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There are no payments or gifts provided to respondents.

10.

Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy. If the collection requires a
systems of records notice (SORN) or privacy impact assessment (PIA), those should
be cited and described here.

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
both customarily and actually treated as private by its owner.5 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.
5

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

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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.
11.

Provide additional justification for any questions of a sensitive nature.
There are no questions of a sensitive nature.

12.

Provide estimates of the annual hourly burden of the collection of information.

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
respondents

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.
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/.
13.

Provide an estimate for the total annual cost burden to respondents or record
keepers resulting from the collection of information.
There are no annualized costs to the respondents.

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14.

Provide estimates of annualized costs to the Federal government.

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.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.

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.6
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.7 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
6

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).
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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.
16.

Provide information regarding plans for publication 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.
17.

If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
No such approval is sought.

18.

Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
There are no exceptions.

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