September 2025 SFOS Survey

INTERNAL FR/OFFICIAL USE // FRSONLY

Preface
The Board of Governors of the Federal Reserve System, under delegated authority from the Office of
Management and Budget (OMB), is conducting a Senior Financial Officer Survey (FR 2023; OMB No.
7100-0223) in collaboration with the Federal Reserve Bank of New York. Surveys conducted under FR
2023 have been used intermittently to obtain information about deposit pricing and behavior, bank
liability management, the provision of financial services, and reserve management strategies and
practices. Approval for this survey expires August 31, 2027.
The purpose of this survey is to systematically gather views from a number of depository institutions
(DIs) concerning their individual DI’s balance sheet and reserve management behavior. This information,
along with other data, will provide useful information for the Federal Reserve in monitoring and
interpreting developments in financial markets and the banking system as the level of reserve balances
in the banking system changes. The Federal Reserve System regards the information provided by each
respondent as confidential. A summary of aggregated survey results will be published.
Please respond by September 29, 2025, to the questions below. Your voluntary cooperation in
submitting this report is needed to make the results comprehensive, accurate, and timely. All answers
will be used solely for analytical, not supervisory, purposes. Your time and input are greatly appreciated.

Disclaimer
This survey is authorized under sections 2A, 12A, and 11 of the Federal Reserve Act (12 U.S.C. 225(a),
263, and 248(a)). The Federal Reserve may not conduct or sponsor, and an organization (or a person) is
not required to respond to, a collection of information unless it displays a currently valid OMB control
number.
The public reporting burden for this information collection is estimated to average three hours per
response, including time to gather and maintain data in the required form and to review instructions and
complete the information collection. Comments regarding this burden estimate or any other aspect of
this information collection, including suggestions for reducing the burden, may be sent to Secretary,
Board of Governors of the Federal Reserve System, 20th and C Streets, NW, Washington, DC 20551, and
to the Office of Management and Budget, Paperwork Reduction Project (7100-0223), Washington, DC
20503.

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Part 1: Balance Sheet Management
1) This question asks about changes to the projected level of different categories on your
institution’s balance sheet.1 For each of the categories listed, please indicate your institution’s
expectation about its most likely strategy between September 2025 and March 2026.
I expect my institution to: (select one; please select “N/A” only if your institution does not or
cannot have the asset or liability on its balance sheet)
a)
b)
c)
d)
e)

Take actions intended to decrease, or limit the growth in, the size of this item
Take actions intended to maintain the current size of this item
Take actions intended to increase, or limit the decline in, the size of this item
Not take actions to affect the size of this item
N/A

Balance Sheet Item
Liabilities
i. Term wholesale funding (brokered deposits, term repo, term CP/CD)
ii. Overnight wholesale funding (fed funds, on repo, overnight CP/CD)
iii. FHLB advances
Assets
iv. Reserves
v. Level 1 HQLA securities
vi. Level 2 HQLA securities
vii. Loans

Strategy

2) Looking ahead to March 2026, please select the rationale that most closely aligns with your
institution’s deposit rate-setting strategy for each of the deposit types listed. (select one)
a) Rates will be set to increase deposit balances.
b) Rates will be set to maintain deposit balances.
c) Rates will be set to decrease deposit balances.
Deposit type

Strategy

i. Retail deposits (excluding brokered retail deposits/ brokered retail CDs)
ii. Brokered retail deposits/brokered retail CDs
iii. Wholesale operational deposits
iv. Wholesale nonoperational deposits
3) [Gated for all FBOs] Please rate on a scale of 1 (not important or not applicable) to 5 (very
important) the factors driving net borrowing from your parent organization over the last year?

1

Please refer to Regulation WW for HQLA definitions, which is available at
https://www.ecfr.gov/current/title-12/chapter-II/subchapter-A/part-249/subpart-C.
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Factors

