Supporting Statement A

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09-16-2026
Supporting Statement for the
Capital Assessments and Stress Testing Reports
(FR Y-14A/Q/M; OMB No. 7100-0341)
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 Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No.
7100-0341). These collections of information are applicable to top-tier U.S. bank holding
companies (BHCs), U.S. intermediate holding companies of foreign banking organizations
(IHCs), and covered savings and loan holding companies (SLHCs)1 (collectively, holding
companies) with $100 billion or more in total consolidated assets. The FR Y-14A, FR Y-14Q,
and FR Y-14M reports (FR Y-14 reports) are used to support and calibrate the supervisory stress
test models used in connection with setting firms’ stress capital buffer (SCB) requirements, as
well as to collect company-run stress test results. The data are also used to support the
supervision and regulation of these financial institutions.
The Board revised the FR Y-14 reports to implement various changes that collect more
granular information on lending to nondepository financial institutions (NDFIs), improve the
coverage of the Board’s collections of counterparty credit risk data, remove data fields deemed
no longer necessary, and make other minor revisions and instructional clarifications. The
revisions are effective for the December 31, 2026, as of date submission unless otherwise noted
below.
The current estimated total annual burden for the FR Y-14 reports is 761,839 hours, and
would increase to 774,828 hours with the revisions and the implementation cost associated with
the addition of two new firms to the FR Y-14 reporting panel since the FR Y-14 was last
updated. The implementation costs for the two new firms contribute 14,400 burden hours. The
form and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
Section 165(i)(1) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank Act)2 requires the Board to conduct an annual stress test of certain companies to
evaluate whether the company has sufficient capital, on a total consolidated basis, to absorb
losses as a result of adverse economic conditions (known as the supervisory stress test).3 Further,
section 165(i)(2) of the Dodd-Frank Act requires the Board to issue regulations requiring such
companies to conduct company-run stress tests.4 On May 24, 2018, the Economic Growth,
Regulatory Relief, and Consumer Protection Act (EGRRCPA) amended sections 165(i)(1) and
1

Covered SLHCs are those that are not substantially engaged in insurance or commercial activities. See 12 CFR
238.2(ff).
2
Pub. L. No. 111-203, 124 Stat. 1376 (2010).
3
12 U.S.C. § 5365(i)(1).
4
12 U.S.C. § 5365(i)(2).

(2) of the Dodd-Frank Act, among other changes.5 The Board’s rules implementing sections
165(i)(1) and (i)(2) of the Dodd-Frank Act, and section 401 of EGRRCPA, establish stress
testing requirements for certain BHCs, state member banks, SLHCs, foreign banking
organizations, and nonbank financial companies supervised by the Board.6
Additionally, the Board’s capital plan rule requires certain firms to submit capital plans to
the Board annually and requires such firms to request prior approval from the Board under
certain circumstances before making a capital distribution.7 In connection with submissions of
capital plans to the Board, firms are required, pursuant to 12 CFR 225.8(e)(3) and 12 CFR
238.170(e)(3), to provide information related to the firm’s financial condition, structure, assets,
risk exposure, policies and procedures, liquidity, and risk management, among others.
The FR Y-14 reports collect stress test and capital plan data from the largest holding
companies, which are those with $100 billion or more in total consolidated assets. The data
collected through the FR Y-14 reports provide the Board with the information needed to help
ensure that large holding companies have strong, firm‐wide risk measurement and management
processes supporting their internal assessments of capital adequacy and that their capital
resources are sufficient given their business focus, activities, and resulting risk exposures.
Information gathered in this data collection is also used in the supervision and regulation of these
financial institutions.
The FR Y-14 reports complement other Board supervisory efforts aimed at enhancing the
continued viability of large firms, including continuous monitoring of firms’ planning and
management of liquidity and funding resources, as well as regular assessments of credit, market,
and operational risks, and associated risk management practices.
Description of Information Collection
These collections of information are applicable to top-tier holding companies with total
consolidated assets of $100 billion or more. This family of information collections is composed
of the following three reports:
• The annual FR Y-14A, which collects quantitative projections of balance sheet, income,
losses, and capital across a range of macroeconomic scenarios, and qualitative
information on methodologies used to develop internal projections of capital across
scenarios.8
5

EGRRCPA requires “periodic” supervisory stress tests for bank holding companies with $100 billion or more, but
less than $250 billion, in total consolidated assets and amended section 165(i)(1) to require annual supervisory stress
tests for bank holding companies with $250 billion or more in total consolidated assets. EGRRCPA amended section
165(i)(2) to require bank holding companies with $250 billion or more in total consolidated assets, and financial
companies with more than $250 billion in total consolidated assets, to conduct their own “periodic” stress tests.
Finally, EGRRCPA amended both sections 165(i)(1) and (2) to no longer require the Board to include an “adverse”
scenario in company-run or supervisory stress tests, reducing the number of required stress test scenarios from three
to two.
6
See 12 CFR 252, Subparts B, E, F, and O.
7
See 12 CFR 225.8; 12 CFR 238.170.
8
In certain circumstances, a firm may be required to re-submit its capital plan. 12 CFR 225.8(e)(4); 12 CFR
238.170(e)(4). Firms that must re-submit their capital plan generally must also provide a revised FR Y-14A in
connection with their resubmission.

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•
•

The quarterly FR Y-14Q, which collects granular data on various asset classes, including
loans, securities, trading assets, and pre-provision net revenue (PPNR) for the reporting
period.
The monthly FR Y-14M, which comprises three retail portfolio- and loan-level
schedules, and one detailed address-matching schedule to supplement two of the
portfolio- and loan-level schedules.
FR Y-14A (annual collection)

The annual collection of quantitative projected regulatory capital ratios across various
macroeconomic scenarios comprises five primary schedules (Summary, Scenario, Regulatory
Capital Instruments, Operational Risk, and Business Plan Changes), each with multiple
supporting tables. The FR Y-14A schedules collect current financial information and projections
under the Board’s supervisory scenarios. The information includes balances for balance sheet
and off‐balance‐sheet positions, income statement and PPNR, and estimates of losses across
various portfolios. Firms are also required to submit qualitative information supporting their
projections, including descriptions of the methodologies used to develop the internal projections
of capital across scenarios and other analyses that support their comprehensive capital plans.9
FR Y-14Q (quarterly collection)
The FR Y-14Q schedules (Retail, Securities, Regulatory Capital Instruments, Regulatory
Capital, Operational Risk, Trading, PPNR, Wholesale Risk, Fair Value Option/Held for Sale,
Supplemental, Counterparty, and Balances) collect firm‐specific data on positions and exposures
that are used to support and calibrate the supervisory stress test models to monitor actual versus
forecast information on a quarterly basis and to conduct ongoing supervision.
FR Y-14M (monthly collection)
The FR Y-14M report includes two portfolio- and loan-level schedules for First Lien data
and Home Equity data, and an account- and portfolio-level schedule for Domestic Credit Card
data. To match senior and junior lien residential mortgages on the same collateral, the Address
Matching schedule gathers additional information on the residential mortgage loans reported in
the First Lien and Home Equity schedules.
Respondent Panel
The FR Y-14 panel comprises BHCs, SLHCs, and IHCs with $100 billion or more in
total consolidated assets, based on (1) the average of the firm’s total consolidated assets in the
four most recent quarters as reported quarterly on the firm’s Consolidated Financial Statements
for Holding Companies (FR Y-9C; OMB No. 7100-0128) or (2) the average of the firm’s total
consolidated assets in the most recent consecutive quarters as reported quarterly on the firm’s
FR Y-9Cs, if the firm has not filed an FR Y-9C for each of the most recent four quarters.

9

The Board has separately proposed to retire the collection of qualitative information on the FR Y-14A. See 90 FR
51856 (November 18, 2025).

3

Reporting is required as of the first day of the quarter immediately following the quarter in which
the respondent meets this asset threshold, unless otherwise directed by the Board.
Frequency and Time Schedule
The following tables outline, by schedule and reporting frequency (annually, quarterly, or
monthly), the as of dates for the data and the associated due dates for the current submissions to
the Board.
Schedules and
Sub-schedules

Summary,
Macro Scenario

Data as of Date

Submission Date
to Federal Reserve

FR Y-14A Filings
• Original Submission: Data are
due April 5th of the following
year.
• Adjusted summary schedule
submission: The Federal Reserve
will notify companies at least 14
Data as of
calendar days in advance of the
st
December 31 .
date on which it expects
companies to submit any adjusted
capital actions.

Operational Risk,
Business Plan Changes,
and Collection of
Supplemental CECL
Information schedules

Data as of
December 31st.

