Supporting Statement A

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06-11-2026
Supporting Statement for the
Financial Statements for Holding Companies
(FR Y-9; OMB No. 7100-0128)
Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio
Standards for U.S. Global Systemically Important Bank Holding Companies and Their
Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt
Requirements for U.S. Global Systemically Important Bank Holding Companies
(Docket No. R-1867) (RIN 7100-AG96)
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 Financial Statements for Holding Companies (FR Y-9; OMB No. 7100-0128). This
information collection comprises the following five reports:
• Consolidated Financial Statements for Holding Companies (FR Y-9C),
• Parent Company Only Financial Statements for Large Holding Companies (FR Y-9LP),
• Parent Company Only Financial Statements for Small Holding Companies (FR Y-9SP),
• Financial Statements for Employee Stock Ownership Plan Holding Companies
(FR Y-9ES), and
• Supplement to the Consolidated Financial Statements for Holding Companies
(FR Y-9CS).
The Board requires bank holding companies (BHCs), most savings and loan holding
companies (SLHCs), securities holding companies, and U.S. intermediate holding companies
(IHCs) (collectively, HCs) to provide standardized financial statements through one or more of
the FR Y-9 reports.1 The information collected on the FR Y-9 reports is necessary for the Board
to identify emerging financial risks and monitor the safety and soundness of HC operations.
The Board, Federal Deposit Insurance Corporation (FDIC), and Office of the Comptroller
of the Currency (OCC) (collectively, the agencies) adopted a final rule2 to modify the enhanced
supplementary leverage ratio (eSLR) standards applicable to U.S. BHCs identified as global
systemically important bank holding companies (GSIBs), their subsidiary depository institutions
that are Board- or FDIC-regulated, and national banks and Federal savings associations that are
subsidiaries of a U.S. top-tier bank holding company with total consolidated assets of more than
$700 billion or assets under custody of more than $10 trillion (together with Board- and FDICregulated subsidiary depository institutions of GSIBs, covered depository institutions). These
modifications are intended to help ensure that the enhanced supplementary leverage ratio
standards serve as a backstop to risk-based capital requirements rather than a frequently binding
1

The following SLHCs are exempt: (1) a unitary savings and loan holding company with primarily commercial
assets that meets the requirements of section 10(c)(9)(c) of the Home Owners’ Loan Act (HOLA), for which thrifts
make up less than 5 percent of its consolidated assets and (2) an SLHC that primarily holds insurance-related assets
and does not otherwise submit financial reports with the Securities and Exchange Commission pursuant to sections
13 or 15(d) of the Securities Exchange Act of 1934.
2
See 90 FR 55248 (December 1, 2025).

constraint, thus reducing potential disincentives for GSIBs and covered depository institutions to
participate in low-risk, low-return activities. The Board also finalized conforming amendments
to its total loss-absorbing capacity and long-term debt requirements. In addition, the Board made
conforming amendments to the FR Y-9C instructions, and the Board and FDIC made final
certain technical corrections to the capital rule and the prompt corrective action framework. The
final rule is effective April 1, 2026. Banking organizations subject to the final rule may elect to
early adopt the final rule as of January 1, 2026. The revisions to the FR Y-9C instructions will
become effective with the first report date following the effective date of the final rule.
Consistent with the final rule, if a holding company elects to adopt the modified eSLR standard
as of January 1, 2026, such holding company should elect early adoption for the March 31, 2026,
reporting as of date.
The current estimated total annual burden for the FR Y-9 is 115,283 hours, and would
remain unchanged with the revisions. The FR Y-9 forms and instructions are available on the
Board’s public website at https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
The FR Y-9 reports are the Board’s primary source of financial data from HCs. Federal
Reserve System examiners rely on the FR Y-9 reports to supervise HCs between on-site
inspections. The Board uses the collected data to detect emerging financial problems, conduct
pre-inspection analysis, monitor and evaluate capital adequacy, evaluate mergers and
acquisitions, and analyze an HC’s overall financial condition to monitor the safety and soundness
of its operations. The information collected by the FR Y-9 reports is not available from other
sources.
Description of Information Collection
The FR Y-9C consists of standardized financial statements for HCs similar to the
Call Reports filed by commercial banks. The FR Y-9C collects consolidated data and is filed
quarterly by top-tier HCs with total consolidated assets of $3 billion or more.3
The FR Y-9LP, which collects parent company only financial data, must be submitted
quarterly by each HC that files the FR Y-9C, as well as by each of its subsidiary HCs.4 The
report consists of standardized financial statements, including the following schedules: Income
Statement, Cash Flow Statement, Balance Sheet, Investments in Subsidiaries and Associated
Companies, Memoranda, and Notes to the Parent Company Only Financial Statements.
The FR Y-9SP is a parent company only financial statement filed semiannually by HCs
with total consolidated assets of less than $3 billion. In a banking organization with total
consolidated assets of less than $3 billion that has tiered HCs, each HC in the organization must
submit, or have the top-tier HC submit on its behalf, a separate FR Y-9SP. This report collects
basic balance sheet and income data for the parent company, as well as data on its intangible
3