Rating

I. Cross-currency basis spreads
II. Nominal interest rate differentials between jurisdictions
III. Domestic branch customer activity/funding needs
IV. Head office or other affiliate customer activity
V. Market volatility/stress
VI. Supervisory guidance
VII. Other [please explain]
[Comment box]
4) Which statement best characterizes your institution’s reserve management strategy over the
past few months? (select one)
I. My institution has taken actions intended to decrease, or limit the growth in, the amount of
its reserves.
II. My institution has taken actions intended to maintain the current amount of its reserves.
III. My institution has taken actions intended to increase, or limit the decline in, the amount of
its reserves.
IV. My institution has taken limited or no actions intended to affect the amount of its reserves.
5) Aggregate reserves have declined from $3.26 trillion to $[to be updated on 9/18/2025] between
the start of July and mid-September. Moreover, the results of the July 2025 Survey of Market
Expectations showed median dealer expectations for the average level of reserves to decline by
$205 billion between 2025 Q3 and 2025 Q4.
A) Has your institution adjusted its reserves or liquidity management strategy in response to the
recent and expected future decline in aggregate reserves or in anticipation of potentially
higher funding costs? (select one)
I. Yes
II. No
III. No, but my institution’s reserves and liquidity management strategy has been discussed
more frequently with management in light of these developments
B) [Gated if respondent answered “I” to part 5A] Which, if any, of the following actions has your
institution pursued as part of the adjustments to its reserves or liquidity management strategy
referenced in part A of this question? Please only specify changes that your institution in the
past few months has taken in response to the declining trend in aggregate reserves.
My institution has: (select all that apply)
I.
II.
III.
IV.
V.

Increased its reserve holdings on a sustained basis
Increased its reserve holdings only ahead of high payment flow days
Increased its holdings of non-reserve HQLA securities
Increased its readiness to use contingent funding sources or considered adding new sources
Increased the amount of collateral it has positioned at either FHLBs or the discount window

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VI.

Decreased reserves by reducing arbitrage activity that had been conducted to earn a spread
between different money market rates
VII. Decreased reserves by lending in money markets at attractive rates
VIII. Other (please elaborate in comment box)
[comment box]

Part 2: Preferred Reserve Levels
Questions in Part 2 ask about your institution’s lowest comfortable level of reserves (LCLOR) – the lowest
dollar level of reserve balances your institution would feel comfortable holding before it began taking
active steps to maintain or increase its reserve balances. “Active steps” could include, but are not limited
to, borrowing in the federal funds or other wholesale funding markets or bidding more aggressively in
those markets, reducing holdings of other liquid assets, or raising deposit rates.
6) Given the constellation of short-term interest rates relative to the interest on reserve balances
(IORB) rate over the past month, what is the estimated LCLOR (in $ millions) your institution
would feel comfortable holding before it “takes active steps” to maintain or increase its
reserve balance position?
Estimated LCLOR ($ millions)

7) Given the constellation of short-term interest rates relative to IORB over the past month, if your
institution prefers to hold additional reserves above its LCLOR, please provide an estimated
amount of preferred additional reserves (in $ millions). If your institution does not prefer to hold
additional reserves above its LCLOR, please enter “0.”
Estimated preferred additional
reserves ($ millions)

8) [Gated for institutions with 10% change in LCLOR and/or buffer relative to March 2025] Please
rate on a scale of 1 (not important) to 5 (very important) the factors that affected the change in
your institution’s LCLOR and/or preferred additional reserves level since March 2025. (Please
select “N/A” only if the factor does not apply to your institution.)

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Factors driving change

Rating
LCLOR Additional
(A)
reserves
(B)

Changes in liquidity outflow assumptions
a. Changes in liability outflow assumptions
b. Changes in assumptions for routine intraday payment or settlement needs
Changes to monetization
c. Changes in capacity to access liquidity in the market (or via FHLB advances)
d. Changes in capacity to access liquidity through Federal Reserve facilities like
the standing repo facility (SRF) or discount window
Changes in balance sheet composition
e. Changes in balance sheet composition
f. Changes in composition or level of off-balance-sheet exposures
g. Changes to balance sheet interest rate risk / duration of equity
Other considerations
h. Changes to broader market conditions (for example, level of volatility or
stress)
i. Changes in the relative rate of return between reserves and other assets
j. Changes to aggregate banking system reserve levels
9) [Gated: question only appears to banks with surplus reserves (as defined as holding, on average,
10% more reserves than reported LCLOR + preferred additional reserves)] Your institution’s
average daily reserve balances over the past few months have been higher than the sum of the
LCLOR plus preferred additional reserves as reported in questions [6] and [7].
Please rate on a scale of 1 (not important or not applicable) to 5 (very important) the factors that
have resulted in your institution holding reserves above its LCLOR plus preferred additional
reserves.