Market Shock exercises
Summary schedule
• Trading Risk
• Counterparty

Data as of a
specified date in the
first quarter. As of
date would be
communicated by
Federal Reserve.10

10

Upon resubmission of a firm’s capital
plan:
• As required.
• Original Submission: Data are
due April 5th of the following
year.
Upon resubmission of a firm’s capital
plan:
• As required.
• Original Submission: Data are
due April 5th.
Upon resubmission of a firm’s capital
plan:
• As required.

As outlined in section 252.54(b) of Regulation YY and section 238.143(b) of Regulation LL, the as of date will be
October 1 of the calendar year preceding the year of the stress test cycle to March 1 of the calendar year of the
stress test cycle and will be communicated to the BHCs and SLHCs by March 1st of the calendar year. BHCs and
SLHCs are permitted to submit the CCR schedule and the Trading and CCR sub-schedules of the Summary
schedule as of another recent reporting date prior to the supplied as of date, as appropriate.

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Regulatory Capital
Instruments

Data as of
December 31st.

•
•

•

Original submission: Data are due
April 5th of the following year.
Adjusted submission: The Federal
Reserve will notify companies at
least 14 calendar days in advance
of the date on which it expects
companies to submit any adjusted
capital actions.
Incremental submission: At the
time the firm seeks approval for
additional capital distributions
pursuant to 12 CFR 225.8(j) or
within 15 days after making any
capital distribution approved
pursuant to that section or a capital
distribution in excess of the firm’s
final planned capital distributions.

Upon resubmission of a firm’s capital
plan:
• As required.
Schedules

Firm Category

Data as of
Date

Submission Date
to Board

Quarter-end

Data are due seven
calendar days after the
FR Y-9C reporting
schedule (52 calendar
days after the calendar
quarter-end for
December and 47
calendar days after the
calendar quarter-end
for March, June, and
September).

Frequency
FR Y-14Q Filings

Retail,
Securities,
Regulatory
Capital
Instruments,
Regulatory
Capital,
Operational
Risk,
PPNR,
FVO/HFS,
Supplemental,
Wholesale
Risk,
and
Balances

All firms

Quarterly

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Trading
Counterparty

All firms

Quarterly

Fourth
Quarter:
GMS as of
date for all
exposures
except
Trading FVO
Loan Hedges,
which must
be reported as
of calendar
quarter-end.
All Other:
Quarter-end.

Fourth Quarter Trading and
Counterparty
regular/unstressed
submission: 52
calendar days after the
notification date
(notifying respondents
of the as of date) or
March 15, whichever
comes earlier.
Unless the Board
requires the data to
be provided over a
different weekly
period, BHCs,
SLHCs, and IHCs may
provide these data as
of the most recent date
that corresponds to
their weekly internal
risk reporting cycle as
long as it falls within
the same week as the
as of date.
Fourth quarter –
Counterparty stressed
GMS submission:
April 5th of the
following year.
All other: 47 calendar
days after the calendar
quarter-end (Seven
days after the
FR Y-9C reporting
schedule).
Upon resubmission of
a firm’s capital plan –
Counterparty stressed
GMS submission: as
required.

6

Schedules

All schedules

Data as of date

Submission Date
to Board

FR Y-14M (Monthly Filings)
The last business day
By the 30th calendar day of the
of each calendar
following month.
month.

Proposed Revisions to the FR Y-14
On June 21, 2024, the Board invited public comment on proposed revisions to the
FR Y-14A/Q/M reports that would have collected more granular information on lending to
nondepository financial institutions (NDFIs), improved the timeliness and coverage of the
Board’s collections of counterparty credit risk data, removed data fields deemed no longer
necessary, and made other minor revisions and instructional clarifications. All proposed
revisions would have been effective for the September 30, 2024, report date for the FR Y-14Q
and FR Y-14M, and for the December 31, 2024, report date for the FR Y-14A.
General
FR Y-14 Q&A System
Firms that report the FR Y-14 frequently have questions on the reporting requirements. In
order to promote the accuracy and consistency of the FR Y-14 reports, the Board developed a
Q&A system where firms could submit questions to receive clarification on reporting the
FR Y-14. Due to the volume of questions received and the detailed scenarios described in some
questions, the Board is limited in its ability to address all submitted questions, and firms
occasionally do not receive responses in a timely manner. Often, revisions to the FR Y-14
address outstanding questions or otherwise make previous questions no longer applicable.
Moreover, during the revision process, the public is provided the opportunity to comment on
various aspects of the FR Y-14 that are unclear. Therefore, unanswered questions that predate the
most recent FR Y-14 revisions may become obsolete.
In connection with the proposal, the Board encouraged the submission of comments
regarding any aspects of the FR Y-14 instructions that may be unclear. Upon receipt of public
comments following the proposal, the Board intended to answer relevant unaddressed questions
and retire unanswered questions in the system submitted prior to publication of the initial notice.
Firms would continue to have the opportunity to submit questions related to the FR Y-14 to the
Federal Reserve.
Supporting Documentation
Firms previously used Intralinks to submit supporting documentation for certain
FR Y-14A/Q/M schedules to the Board. Intralinks has been replaced by One Agile Supervision
Solution (OASiS) and firms were required to submit supporting documentation through OASiS

7

instead of Intralinks for the 2024 supervisory stress test. Therefore, the Board proposed to update
all references to Intralinks in the FR Y-14A/Q/M instructions to reflect the transition to OASiS.
Historical Data
New reporters of the FR Y-14 are currently required to provide historical reports of the
FR Y-14Q PPNR and Retail schedules, providing reports for all periods from first submissions
of the FR Y-14 back through March 2009 and January 2007, respectively. Firms began reporting
the FR Y-14 in 2012, and this historical data requirement enabled the Board to understand how a
firm’s Retail and PPNR schedules had performed in the years preceding the initial submissions
and to appropriately project its losses in the supervisory stress test. However, given the passage
of time, firm-level historical data from as far in the past as 2007 or 2009 is less relevant to
modeling a firm’s losses in the stress test. Additionally, firms that join the FR Y-14 panel may
face significant burdens to produce the required historical data. Therefore, the Board proposed to
modify this requirement in the FR Y-14Q instructions such that new reporters, or existing
reporters that must begin filing a Retail schedule, would have been required to provide historical
reports only for the five years preceding the first quarter that the firm is subject to reporting. This
change would have reduced reporting burden, aligned with the original spirit of the FR Y-14
historical reporting requirements, and made the reporting requirement consistent for all firms
regardless of when they begin reporting.
Exploratory Market Shocks
The supervisory stress test includes a global market shock (GMS) component that applies
to covered companies with substantial trading exposures and is calculated using a large set of
shocks to market risk factors.11 The losses associated with the GMS are included in a firm’s
losses under the severely adverse scenario, and consequently, generally feed into their ultimate
SCB requirement. Currently, the use of a single GMS limits the Board’s ability to capture and
test a firm’s resilience to a wider range of risks. To expand risk identification beyond the current
GMS framework, the Board proposed to revise the FR Y-14 instructions to require firms to
submit relevant data with respect to all market shocks that the Board may conduct in a given
year, including any exploratory market shocks.
Collection of Supplemental CECL Information
The FR Y-14A, “Collection of Supplemental CECL Information” is a one-time
submission required from firms that have adopted ASU 2016-13, which collects certain
information reflecting the current expected credit losses (CECL) methodology. This collection
was implemented to identify the effect and timing of the adoption of CECL and the associated
transition provisions, as provided by section 301 of the regulatory capital rules. As all firms have
now adopted ASU 2016-13, this supplemental collection is no longer needed for modeling or
analytic purposes. Therefore, the Board proposed to remove the “Collection of Supplemental
CECL Information” from the FR Y-14A.

11

See Board of Governors of the Federal Reserve System, 2023 Stress Test Scenarios (February 2023),
https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20230209a1.pdf.