Under certain circumstances described in the FR Y-9C’s General Instructions, HCs with assets under $3 billion
may be required to file the FR Y-9C.
4
A top-tier HC may submit a separate FR Y-9LP on behalf of each of its lower-tier HCs.

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assets and intercompany transactions.
The FR Y-9ES is filed annually by each employee stock ownership plan (ESOP) that is
also an HC. The report collects financial data on the ESOP’s benefit plan activities. The
FR Y-9ES consists of four schedules: Statement of Changes in Net Assets Available for
Benefits, Statement of Net Assets Available for Benefits, Memoranda, and Notes to the Financial
Statements.
The instructions to each of the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES state that
respondent HCs should retain workpapers and other records used in the preparation of the reports
for a period of three years following submission. In addition, HCs must maintain in their files a
manually signed and attested printout of the data submitted under each form for a period of three
years.
The FR Y-9CS is a voluntary, free-form supplemental report that the Board may utilize to
collect critical additional data deemed to be needed from HCs in an expedited manner. The
FR Y-9CS data collections are used to assess and monitor emerging issues related to HCs, and
the report is intended to supplement the other FR Y-9 reports. The data requested by the
FR Y-9CS would depend on the Board’s data needs in any given situation. For example, changes
made by the Financial Accounting Standards Board (FASB) may introduce into generally
accepted accounting principles (GAAP) new data items that are not currently collected by the
other FR Y-9 reports. The Board could use the FR Y-9CS report to collect these data until the
items are implemented into the other FR Y-9 reports.5
Respondent Panel
The FR Y-9 panel comprises HCs. Specifically, the FR Y-9C panel comprises top-tier
HCs with total consolidated assets of $3 billion or more; the FR Y-9LP panel comprises of each
HC that files the FR Y-9C, as well as each of its subsidiary HCs; the FR Y-9SP panel comprises
HCs with total consolidated assets of less than $3 billion;6 the FR Y-9ES panel comprises each
ESOP that is also an HC; and the FR Y-9CS panel comprises any HC the Board selects.7 Most
small HCs file the streamlined parent only FR Y-9SP report semiannually.

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The FR Y-9CS was most recently used by the Board on June 30, 2008. In that collection, data were requested from
banking organizations implementing an Advanced Measurement Approach to calculate operational risk capital
under the Basel II Risk-Based Capital Framework. The report was used to conduct a voluntary Loss Data Collection
Exercise relating to operational risk.
6
The following HCs do not have to file HC financial statements under the FR Y-9C, FR Y-9LP, and FR Y-9SP: (1)
HCs that have been granted an exemption under section 4(d) of the Bank Holding Company Act of 1956 and (2) a
“qualified foreign banking organization” as defined by section 211.23(a) of Regulation K (12 CFR 211.23(a)) that
controls a U.S. subsidiary bank.
7
The Reserve Bank with whom a reporting HC files its reports may require that an HC with total consolidated assets
of less than $3 billion submit the FR Y-9C and the FR Y-9LP reports to meet supervisory needs. In addition, any
HC that is not subject to the Federal Reserve’s Capital Adequacy Guidelines, but nonetheless elects to comply with
the guidelines, is required to file a complete FR Y-9C and FR Y-9LP report, and generally would not be permitted to
revert to filing the FR Y-9SP report in any subsequent periods. See footnote 2 of the general instructions for the
FR Y-9C for more information.