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Factors

Rating

I. Relative or risk-adjusted rate of return between interest on reserves and
other HQLA
II. Spread between interest on reserves and overnight borrowings
III. Low duration of reserves
IV. Differential in foreign exchange/cross-currency basis resulting in a preference
for holding dollar reserves
V. Higher-than-expected uncertainty in your institution’s deposit base
VI. Elevated economic uncertainty or market volatility
VII. Anticipation of an acceleration in future loan growth/capital markets activity
VIII. [For FBOs only] Changes in your net due to/net due from position vis-à-vis
your parent organization (intended for foreign banking organizations)
IX. Other (please use the comment box)
[comment box]

10) For each hypothetical change in the level of overnight interest rates relative to the interest rate
on reserve balances (IORB) shown in the first column of the following table in basis points,
please provide an approximate forecast of your institution’s reserve balance in $ millions.
Relative to IORB, the constellation of overnight interest rates
is:
At the same level as it was over the past month

Approximate level of reserve
balance ($ millions):
[import institution’s recent
reserve level]

I. 4 basis points higher than it was over the past month
II. 8 basis points higher than it was over the past month
III. 12 basis points higher than it was over the past month
IV. 16 basis points higher than it was over the past month

11) Assume you are considering re-allocating a portion of your institution’s reserves into Treasury
securities and relative or risk-adjusted rate of return is your only consideration for making this
re-allocation.
A) Do you expect that your institution would re-allocate reserves and invest in Treasury securities
on either a hedged (e.g. asset swap) or unhedged basis? If you would expect to do both,
please select the one that is most likely. (select one)
i. Hedged
ii. Unhedged
B) [Gated for those that selected “i. hedged”] For each of the following hypothetical Secured
Overnight Financing Rate (SOFR) swap spreads, please estimate the amount of reserves you

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would be willing to re-allocate and invest in Treasury securities. (Note: highlighted values in
parentheses will be updated closer to survey distribution.)
The 2-year SOFR swap spread (UST yield –
SOFR swap) is:
I. Near current levels (-16 bps)

Approximate level of reserve balance reallocated to Treasury securities ($ millions):
[greyed out]

II. 8 bps lower than current levels (-24 bps)
III. 16 bps lower than current levels (-32 bps)
The 5-year SOFR swap spread (UST yield –
SOFR swap) is:
I. Near current levels (-29 bps)
II. 5 bps lower than current levels (-34 bps)

Approximate level of reserve balance reallocated to Treasury securities ($ millions):
[greyed out]

III. 10 bps lower than current levels (-39 bps)
C) [Gated for those that selected “ii. Unhedged”] For each of the following hypothetical spreads
between nominal Treasury yields and IORB, please estimate the amount of reserves you would
be willing to re-allocate and invest in Treasury securities. (Note: highlighted values in
parentheses will be updated closer to survey distribution.)
The 2-year spread (UST yield – IORB) is:
Approximate level of reserve balance reallocated to Treasury securities ($ millions):
I. Near current levels (-68 bps)
[greyed out]
II. Near 25 bps
III. Near 50bps
The 5-year spread (UST yield – IORB) is:
I. Near current levels (-61 bps)
II. Near 50 bps
III. Near 100 bps

Approximate level of reserve balance reallocated to Treasury securities ($ millions):
[greyed out]

D) Please describe any assumptions behind your responses to parts B and/or C.
[comment box]
12) This question asks about your institution’s activity in secured funding markets (repo markets).
A) Is your institution an active lender in repo markets? For the purposes of this question,
consider an active lender as an institution that lends for non-test purposes at least once a
month. (select one)
i.
Yes. My institution has been an active lender in repo markets.
ii.

No. While my institution currently has the operational capacity to lend in repo
markets, it has not done so in recent months.

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iii.

No. My institution currently does not have the operational capacity to lend in
repo markets and has not been an active lender.

B) [Gated for those who answer either i or ii to part A of this question] Please rate on a scale of
1 (not important or not applicable ) to 5 (very important) the following non-price factors that
drive your institution’s decision-making around lending in repo on quarter-end.
i. Leverage capital constraints
ii. Risk-based capital constraints
iii. Internal risk management guidelines/limits (excluding those related to i and ii)
iv. My institution’s reserve levels
v. Counterparty relationship management
vi. Other
[comment box]
C) [Gated for those who answer either i or ii to part A of this question] Under each of the
scenarios outlined in the table below, what is the smallest spread above the IORB rate in the
cleared and uncleared repo segments at which your institution would (actively consider)
lending? Please consider lending activity through an affiliated dealer and/or lending directly
to a client.
For this question, please assume your institution’s reserves balances are greater than the
amount you reported in Questions 6 and 7 and that you would receive Treasury securities as
collateral. If under no circumstances you would be willing to lend or if you do not have
capacity to transact in either or both repo market segments, please type “N/A”.
Scenario