8

Other Revisions
For Comprehensive Capital Analysis and Review (CCAR) submissions of FR Y-14A,
Schedule A (Summary), under both the internal stress scenario as well as the supervisory
severely adverse scenario, firms are currently instructed to report alternative capital actions,
which the firms would expect to take if the stress scenario were realized. Per the Board’s capital
rule, the maximum payout amount is a function of a firm’s eligible retained income and capital
ratios.12 However, upon the request of a Board-regulated institution, the Board may approve
additional distributions if it determines that the distribution would not be contrary to the purposes
of this capital rule, or to the safety and soundness of the Board-regulated institution.13 To
accurately monitor firms’ capital ratios and plans under the internal stress scenario and the
supervisory severely adverse scenario, the Board proposed to instruct firms to report the CCAR
submissions of Schedule A inclusive of capital actions for which the firm expects to request prior
approval under 12 CFR 217.11.
Net charge-offs are generally defined to be gross of write-downs. FR Y-14A, Schedule
A.1.a (Income Statement), line item 114 (Total Net Charge-offs during the quarter) instructs
firms to report as defined in the FR Y-9C, Schedule HI-B (Charge-Offs and Recoveries on Loans
and Leases and Changes in Allowances for Credit Losses), Part I (Charge-offs and Recoveries on
Loans and Leases), line item 9 (Total), column A (Charge-offs) minus column B (Recoveries)
and is derived as the sum of Schedule A.1.a., items 114a-d. However, FR Y-9C, Schedule HI-B,
Part I, line item 9, column A is charge-offs gross of write downs, and Column B is recoveries.
The calculation defined in the instructions for line item 114a (Net charge-offs during the quarter
on loans and leases) is FR Y-9C, Schedule HI-B, Part II (Changes in Allowances for Credit
Losses), Column A (Loans and leases held for investment), item 3 (Charge-offs) minus item 2
(Recoveries), where item 3 is charge-offs net of write-downs. This creates an inconsistency
between how firms are instructed to report line item 114, which is done as reported on the
FR Y-9C, and its sum as a total of line items 114a-d. For alignment and accurate reporting, the
Board proposed to revise the instructions for the FR Y-14A, Schedule A.1.a line item 114a to be
gross of write downs and line item 114 to be the total of the components,114a-d.
FR Y-14A, Schedule A.7.a, item 36 (Provisions for Unfunded Off-Balance Sheet Credit
Exposures) instructs firms to report the provision for credit losses on off-balance sheet exposures
normally reported as one of the items in FR Y-9C, Schedule HI, item 7.d (Other noninterest
expense). Prior to implementation of the CECL methodology, provisions for off-balance sheet
exposures were recorded as other noninterest expense. However, CECL incorporates provisions
for off-balance sheet exposures in provisions for loan and lease losses. The FR Y-9C has been
updated to reflect this standard. As a result, the FR Y-9C, Schedule HI, item 7.d is no longer
relevant for item 36 on FR Y-14A, Schedule A.7.a. To ensure consistency between reports, the
Board proposed to update the instructions for item 36 to reference the FR Y-9C, Schedule HI-B,
Part II, item M7 (Provisions for credit losses on off-balance sheet credit exposures).

12
13

12 CFR 217.11(a)(2)(ii).
12 CFR 217.11(c)(1)(vi).

9

On January 26, 2023, the Board adopted a final rule to implement the Adjustable Interest
Rate (LIBOR) Act.14 The rule established benchmark replacements for certain contracts
governed by U.S. law to address references to LIBOR, which ceased to exist after June 30, 2023.
The Board therefore proposed to revise the FR Y-14 to remove or replace all references to
LIBOR in a manner consistent with the rule.
Counterparty
Submission of Fourth Quarter Data
Unstressed submissions of FR Y-14Q, Schedule L (Counterparty) are currently collected
four times per year. Three of the as of dates are the last calendar days of the first, second, and
third quarters. The fourth is the Board provided as of date for the GMS component of the
supervisory stress test, which must fall between October 1 of the previous calendar year and
March 1 of the year of the supervisory stress test.15 These requirements can result in a timing gap
between the unstressed submissions for the first and third quarters of up to 6 months. This timing
gap can result in the Board not having up-to-date data on firms’ counterparty credit risks. The
absence of important data has been noted during times of instability, when it is important to have
reliable, timely data. To address this limitation and create consistency in reporting frequency, the
Board proposed to require an additional unstressed Schedule L submission as of the last calendar
day of the fourth quarter.
Reporting Scope and Frequency for Firms Subject to Category I Standards
The FR Y-14Q instructions set several materiality thresholds to determine the frequency
and scope of reporting for several schedules. Only firms subject to Category I, II, or III standards
and that, as of two quarters preceding the reporting quarter, have on average for four quarters
aggregate trading assets and liabilities of $50 billion or more, or aggregate trading assets and
liabilities equal to 10 percent or more of total consolidated assets, must submit FR Y-14Q,
Schedule L. Firms with trading operations below the materiality threshold are not required to
report Schedule L. As a result, certain U.S. global systemically important banks (GSIBs) do not
file the complete Schedule L.
Category I standards apply to firms that qualify as U.S. GSIBs, given the risk their
individual failure poses to the broader financial system. For the U.S. GSIBs that are not currently
required to report Schedule L, the minimal data on their counterparty credit exposures is not
sufficiently frequent or comprehensive to provide meaningful risk monitoring when a financial
market stress event occurs.
To ensure that data on all U.S. GSIB counterparty risks, including credit valuation
adjustment and counterparty default risks, would be available in a timely manner, the Board
proposed to revise the threshold for Schedule L reporting to be inclusive of all firms subject to
Category I standards. The reporting threshold would have remained unchanged for firms subject
to Category II, III, and IV standards.
14
15

88 FR 5204 (January 26, 2023).
12 CFR 252.54(b)(2)(i).

10

Reporting of Counterparties under the Firm-generated Scenario
FR Y-14Q, Schedule L.5 (Derivatives and Securities Financing Transactions Profile)
collects information on a firm’s top counterparties associated with securities financing
transactions (SFTs) and/or derivative positions at the level of positions netting. Specifically,
Schedule L.5.1 (Derivative and SFT information by counterparty legal entity and netting
set/agreement) is intended to identify the counterparties to these types of positions under ranking
methodologies and the associated exposures. Schedule L.5 is submitted yearly under the stressed
conditions as prescribed in the Board-provided scenario. Firms are also required to generate their
own stress scenario, but the related exposures are not collected on Schedule L.5. To have more
information on a firm’s view of its own risk profile, the Board proposed to require the reporting
of Schedule L.5 under the firm-generated stress scenario. This revision would have required a
new ranking methodology to be reported on Schedule L.5 under which a firm ranks its top 25
counterparties by stressed net current exposure (net CE) under the firm-generated scenario and
the reporting of the related exposures on sub-schedules L.5.2-L.5.4.
Assumptions Associated with the Reporting of CVA Sensitivities
FR Y-14Q, Schedule L.4 (Aggregate and Top 10 CVA Sensitivities by Risk Factor)
collects sensitivity information of aggregate asset-side CVA based on changes in underlying risk
factors. Generally, a sensitivity refers to a 1-unit change in the risk factor, and a slide refers to a
larger change in the risk factor. However, Schedule L.4 does not specify the assumptions under
which to calculate the CVA which results in inconsistent reporting across firms and hinders data
comparisons. Additionally, the other CVA sub-schedules (L.1, L.2, and L.3) specify that the data
are to be reported using the Board-provided scenario and specifications (i.e., margin period of
risk of 10 business days, keeping CSA thresholds flat, no gains from netting, and no credit
downgrade triggers). To increase the consistency of reporting and to better assess the impact of
the market shock scenario across firms, the Board proposed to specify that the CVA sensitivities
on Schedule L.4 must be reported using the Federal Reserve-provided specifications.
Netting when Calculating Net Current Exposure
FR Y-14Q, Schedule L collects information on net CE for SFT agreements in a firm’s
portfolio. Generally, if a firm does not have a close-out netting agreement with a counterparty on
its SFT portfolio, the firm is not allowed to take a netting benefit across the transactions but can
net exposures across multiple legs within a single transaction when calculating net CE. However,
the instructions for reporting net CE are ambiguous regarding netting practices. To clarify the
reporting of net CE in Schedule L, the Board proposed to revise the instructions to describe how
a firm can net exposures when calculating net CE for SFTs. This revision would have addressed
questions and issues raised in FR Y-14 Q&As #Y140001627 and #Y140001614.
Removal of Fields Deemed No Longer Necessary
FR Y-14Q, Schedule L.5.1 (Derivative and SFT information by counterparty legal entity
and netting set/agreement) collects information about a firm’s top counterparties associated with
SFTs and/or derivative positions at the level of position netting under different ranking