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Frequency and Time Schedule
The FR Y-9C and FR Y-9LP are filed quarterly as of the last calendar day of March,
June, September, and December. The filing deadline for the FR Y-9C is 40 calendar days after
the March 31, June 30, and September 30 as of dates and 45 calendar days after the December 31
as of date. The filing deadline for the FR Y-9LP is 45 calendar days after the quarter-end as of
date. The FR Y-9SP is filed semiannually as of the last calendar day of June and December, and
the filing deadline is 45 calendar days after the as of date. The annual FR Y-9ES is collected as
of December 31, and the filing deadline is July 31 of the following year, unless an extension to
file by October 15 is granted. Respondents will be notified of the filing deadline for the
FR Y-9CS if it is utilized by the Board.
If the above submission deadlines for the FR Y-9C, FR Y-9LP, FR Y-9SP, and
FR Y-9ES fall on a weekend or holiday, the reports must be received on the first business day
after the Saturday, Sunday, or holiday. The reports are due by the end of the reporting day on the
submission date (i.e., 5:00 P.M. at each of the Reserve Banks).
Revisions to the FR Y-9C
The Board revised the FR Y-9C, Schedule HC-R, Part I, Regulatory Capital Components
and Ratios, to calibrate supplementary leverage ratio requirements. Specifically, the instructions
for Schedule HC-R, Part I, line item 64, “Leverage buffer requirement (if applicable),” will be
updated to reflect the change to the leverage buffer requirement to an amount equal to 50 percent
of a holding company’s most recent method 1 surcharge, calculated in accordance with the
capital rule. Additionally, the instructions for Schedule HC-R, Part I, line item 62(b), “TLAC
leverage buffer,” will be amended in accordance with the revisions to the Board’s TLAC
framework to replace the two percent TLAC leverage buffer with a buffer equal to the enhanced
supplementary leverage ratio buffer under the capital rule as well as an additional revision to
update the instructions to be consistent with the TLAC framework. The revisions to the FR Y-9C
instructions will become effective with the first report date following the effective date of the
final rule. Consistent with the final rule, if a holding company elects to adopt the modified eSLR
standard as of January 1, 2026, such holding company should elect early adoption for the March
31, 2026, reporting as of date.
Public Availability of Data
Data from the FR Y-9 reports that are not granted confidential treatment as described
below are publicly available on the FFIEC website: https://www.ffiec.gov/NPW.
Legal Status
The reporting and recordkeeping requirements associated with the FR Y-9 are authorized
for BHCs pursuant to section 5 of the Bank Holding Company Act of 1956 (BHC Act)
(12 U.S.C. § 1844); for SLHCs pursuant to section 10(b)(2) and (3) of the HOLA (12 U.S.C. §§
1467a(b)(2) and (3)); for IHCs pursuant to section 5 of the BHC Act, as well as pursuant to
sections 102(a)(1) and 165 of the Dodd-Frank Wall Street and Consumer Protection Act (Dodd-

4

Frank Act) (12 U.S.C. §§ 5311(a)(1) and 5365);8 and for securities holding companies pursuant
to section 618 of the Dodd-Frank Act (12 U.S.C. § 1850a(c)(1)(A)). Except for the FR Y-9CS
report, which is collected on a voluntary basis, the obligation to submit the remaining reports in
the FR Y-9 series of reports and to comply with the recordkeeping requirements set forth in the
respective instructions to each of the other reports is mandatory.
Certain information collected on the FR Y-9C and FR Y-9SP reports is kept confidential
by the Board. The following items are kept confidential under exemption 4 of the Freedom of
Information Act (FOIA) because these data items reflect commercial and financial information
that is both customarily and actually treated as private by the respondent (12 U.S.C. § 552(b)(4)):
• FR Y-9C, Schedule HI, memoranda item 7(g), FDIC deposit insurance assessments,
• FR Y-9C, Schedule HC-P, item 7(a) Representation and warranty reserves for 1-4 family
residential mortgage loans sold to U.S. government agencies and government sponsored
agencies,
• FR Y-9C, Schedule HC-P, item 7(b) Representation and warranty reserves for 1-4 family
residential mortgage loans sold to other parties,
• FR Y-9C, Schedule HC-C, Part I, memorandum items 16.a and 16.b, for eligible loan
modifications under Section 4013 of the 2020 Coronavirus Aid, Relief, and Economic
Security Act, and
• FR Y-9C, Schedule HC and FR Y-9SP, Schedule SC, Memoranda item 2.b, the name and
email address of the external auditing firm’s engagement partner.9
In some circumstances, disclosing these data items may also reveal confidential
examination and supervisory information protected from disclosure under exemption 8 of the
FOIA (12 U.S.C. § 552(b)(8)). The Board has previously assured submitters that these data items
will be treated as confidential.
In addition, the Chief Executive Officer Contact Information section of both the FR Y-9C
and FR Y-9SP is kept confidential pursuant to FOIA exemption 6, which applies to personnel
and medical files the disclosure of which would constitute a clearly unwarranted invasion of
personal privacy (5 U.S.C. § 552(b)(6)), and exemption 8, which applies to 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
(5 U.S.C. § 552(b)(8)).
8