Cleared repo
(basis points)

Uncleared repo
(basis points)

Quarter-end date
Non quarter-end date

Part 3: Federal Reserve Liquidity
13) A) Do you include the discount window in your monetization assumptions when your institution
stress tests your liquidity position against potential outflows? (Select one: Yes/no)
B) [gated for those who say “yes” to 13A ] Does your institution’s monetization assumptions for
the discount window affect your estimated LCLOR plus preferred additional level of reserves?
(Select one: Yes/no)
C) [gated for those who say “yes” to 13B] Please estimate your institution’s LCLOR and preferred
additional level of reserves given the following scenarios.

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Scenario

i.

i. baseline
ii. your institution assumes no monetization
related to the discount window
iii. your institution’s monetization assumptions
related to the discount window double

Estimated LCLOR plus
preferred additional
reserves ($ millions)
[pipe in from Q6+Q7]

D) Please provide any comments on this topic you would like to share, including whether there
are any other ways outside of your monetization assumptions in which the discount window
affects your LCLOR and/or preferred reserve level. [comment box]
14) [Gated for SRF counterparties] A) Do you include the standing repo facility (SRF) in your
monetization assumptions when your institution stress tests your liquidity position against
potential outflows? (Select one: Yes/no)
B) [gated for those who say “yes” to A ] Does your institution’s monetization assumptions for the
SRF affect your estimated LCLOR plus preferred additional level of reserves? (Select one:
Yes/no)
C) [gated for those who say “yes” to 14B] Please estimate your institution’s LCLOR and preferred
additional level of reserves given the following scenarios.
Scenario

i. baseline
ii. your institution assumes no monetization
related to the SRF
iii. your institution’s monetization
assumptions related to the SRF double

Estimated LCLOR plus
preferred additional
reserves ($ millions)
[pipe in from Q6+Q7]

D) Please provide any comments on this topic you would like to share, including whether there
are any other ways outside of your monetization assumptions in which the SRF affects your
LCLOR plus preferred additional reserve level. [comment box]
15) A) Which of the following private sector liquidity sources would your institution be most likely to
use to meet an overnight funding need? (select one)
i. overnight FHLB advance
ii. Treasury repo
iii. fed funds
B) At what spread between [above option] and the primary credit rate would your bank be
indifferent between borrowing from the discount window and from that funding source? (If
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applicable, please provide the spread between the effective FHLB rate that your institution
would be charged (i.e. the dividend adjusted rate) and the primary credit rate.)
Spread (basis points)

Part 4: Stablecoins and Digital Assets
16) For each of the stablecoin and digital asset related products and services listed in the table
below, please select the statement that best characterizes your institution’s current expectations
about its prioritization of growth and development in that area over the next three years.
My institution: (select one)
i. Does not intend to prioritize growth and development
ii. Views growth and development in this area to be a low priority
iii. Views growth and development in this area to be a medium priority
iv. Views growth and development in this area to be a high priority
v. Other
Products and services
a. Issuing its own stablecoin

Option

b. Issuing tokenized deposits
c. Holding reserve assets for other stablecoin issuers
d. Providing retail custodial/wallet services for stablecoins
or other crypto assets issued by other entities
e. Other (please describe in comment box)
[comment box]
17) This question asks about how your institution’s and the broader industry’s development of
stablecoin or digital asset-related products and services, as listed in Question [16], may impact
your institution over the next three years. Please rate the below items on a scale of -2 (I expect
a significant decrease) to +2 (I expect a significant increase). Please select “unsure” if you do not
know, have no opinion, or view the item as not applicable to your institution.
i.
ii.
iii.
iv.
v.
vi.
vii.
viii.
ix.

Payment activity during hours when the Fedwire Funds Service is not operating
Volume of your institution’s payment flows over the Fedwire Funds Service
Settlement speed of your institution’s money market transactions
Predictability of your institution’s payments flows over the Fedwire Funds Service
Funding cost of your institution’s liabilities
Outflow rates associated with your institution’s deposits
Level of deposits at your institution
Level of your institution’s reserves holdings
Duration of your institution’s HQLA
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18) If there is any other information relevant to your institution’s approach to stablecoin-related
products and services and digital assets that you would like to provide, please do so in the
comment box.
[comment box]

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