11

methodologies. The collection of these data supports both the stress test modeling and
supervisory monitoring of counterparty exposures. Over time, several items on Schedule L.5.1
have been identified as providing minimal value in these supervisory activities. These items are:
• Threshold CP
• Threshold BHC or IHC or SLHC
• Minimum Transfer Amount CP
• Minimum Transfer Amount BHC or IHC or SLHC
• Credit Default Swap (CDS) Reference Entity Type
• 5Y CDS Spread (bp)
Additionally, the item “Downgrade Trigger Modeled?” on Schedule L.1.a (Top
consolidated/parent counterparties comprising 95% of firm unstressed credit valuation
adjustment (CVA), ranked by unstressed CVA) and L.1.b (Top consolidated/parent
counterparties comprising 95% of firm stressed CVA, ranked by Federal Reserve Severely
Adverse Scenario stressed CVA for the CCAR quarter) is no longer necessary as firms are
instructed to report ‘NA’ in this field. To reduce burden and ensure the Board only collects
necessary data, the Board proposed to retire all the items discussed in this sub-section from
Schedule L.
Other FR Y-14Q, Schedule L Revisions
Firms are required to identify the type of non-cash collateral or initial margin that was
either posted or received for SFT and derivative agreements in the “Non-Cash Collateral Type”
field, per the general instructions for Schedule L.5.1. However, the “Non-Cash Collateral Type”
instructions do not specify if this field applies to both derivatives and SFTs. To remove
ambiguity, the Board proposed to clarify that the “Non-Cash Collateral Type” field pertains to
both SFTs and derivatives. This revision would have addressed questions and issues raised in
FR Y-14 Q&A #Y140001591.
On FR Y-14Q, Schedule L.5, firms are instructed to rank their top 25 counterparties with
positive net CE for each of the ranking methodologies. However, in some cases, a firm may not
have 25 counterparties with positive net CE. For clarity, the Board proposed to specify that if a
firm has less than 25 applicable counterparties for a given ranking methodology, then it should
only report the applicable counterparties, and should not report additional counterparties with
zero net CE. This revision would have addressed questions and issues raised in FR Y-14 Q&A
#Y140001595.
Net CE is calculated at the counterparty netting agreement level where it is possible for
an underlying netting agreement to cover both fair-value and accrual SFT agreements.
Schedule L currently pertains to both fair-value and accrual SFTs; however, the instructions only
mention fair-value SFTs when calculating Net CE. To reduce ambiguity, the Board proposed to
clarify that, when a netting agreement covers both fair-value and accrual SFTs, a firm should
combine both types of SFTs for purposes of reporting Net CE and CVA metrics in Schedule L.
The FR Y-14Q, Schedule L.5.1 “Agreement Type” field requires firms to identify the
derivative agreement type when at least one of the netting sets associated with the counterparty

12

has a legally enforceable collateral agreement. For derivatives, allowable entries are “Derivatives
1-way CSA [Credit Support Annex],” “Derivatives 2-way SCSA [Standard Credit Support
Annex],” “Derivatives 2-way old CSA,” or “Derivatives Centrally Cleared.” However, the
instructions do not currently provide definitions for these agreement types. The Board proposed
to clarify that firms should use the International Swaps and Derivatives Association, Inc.,
publication of the 2013 Standard Credit Support Annex for the basis of classifying derivatives as
SCSA and use Old-CSA for agreements made prior to this publication when reporting this field.
Wholesale
FR Y-14Q, Schedule H (Wholesale) collects loan-level information on corporate and
commercial real estate loans and leases to support the supervisory stress test and risk analyses.
The data collected includes details on the obligor and loan itself, and the financial health of the
obligor. The following proposed revisions would have enhanced Schedule H to address growing
financial stability risks, improve the quality of collected data, and address new accounting
standards.
Reporting Treatment of Nondepository Financial Institutions
U.S. bank exposures to NDFIs have grown rapidly over the past five years and banks’
credit commitments to NDFIs reached about $2.5 trillion in the second quarter of 2025.16 This
growth poses risks to banks, as certain NDFIs operate with very high leverage and are dependent
on credit from the banking sector. Currently, data on exposures to NDFIs are limited on the
FR Y-14, as banks report minimal information about these obligors, relative to other corporate
borrowers. This lack of data hinders staff’s ability to consistently measure, monitor, and model
the risks stemming from these exposures under stress.
The FR Y-14 report currently does not require firms to report certain financial
information (such as total assets, total liabilities, short term debt, or net income) on NDFI
obligors, which results in a material data gap. As a result, less than half of the total committed
exposure on the corporate loan schedule includes data on the financial health of the obligor. This
lack of data means the stress test models may not accurately capture risks associated with loans
to NDFIs. Similarly, this lack of data reduces the consistency of measurement and monitoring of
these exposures for supervisory purposes. To understand the financial conditions of NDFI
borrowers, the Board proposed to require the reporting of fields 52 through 82 on Schedule H.1,
the “Obligor Financial Data Section,” for NDFIs.
Currently the FR Y-14 lacks the necessary granularity to classify the business type of
NDFI obligors that borrow from firms and the associated risks. As the various business types of
NDFIs pose different types of risks to banks, these data are necessary to consistently measure
and monitor the risks NDFIs pose to firms and to ensure that the supervisory stress test is
appropriately calibrated for loans to NDFIs. To understand banks’ exposures to various NDFI
types, the Board proposed to add a “NDFI Entity Type” field to Schedule H.1 in which firms

16

See Board of Governors of the Federal Reserve System, Financial Stability Report (November 2025),
https://www.federalreserve.gov/publications/files/financial-stability-report-20251107.pdf.

13

would have had multiple options to specify the NDFI type (e.g., credit fund, broker-dealer,
special purpose entity, etc.) to which the facility was extended.
Reporting of Financial Sponsors
The role of financial sponsors has contributed to the growth of NDFI activities in the
corporate sector over the past several years. A financial sponsor is any person, including any
subsidiary of such person, whose principal business activity is acquiring, holding, and selling
investments in otherwise unrelated companies that each are distinct legal entities with separate
management, books, records, and bank accounts, whose operations are not integrated with one
another and whose financial condition and creditworthiness are independent of the other
companies so owned by such person. While the proposed revisions to Schedule H described
above would have collected information on lending to NDFIs and the associated risks, they
would not have increased insight into equity investments in the corporate sector where NDFIs
are increasing their activities. To address this remaining data gap, the Board proposed to
introduce three additional new fields on FR Y-14Q, Schedule H.1 to capture whether the obligor
is controlled by a financial sponsor, and if so, that financial sponsor’s legal name and legal entity
identifier. These fields would have informed the Board of lending to companies controlled by a
NDFI, a noted gap of supervisory insight into firm activities with NDFIs.
Additional Options for the Reporting of Security Type
FR Y-14Q, Schedule H.1 item 36 (Security Type) requires firms to report the
predominant security type for collateral other than or in addition to real estate. There are
currently seven options that can be reported for this field. The majority of wholesale loans are
secured by collateral, which serves as the primary source of repayment. Further, collateral is a
key risk transmitter from NDFIs to firms and provides additional insight into the NDFI’s
activities. The lack of granularity in this field diminishes the Board’s understanding of this
characteristic of the obligor’s facility, as the options provided are not comprehensive. To better
define the collateral underlying the loan, the Board proposed to add twelve additional response
options to the “Security Type” field, covering an array of known collateral types, and implement
an “Other Security Type” field to capture the full range of collateral types.
Reporting of Fee Information
The data collected by Schedule H includes pricing characteristics of each loan and
sources of lender income, such as the facility’s interest rate. However, a facility’s fees can also
be a significant source of lender income and risk. Fee information is not currently captured on
Schedule H. The fee structure is a component of the overall loan pricing, an indicator of lender
tolerance, and a contributor to the fair value of loans. The lack of fee data constrains the Board’s
supervisory risk assessment process and obscures the pricing characteristics of the facilities
reported. To increase insight into this aspect of a loan’s pricing and riskiness, the Board
proposed to add five fields to Schedule H.1 and Schedule H.2 to capture the facility’s fee
structure.