Section 165(b)(2) of Title I of the Dodd-Frank Act (12 U.S.C. § 5365(b)(2)), refers to “foreign-based bank holding
company.” Section 102(a)(1) of the Dodd-Frank Act (12 U.S.C. § 5311(a)(1)), defines “bank holding company” for
purposes of Title I of the Dodd-Frank Act to include foreign banking organizations that are treated as bank holding
companies under section 8(a) of the International Banking Act of 1978 (12 U.S.C. § 3106(a)). The Board has
required, pursuant to section 165(b)(1)(B)(iv) of the Dodd-Frank Act (12 U.S.C. § 5365(b)(1)(B)(iv)), certain
foreign banking organizations subject to section 165 of the Dodd-Frank Act to form U.S. intermediate holding
companies. Accordingly, the parent foreign-based organization of a U.S. IHC is treated as a BHC for purposes of the
BHC Act and section 165 of the Dodd-Frank Act. Because section 5(c) of the BHC Act authorizes the Board to
require reports from subsidiaries of BHCs, section 5(c) provides additional authority to require U.S. IHCs to report
the information contained in the FR Y-9.
9
The Board has assured respondents that this information will be treated as confidential since the collection of this
data item was proposed in 2004, under the assumption that the identity of the engagement partner is treated as
private information by HCs.

5

Aside from the data items described above, data collected by the FR Y-9 reports
generally are not accorded confidential treatment. However, as provided in the Board’s Rules
Regarding Availability of Information,10 a respondent may request confidential treatment for any
data items the respondent believes should be withheld pursuant to a FOIA exemption. The Board
will review any such request to determine if confidential treatment is appropriate and will inform
the respondent if the request for confidential treatment has been granted or denied.
To the extent that the instructions to the FR Y-9 reports direct the financial institution to
retain the workpapers and related materials used in preparation of each report, such material
would only be obtained by the Board as part of the examination or supervision of the financial
institution. Accordingly, such information is considered confidential pursuant to exemption 8 of
the FOIA (5 U.S.C. § 552(b)(8)). In addition, the workpapers and related materials may also be
protected by exemption 4 of the FOIA, to the extent such financial information is customarily
and actually treated as private by the respondent (5 U.S.C. § 552(b)(4)).
Consultation Outside the Agency
The Board consulted with the FDIC and OCC regarding the revisions to the FR Y-9.
Public Comments
On July 10, 2025, the agencies published a notice of proposed rulemaking in the Federal
Register (90 FR 30780) requesting public comment on the extension, with revision, of the
FR Y-9. The comment period for this notice expired on August 24, 2025. The agencies did not
receive any specific comments on the Paperwork Reduction Act. The Board adopted the
extension, with revision, of the FR Y-9 as originally proposed. On December 1, 2025, the
agencies published a final rule in the Federal Register (90 FR 55248).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-9 is 115,283
hours, and would remain unchanged with the revisions. These reporting and recordkeeping
requirements represent approximately 1.5 percent of the Board’s total paperwork burden.

10

12 CFR Part 261.

6

FR Y-9
Reporting
FR Y-9C (non AA HCs)
with less than $5 billion in
total assets
FR Y-9C (non AA HCs)
with $5 billion or more in
total assets
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Recordkeeping
FR Y-9C
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS

Estimated
number of
respondents11

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

107

4

35.59

15,233

236
9
411

4
4
4

45.23
50.76
5.27

42,697
1,827
8,664

3,596
73
236

2
1
4

5.45
0.50
0.50

39,196
37
472

352
411
3,596
73
236

4
4
2
1
4

1.00
1.00
0.50
0.50
0.50

1,408
1,644
3,596
37
472
115,283

Total

The estimated total annual cost to the public for the FR Y-9 is $8,571,291, and would
remain unchanged with the revisions.12
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.

11

Of these respondents, 5 FR Y-9C (non AA HCs) with less than $5 billion in total assets filers; 212 FR Y-9LP
filers; 3,492 FR Y-9SP filers; and 73 FR Y-9ES filers 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. There are no accommodations given to mitigate
the burden on small entities. The respondent counts are as of December 31, 2021.
12
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 $25, 45% Financial
Managers at $90, 15% Lawyers at $89, and 10% Chief Executives at $130). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2025, published May 15, 2026, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

7

Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FR Y-9 reports is $1,922,400.

8