14

Reporting of Collateral Market Value
On Schedule H.1, one of the fields used to gain insight into the financial health of the
obligor is “Collateral Market Value,”, line item 93, which requires the reporting of collateral
market value for facilities that require ongoing or periodic valuation of collateral if the value has
been updated in the firm’s internal risk management systems. Under the current instructions, this
field is only reported for collateral that is market-based. These specifications result in infrequent
reporting of this field, severely limiting its usefulness in evaluating firm risk. To increase the
understanding of a loan’s risk characteristics, the Board proposed to modify the instructions of
the “Collateral Market Value” field to require the reporting of collateral valuations for all
facilities with commitments based on collateral.
Loan Covenant Violation Information
Loan covenants appear in many commercial loan contracts and circumscribe specific
actions a borrower may take (nonfinancial covenants) or thresholds for cash flow or balance
sheet variables (financial covenants). Breaching a covenant can put a borrower into technical
default and may give the lender the right to modify the terms of the agreement. Covenant
violations can increase a lender’s bargaining power and can provide broad opportunity to
renegotiate contract terms when the lender’s internal cost of funds rises. Thus, covenant
violations could lead to a reduction in the existing stock of credit, potentially affecting a large
segment of borrowers. Information regarding loan covenants provides additional details
regarding the lender’s perspective of loan riskiness. Additionally, details on a covenant violation
would increase the Board’s understanding of a firm’s ability to renegotiate a credit relationship,
change its exposure to a given borrower, or provide early warning signs of future loan
performance. However, FR Y-14Q, Schedule H.1 does not currently capture covenant details.
Therefore, the Board proposed to introduce a field to capture whether a loan covenant exists,
whether the covenant has been violated, and, if so, whether the agreement has been amended.
Loan Amortization Reporting
FR Y-14Q, Schedule H.2 requires the reporting of the number of months to fully
amortize a loan or indication of a non-standard amortization schedule in line item 20
(Amortization). However, there is not equivalent data collected for corporate loans on
Schedule H.1, and so the Board proposed to add an identical item to Schedule H.1. The CECL
methodology requires additional consideration of amortization periods to accurately quantify the
lifetime of a loan and balance run off. Therefore, receiving amortization information on Schedule
H.1 would have provided data to more accurately model provisions for corporate loans in the
stress test.
Troubled Debt Restructurings
FR Y-14Q, Schedule H.2 collects information on loans that have been modified as a
troubled debt restructuring (TDR). Additionally, line item 10 (Origination Date) indicates that
firms should generally not update the origination date if the modification made is a TDR. In
March 2022, the Financial Accounting Standards Board (FASB) issued new accounting

15

guidance, ASU No. 2022-02, which eliminated the recognition of TDRs. In addition, ASU 202202 introduced accounting disclosures for loan modifications to borrowers experiencing financial
difficulty (LMBEFDs). This guidance went into effect January 1, 2023, for firms that had
adopted ASU No. 2016-13. Consistent with ASU 2022-02, the Board proposed to introduce a
new field to Schedule H.1 and Schedule H.2 to capture loans modified as LMBEFDs for firms
that have adopted ASU 2016-13. The Board also proposed to retire item 49 as it is no longer
needed under ASU 2022-02. Additionally, the Board proposed to add LMBEFDs to line item 10
to indicate that LMBEFDs are generally not considered a major loan modification, as currently
indicated for TDRs.
Units of Size for Property Size Reporting
Beginning with the June 30, 2023, as of date, the Board added two options, “Healthcare”
and “Warehouse/Distribution” to the “Property Type” field on the FR Y-14Q, Schedule H.2.17
Schedule H.2, line item 39 (Property Size) collects data on the size of the property securing the
facility and specifies the unit of size in which to report this field based on the property type. The
instructions currently do not specify how to report this field for the new healthcare and
warehouse/distribution property types. Therefore, the Board proposed to specify that item 39
should be reported in square feet when reporting the size of healthcare and
warehouse/distribution property types.
Unused Commitments
The instructions to FR Y-14Q, Schedule H require firms to include any unused
commitments that are reported on FR Y-9C, Schedule HC-L (Derivatives and Off-Balance-Sheet
Items) that would be reported in the relevant FR Y-9C category if such loans were drawn
(including all undrawn commitments extended to non-consolidated variable interest entities and
commitments to commit as defined in the FR Y-9C). Schedule H is intended to capture all
unused commitments where the firm has extended terms that the borrower has accepted and are
either in writing or otherwise legally binding. The current Schedule H language is ambiguous as
to how to account for undrawn commitments, which can result in inconsistencies across reports.
To ensure consistent reporting across firms and to eliminate ambiguity, the Board proposed to
update the Schedule H language to make clear which commitments must be reported.
Removal of Fields Deemed No Longer Necessary
On FR Y-14Q, Schedule H.1 (Corporate), item 43 (Interest Income Tax Status), firms
report the tax status of interest income for federal or state income tax purposes. The allowable
values are “Taxable” or “Tax Exempt,” as determined by whether the interest income received
by the firm is tax exempt. The Board determined that information on the tax status of interest
income is no longer relevant for modeling or monitoring purposes; therefore, the Board proposed
to retire item 43 from Schedule H.1.

17

87 FR 52560 (August 26, 2022).

16

Retail
Alignment between Loan-Level and Portfolio-Level First Lien Schedules
Currently, FR Y-14M, Schedule A.2 (Domestic First Lien Closed-end 1-4 Family
Residential Portfolio Level Table) captures total principal balance and cumulative write-downs
within a firm’s domestic first-lien portfolio but does not capture total debt from loans
involuntarily terminated, total net recoveries, or total credit enhancements received. While
Schedule A.1 (Domestic First Lien Closed-end 1-4 Family Residential Loan Level Table)
collects these data for individual loans, the absence of these data on Schedule A.2 limits the
Board’s insight into charge-off and recovery information at the portfolio level. The current
granularity of the collection prohibits the calculation of write-downs in a specific month or the
timing of the loan termination. Therefore, the Board proposed to add the fields “Total Debt from
Loans Involuntarily Terminated,” “Total Net Recoveries,” and “Total Credit Enhancements
Received” to Schedule A.2. The instructions for these fields would have replicated the language
currently used for the related fields on Schedule A.1.
Owner-Occupied Nonfarm Nonresidential Loans
FR Y-14Q, Schedule A.9 (U.S. Small Business) instructs firms to report “scored” or
“delinquency managed” domestic small business loans as included in FR Y-9C, Schedule HC-C
(Loans and Lease Financing Receivables) line items 2.a, 2.b, 3, 4.a, 4.b, 7, 9.a, 9.b.2, and 10.b. A
key differentiating factor between corporate loans and small business loans is how the firm
evaluates the creditworthiness of the borrower. For small business lending, firms rely on the
credit score of the borrower (scored) and/or use delinquency management. Therefore, scored or
delinquency managed owner-occupied nonfarm nonresidential (NFNR) loans as reported in line
item 1.e.1 in the FR Y-9C, Schedule HC-C are small business loans and should be reported as
such on Schedule A.9. However, the Schedule A.9 instructions do not reference the
corresponding FR Y-9C line item. Further, FR Y-14Q, Schedule M (Balances) does not
distinguish between wholesale and retail owner-occupied NFNR loans, as there is only one line
item under which to report all owner-occupied NFNR loans. To eliminate reporting ambiguity,
the Board proposed to specify that scored or delinquency managed owner-occupied NFNR loans,
as reported in the FR Y-9C, Schedule HC-C, line item 1.e.1, should be reported on Schedule A.9.
The Board also proposed to specify that scored owner-occupied NFNR loans be reported as
small business loans (line item 2.b) on Schedule M.1 and to add a line item to Schedule M.2 for
scored owner-occupied NFNR loans. The existing owner-occupied NFNR field (line item
1.b.3.a) on schedule M.1 would have specified that it is only intended to capture the wholesale
loan balance. For completeness, the Board proposed to enable the reporting of column F (Scored
Loans) for line item 7.d.1 (Domestic Owner Occupied NFNR) on FR Y-14Q, Schedule K
(Supplemental). The Board proposed to also clarify that column F applies only to owneroccupied NFNR loans. These revisions would have ensured scored owner-occupied NFNR loans
are reported properly across the FR Y-14Q.

17

Reporting of International and Domestic Credit Card Loans
The instructions for FR Y-14Q, Schedule A.3 (International Credit Card) require firms to
report small business and corporate credit card loans that are issued to non-U.S. addressees, as
defined in the FR Y-9C, Schedule HC-C, item 4.b ([Loans] To non-U.S. addresses), which only
accounts the loans for which the borrower is non-U.S. domiciled. However, reporting
international loans determined by borrower domicile is inconsistent with the other international
retail sub-schedules and the Balances schedule. All other FR Y-14Q retail schedules and the
Balances schedule instruct firms to report international loans as determined by the location of the
holding office. The use of borrower domicile as the defining criteria for loans in Schedule A.3
results in credit card loans issued by international offices to U.S. addresses being reflected only
in Schedule M, which does not provide any loan details. To align reporting standards of
international loans across all FR Y-14 schedules and ensure the Board has the data needed to
project loan performance in the stress test, the Board proposed to define all international credit
card loans by office location, not borrower domicile. This revision would have superseded the
guidance issued in FR Y-14 Q&As #Y14000700, #Y140001258, #Y140001176, and
#Y14000994, and these Q&As would have been updated to point to the new instructions.
Further, to avoid ambiguity, the Board proposed to revise the FR Y-14Q retail schedule
instructions to clarify that only loans held in foreign offices should be reported on the
international sub-schedules. Additionally, to avoid a reporting gap or confusion in the
“Geography” field, the Board proposed to add “United States” to Region 1 for all international
retail sub-schedules. These revisions would have been consistent with the proposed revision that
would have provided that international loans are classified as such based on the location of the
office that holds the loan balance.
Relatedly, and for completeness in the collection of credit card loan data, the Board
proposed to incorporate loans issued by domestic offices to international domiciles on
FR Y-14M, Schedule D (Credit Cards). Currently, the FR Y-14M defines domestic credit card
loans by office location but does not account for loans issued by domestic offices to international
addressees. This revision would have closed this reporting gap and instructed firms to report all
credit card loans held in domestic offices, issued to both U.S. and non-U.S. addressees.
Revenue and Loss Sharing Agreements
As mentioned in the 2023 Supervisory Stress Test Methodology document, the Board
adjusts projected credit card losses to reflect agreements with private entities to share a portion
of both revenues and losses generated by a specific credit card portfolio.18 Currently, the Board
collects the data used to make this adjustment through a supplemental data collection. The Board
proposed to formalize this supplemental collection by requiring the reporting of all revenue and
loss sharing agreements (RLSAs) on FR Y-14M, Schedule D (Domestic Credit Card).
Schedule D currently only collects data on RLSAs with the Federal Deposit Insurance
Corporation (FDIC). This revision would have required firms to report all accounts that are a part
of any RLSA on Schedule D.1 (Domestic Credit Card Loan Level Table), line item 70 (Loss
18

See Board of Governors of the Federal Reserve System, 2023 Supervisory Stress Test Methodology (June 2023),
https://www.federalreserve.gov/publications/files/2023-june-supervisory-stress-test-methodology.pdf.

18

Share). Additionally, the Board would have added two line items to Schedule D.2 (Domestic
Credit Card Portfolio Level Table) to collect information on the dollar amount received or
credited for credit losses associated with RLSAs. Incorporating this supplemental collection
would have ensured reporting of RLSAs is standardized and all firms receive consistent
treatment in the supervisory stress test.
Troubled Debt Restructurings
FR Y-14M, Schedule A.1 and Schedule B.1 (Domestic Home Equity Loan/Line Level
Table) collect information on loans that have been modified as a troubled debt restructuring
(TDR). Specifically, line item 96 (Troubled Debt Restructuring Flag) on Schedule A.1 and line
item 55 (Troubled Debt Restructuring Date) on Schedule B.1 are reported by firms that have
made a loan modification classified as a TDR, as defined in the FR Y-9C Glossary. However, as
discussed above, ASU 2022-02 eliminated the recognition of TDRs and introduced accounting
disclosures for LMBEFDs. This guidance went into effect January 1, 2023, for firms that have
adopted ASU No. 2016-13. Consistent with ASU 2022-02, the Board proposed to introduce a
new field to each Schedule A.1 and Schedule B.1 to capture LMBEFDs for firms that have
adopted ASU 2016-13. The Board also proposed to retire the existing TDR fields as they are no
longer needed under ASU 2022-02.
Removal of Fields Deemed No Longer Necessary
The Board proposed to remove three items from FR Y-14M, Schedule D.1 (Domestic
Credit Card Loan Level Table) that are inconsistently reported and therefore provide reduced
value in supervisory stress test modeling and related analyses. Specifically, the Board proposed
to remove item 42 (Behavioral Score), item 111 (Behavioral Score Name Version), and item 114
(Date Co-Borrower was Added). Items 42 and 114 are firms’ internal estimates that are difficult
to compare across firms due to inconsistencies in how they are recorded. Similarly, item 114 is
infrequently reported which results in limited value for modeling or analysis.
Line item 77 “Modification Type” on the FR Y-14M, Schedule B.1 allows the reporting
of multiple types of modifications to a loan. One of the reportable codes in this field is “99 =
Other,” which captures cases when the loan modification type is unknown. As the “Modification
Type” field covers all possible modification action types, the Board proposed to remove line
item 90 “Other Modification Action Type” from Schedule B.1. Item 90 captures the loans under
unknown modification types but is no longer needed by the Board.
Other Revisions
The instructions for FR Y-14M, Schedule A.1 and Schedule B.1 “Workout Type
Completed” fields, line items 77 and 61 respectively, require firms to leave these items blank if
the loan has never been in loss mitigation. To align the instructions for the workout type fields,
the Board proposed to clarify that the “Workout Type Started” fields on these schedules
(Schedule A.1, line item 143 and Schedule B.1, line item 120), should also be left blank if the
loan has never been in loss mitigation.

19

The Board previously adopted revisions to expand the circumstances under which firms
would report the “Principal Deferred” and “Principal Write-Down” items on FR Y-14M,
Schedule B.1; however, the instructions for “Principal Deferred” were not revised to reflect
this.19 Specifically, the revision intended to expand reporting requirements for loans deferred due
to loss mitigation activities. These revisions were adopted and implemented for the
corresponding fields on the FR Y-14M, Schedule A.1. For consistency, the Board proposed to
update the instructions for the FR Y-14M, Schedule B.1 line item 59 (Principal Deferred) and to
expand reporting requirements to loans deferred due to loss mitigation activities. For
completeness, the Board proposed to clarify the instructions for the “Principal Write-Down”
field on the FR Y-14M, Schedule B.1 to indicate the line item should be coded “Y” if adjustment
to the unpaid principal balance has occurred through modification or loss mitigation activities.
Firms are required to report quarter-end balances for charge cards with a pay-over-time
feature under line item 3.b (Charge Cards) on FR Y-14Q, Schedule M (Balances). The Board has
received questions asking if the corresponding line item on FR Y-14A, Schedule A.1.b
(Balances) should also reflect charge cards with a pay-over-time feature. For consistency and
clarity, the Board proposed to specify that charge cards with a pay-over-time feature should be
reported in line item 36 (Charge Cards) on FR Y-14A, Schedule A.1.b.
Balances
Information on shared-loss agreements (SLAs) with the FDIC has historically been
reported on the FR Y-9C, which collected data on the balances of a portfolio covered by such
agreements. These data have been used to monitor the impact of SLAs on a firm’s loan and lease
losses. However, in connection with a recent statutorily mandated review, the Board removed
most of these items from the FR Y-9C.20 To ensure that the Board continues to receive this
information and that SLAs are reflected appropriately in the supervisory stress test, the Board
proposed to create a new FR Y-14Q, Schedule M (Balances) sub-schedule to collect data on
loans and leases covered by SLAs with the FDIC. This collection would have been substantially
similar to the data previously collected by the FR Y-9C. However, collecting the information
through the FR Y-14, rather than the FR Y-9C, would have ensured that only firms subject to the
supervisory stress test are required to report the information.
Trading
Small Business Investment Companies
FR Y-14Q, Schedule F (Trading) is designed to capture profit/loss sensitivities to
positions firms hold in their trading books, private equity investments, fair value option (FVO)
loan hedges, and certain other assets under fair value accounting. Private equity includes all
equity related investments such as common, preferred, and convertible securities. Currently,
investments in small business investment companies (SBICs) are reported under the “Other
Unspecified Sector/Industry” industry group in the “Unspecified Sector/Industry” sector.21 This
19

87 FR 52560 (August 26, 2022).
88 FR 18315 (March 28, 2023).
21
See 13 CFR Part 107 for the definition of SBICs.
20

20

item is meant to capture the carry value of instruments not easily categorized into one of the
specified industries and sectors, investments in several sectors, and for which there is insufficient
detail to break out the carry value of the holding into component sectors. However, given the
unique characteristics of SBICs that distinguish them from general private equity exposures, the
Board proposed to add “SBIC Interests” as an industry group to capture funded and unfunded
equity interests in SBICs.
Capital
The instructions for FR Y-14Q, Schedule D (Capital) line item M1 (Taxes paid through
the as of date of the current fiscal year) require firms to report the amount of taxes paid during
the fiscal year, through the as of date, that are included in Schedule D, line item 17 (Amount to
be deducted from common equity tier 1 due to deduction threshold). The reference to line item
17 is erroneous, as this item was modified during an update to the form and instructions. To
correct this error and restore the original intent of item M1, the Board proposed to remove the
reference to line item 17 from the instructions to clarify that firms should report taxes paid
through the as of date of the current fiscal year.
FR Y-14A, Schedule A.1.d (Capital), line item 56 (Unrealized gains on available-for-sale
preferred stock classified as an equity security under GAAP and available for sale equity
exposures includable in tier 2 capital) previously captured unrealized gains on AFS equity
securities that were recognized in AOCI. However, ASU 2016-01 reclassified unrealized gains
on AFS equity securities to be reflected in the retained earnings component of equity capital. To
address the new accounting standard, the Board proposed to retire item 56, as what was
previously captured in this item is already reflected in retained earnings.
Firms are required to submit a version of FR Y-14A, Schedule C (Regulatory Capital
Instruments) at the time the firm seeks approval for additional capital distributions pursuant to 12
CFR 225.8(j) or within 15 days after making any capital distribution approved pursuant to that
section or a capital distribution in excess of the firm’s final planned capital distributions. These
Schedule C submissions are referred to as “Incremental” submissions. In FR Y-14 Q&A
#Y140001459, the Board clarified that an Incremental submission is required if a firm makes a
distribution such that the dollar amount exceeds the firm’s final planned capital distribution, as
measured on an aggregate basis beginning in the fourth quarter of the planning horizon through
the quarter at issue, even if that change is not reflected on Schedule C. The Board proposed to
add language to incorporate that response and clarify that these Incremental submissions are
required.
Securities
Reporting of Market Value
Firms are required to report the market value of the security being hedged on FR Y-14Q,
Schedule B.2 (Securities), line item 4 (Market Value). Currently, the instructions for this field
instruct firms to report amortized cost when reporting a security that contains trade lots or
holdings that are not part of the hedging relationship. Since this field is intended to capture the

21

market value of the security, the reference to amortized cost is erroneous and duplicative since
amortized cost is reported in line item 3 (Amortized Cost). To correct this erroneous reference,
the Board proposed to revise the language from “amortized cost” to “market value” in the
instructions for line item 4.
Hedge Designations
FR Y-14Q, Schedule B.2, item 15 (ASU 2017-12 Hedge Designations) currently captures
ASU 2017-13 hedge designations allowed in conjunction with partial-term hedging election in
ASC 815-20-25-12b(2)(ii). On March 28, 2022, the FASB issued ASU 2022-01, which
established the portfolio layer method to allow multiple hedged layers of a closed portfolio,
rather than just a single layer as was currently allowed. To be consistent with ASU 2022-01, the
Board proposed to revise item 15 to reflect the updated portfolio layer method of hedge
accounting.
Removal of Field Deemed No Longer Necessary
FR Y-14Q, Schedule B.2 (Investment Securities with Designated Accounting Hedges),
item 11 (Hedged Cash Flow) collects information on the type of cash flow associated with the
hedge if it is a cash flow hedge. The Board determined that this variable is not needed for
modeling or monitoring purposes, therefore the Board proposed to retire item 11 from Schedule
B.2.
Supplemental
FR Y-14Q, Schedule K (Supplemental) is intended to capture gaps in the data collected
between the FR Y-14 and FR Y-9C, and firms generally do not need to complete all fields in the
schedule. Specifically, Column A (Immaterial Portfolios) captures the carrying value of loans in
immaterial or excluded portfolios that were not reported elsewhere on the FR Y-14Q or
FR Y-14M because they did not meet the materiality thresholds. These instructions currently do
not specify whether these portfolios need to be reported on Schedule K if they were only
reported on one of the FR Y-14Q or FR Y-14M. Since Schedule K is intended to capture gaps in
collected data, portfolios that are reported on either the FR Y-14Q or the FR Y-14M should not
be reported on the schedule, and the Board proposed to clarify this existing expectation in the
instructions.
Additionally, the instructions for Column D (Outstanding Balance of Commercial Real
Estate and Corporate loans under $1M in committed balance) tell firms to report the outstanding
balance of CRE and corporate loans with under $1 million in committed balance for each of the
categories that had been excluded from FR Y-14Q, Schedule H based solely on commitment
size. Column D is intended to capture the sum of the outstanding balance for these loans with
under $1 million in committed balance in a portfolio that is reported on Schedule H. Column A is
intended to capture the balance of immaterial portfolios, not reported on Schedule H. To remove
ambiguity, the Board proposed to clarify that column D should only be reported for loans that are
included in a portfolio reported on Schedule H but were excluded based solely on commitment
size.

22

Public Availability of Data
No data received through this information collection are made available to the public.
Legal Status
The FR Y-14 reports are authorized pursuant to sections 5(b) and (c) of the Bank Holding
Company Act of 1956 (BHC Act) (12 U.S.C. §§ 1844(b) and (c)), sections 102(a)(1) and 165 of
the Dodd-Frank Act (12 U.S.C. §§ 5311(a)(1), 5365, and 5365 note), section 10(b) of the Home
Owners’ Loan Act (HOLA) (12 U.S.C. § 1467a(b)), section 8(a) of the International Banking
Act of 1978 (12 U.S.C. § 3106(a)), and section 401(g) of the EGRRCPA (12 U.S.C. § 5365
note).
The Board is authorized to require BHCs to file the FR Y-14 reports pursuant to sections
5(b) and 5(c) of the BHC Act and section 165 of the Dodd-Frank Act, as amended by the
EGRRCPA. Section 5(b) of the BHC Act authorizes the Board to issue regulations and orders
relating to capital requirements for BHCs.22 Section 5(c) of the BHC Act authorizes the Board to
require a BHC and any subsidiary of such company to submit reports to keep the Board informed
of the BHC’s financial condition, systems for controlling financial and operating risks,
transactions with depository institution subsidiaries of the BHC, and compliance with certain
laws.23 Section 165 of the Dodd-Frank Act requires the Board to conduct supervisory stress tests
of certain large BHCs.24 In addition, section 165(i)(2) of the Dodd-Frank Act requires the Board
to issue regulations requiring certain companies to conduct company-run stress tests.25 Section
165(i)(2)(B) provides that a company required to run stress tests pursuant to such regulations
shall submit reports to the Board and the company’s primary federal regulator at the time and in
the form required by the regulators.26
The Board has authority to require SLHCs to file the FR Y-14 reports pursuant to section
10(b) of the HOLA, as amended by the Dodd-Frank Act. Section 10(b) of the HOLA authorizes
the Board to require SLHCs to file “such reports as may be required by the Board” containing
“such information concerning the operations of such [SLHC]… as the Board may require.”27
Section 8(a) of the International Banking Act allows the Board to apply the requirements
of section 5(b) of the BHC Act to foreign banking organizations,28 including such organizations’
22

12 U.S.C. § 1844(b).
12 U.S.C. § 1844(c).
24
See 12 U.S.C. §§ 5365(i)(1), 5365 note. Annual supervisory stress tests are required for BHCs with $250 billion
or more in total consolidated assets. 12 U.S.C. § 5365(i)(1). “Periodic” supervisory stress tests are required for
BHCs with $100 billion or more, but less than $250 billion, in total consolidated assets. 12 U.S.C. § 5365 note.
25
See 12 U.S.C. § 5365(i)(2). Bank holding companies with $250 billion or more in total consolidated assets must
conduct “periodic” stress tests.
26
12 U.S.C. § 5365(i)(2)(B).
27
12 U.S.C. § 1467a(b)(2). Congress transferred this authority from the Director of the Office of Thrift Supervision
to the Board in the Dodd-Frank Act. See 12 U.S.C. §§ 5412, 5415.
28
12 U.S.C. § 3106(a). This provision specifies that (1) any foreign bank that maintains a branch or agency in a
state, (2) any foreign bank or foreign company controlling a foreign bank that controls a commercial lending
company organized under the law of a state, and (3) any company of which a company falling under category (1) or
(2) is a subsidiary, shall be subject to the provisions of the BHC Act. Id.
23

23

U.S. IHCs. Similarly, section 102(a)(1) of the Dodd-Frank Act allows the Board to apply the
requirements of section 165 to U.S. IHCs that are treated as BHCs under section 8(a) of the
International Banking Act.29 In addition, section 401(g) of the EGRRCPA provides that the
Board has the authority to establish enhanced prudential standards for foreign banking
organizations with total consolidated assets of $100 billion or more, and clarifies that nothing
that section “shall be construed to affect the legal effect of the final rule of the Board … entitled
‘Enhanced Prudential Standard for [BHCs] and Foreign Banking Organizations’ (79 FR 17240
(March 27, 2014)), as applied to foreign banking organizations with total consolidated assets
equal to or greater than $100 million.”30 The final rule referenced in section 401(g) of the
EGRRCPA specifically stated that the Board would require IHCs to file the FR Y-14 reports.31
The obligation to respond is mandatory.
The Board generally treats the information collected by the FR Y-14 reports as
confidential. The Board also does not require firms to publicly disclose this information, though
firms may be required to disclose certain information under applicable state or federal law (e.g.,
securities laws). To the extent that the information that firms submit to the Board is made
available to the public, the information would not be considered confidential and would not raise
a question of confidentiality. However, to the extent that the information firms submit to the
Board is not available to the public (or has not yet been made available to the public but will be
published at a later date), the information would qualify as confidential. This confidential
information may be exempt from disclosure by the Board pursuant to exemptions 4 and 8 of the
Freedom of Information Act (FOIA) (5 U.S.C. §§ 552(b)(4) and (b)(8)). Exemption 4 covers
confidential commercial or financial information that is customarily and actually treated as
private by its owner and provided to the government under an assurance of privacy.32 To the
extent that a covered firm does customarily and actually keep the information it submits to the
Board confidential, this information would be exempt from disclosure under exemption 4.
Exemption 8 covers matters 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. Because the information submitted to the Board in the
FR Y-14 is related to the reporting firms’ condition and prepared for the use of the Board, an
agency responsible for the regulation and supervision of financial institutions, the records
containing this information would also be exempt from disclosure under exemption 8.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System with regard to the
proposed FR Y-14A/Q/M revisions aside from what is described below in response to public
comments.

29

12 U.S.C. § 5311(a)(1).
12 U.S.C. § 5365 note.
31
See 79 FR 17240, 17304 (March 27, 2014).
32
See Food Marketing Institute v. Argus Leader Media, 139 S. Ct. 2356, 2364 (2019).
30

24

Public Comments and Adopted Revisions
On June 21, 2024, the Board published an initial notice in the Federal Register (89 FR
52042) requesting public comment for 60 days on the extension, with revision, of the
FR Y-14A/Q/M reports. The proposed revisions to the FR Y-14A/Q/M reports would have
collected more granular information on lending to nondepository financial institutions (NDFIs),
improved the timeliness and coverage of the Board’s collections of counterparty credit risk data,
removed data fields deemed no longer necessary, and made other minor revisions and
instructional clarifications. The comment period for this notice expired on August 20, 2024.
Following the initial notice, the Board received six comment letters. Three comment
letters were from financial industry groups, one comment letter was from a banking organization,
and two comment letters were from organizations associated with small business investment
companies (SBICs).
Following the comment period, Federal Reserve staff met with representatives from
banking organizations, banking industry advocacy groups, and a law firm regarding the comment
letters received on the initial notice. During the meeting, representatives noted their support for
certain aspects of the proposed changes and also reiterated their concerns with certain elements
of the proposal. On May 20, 2026, the Board published a final notice in the Federal Register (91
FR 29485). The Board adopted the proposed revisions, except as discussed below.
General
Implementation Dates
The Board proposed to implement revisions to the FR Y-14Q and FR Y-14M effective
for the September 30, 2024, as of date, and revisions to the FR Y-14A effective for the
December 31, 2024, as of date. Commenters expressed concern with the proposed timeline and
requested that the Board revise the implementation dates to provide firms with sufficient time to
make the required system changes, perform testing, and confirm reporting accuracy. For most
proposed revisions, a commenter noted that implementation time of four quarters from the
publication of the final notice would be adequate.
The Board recognizes the burden associated with regulatory reporting and the importance
of providing firms sufficient time to update reporting systems and perform testing following the
final notice. However, ensuring that data is received in a timely fashion is critical to conduct
supervision and address emerging risks. Notably, several revisions noted as burdensome by
commenters have not been adopted or have been otherwise modified to ease operational burden,
as discussed below. The Board has adopted certain minor revisions or burden reducing revisions
effective for the September 30, 2026, as of date and the remaining revisions effective for the
December 31, 2026, as of date.

25

FR Y-14 Q&A System
To address relevant unaddressed questions on the FR Y-14, the Board encouraged the
submission of comments regarding any aspects of the FR Y-14 instructions that may be unclear.
Additionally, the Board noted that it intended to retire unanswered questions in the Q&A system
that were submitted prior to the publication of the initial notice. One commenter requested
further guidance as to the Board’s intentions with FR Y-14 Q&As in general. The commenter
pointed out that it will continue to be critical for firms to be able to submit questions to the Board
regarding the FR Y-14 and receive timely responses. Additionally, another commenter suggested
that the Board consider changes to its FR Y-14 Q&A process to improve responsiveness and that
the Board consider providing factors for firms to prioritize responses so urgent questions receive
prompt responses.
The Board received 89 outstanding questions related to FR Y-14 reporting. The Board
has since provided responses to 76 of these questions. The Board will consider adopting
additional clarifications related to these questions in future updates to the FR Y-14. Q&As
#Y140001594, #Y140000960, and #Y140001592 have been returned to the firms for
clarification, and the Board expects to address these questions once clarifications have been
received. The remainder of the questions were withdrawn by the firm or were addressed outside
of the FR Y-14 Q&A system due to the nature of the question.
Additionally, the FR Y-14 Q&A system is not the appropriate channel for questions that
do not pertain to an interpretation of reporting requirements. Firms should work with their
Reserve Bank Analyst for questions related to edit checks.
As firms’ relevant previously unaddressed questions have been addressed and this notice
provides additional instructional clarifications, the Board will retire all outstanding questions that
were submitted prior to the initial notice. Unanswered questions submitted since the initial notice
will remain active. The Board understands the importance of providing responses to questions on
FR Y-14 reporting requirements and is committed to improving the timeliness of these
responses. In the absence of a response, firms should report according to their best understanding
of the instructions. At this time, no further process changes will be made to the FR Y-14 Q&A
system and firms will continue to be able to submit questions on the FR Y-14 to the Federal
Reserve. After submitting a question to the Q&A system, firms should notify the Federal
Reserve via email ([email protected]) if a question is urgent or could impact an
upcoming FR Y-14 submission.
Historical Data
The Board proposed to modify the FR Y-14Q historical reporting requirement such that
new reporters, or existing reporters that must begin filing a Retail schedule, would be required to
provide PPNR and Retail historical reports for only the five years preceding the first quarter that
the firms is subject to reporting. One commenter supported this revision and stated that five years
of historical data is appropriately calibrated. Therefore, the Board has adopted this revision
effective for the first reporting period following the publication of this notice.

26

Exploratory Market Shocks
The Board proposed to revise the FR Y-14 instructions to require firms to submit relevant
data with respect to all market shocks that the Board may conduct in a given year, including
exploratory shocks. One commenter noted that the proposed requirements were unclear and
recommended that the Board align this collection with a 2024 supplemental data collection.
Specifically, the commenter stated that firms should not be required to apply exploratory market
shocks to FR Y-14A, Schedule A.1.a, line item 62 (Total Trading and Counterparty Losses) with
respect to trading activity as this line item is dependent on FR Y-14Q, Schedule F (Trading),
which falls outside the scope of the exploratory market shocks. Further, the commenter asked
that the Board conduct no more than two exploratory market shocks per year given the
operational burdens of providing the data and ensure that the as of date for the exploratory
market shock is the same as for the global market shock (GMS). Lastly, the commenter stated
that the FR Y-14Q, Schedule L (Counterparty) data should not be due until April 30.
The Board is cognizant of the burden associated with exploratory market shocks and has
determined that the proposed revision to the FR Y-14 related to exploratory market shocks is not
needed at this time. Therefore, the Board has not adopted this revision.
Loan Modifications to Borrowers Experiencing Financial Difficulty
Consistent with ASU 2022-02, the Board proposed to retire fields that captured troubled
debt restructurings on FR Y-14Q, Schedules H.1 and H.2 and FR Y-14M, Schedules A and B,
and replace them with fields to capture loan modifications to borrowers experiencing financial
difficulty (LMBEFDs). A commenter noted that the FR Y-14 instructions for reporting
LMBEFDs does not align with the FR Y-9C and asked that the Board align the definitions. The
commenter also requested that the revisions related to LMBEFDs are effective for the December
31, 2024, as of date, to align with the FR Y-9C.
For alignment between reports, the Board has revised the FR Y-14 fields related to
LMBEFDs to direct firms to report consistent with the FR Y-9C glossary entry for LMBEFDs.
The Board has adopted this revision for the first reporting period following the publication of
this notice.
FR Y-14 Materiality Threshold Clarification
The Board has received questions as to the materiality threshold calculation for reporting
certain FR Y-14Q and FR Y-14M schedules as respondents have stated there is ambiguity as to
whether the four-quarter average applies to both asset balances and asset balances as a percent of
Tier 1 capital. The Board clarifies that the FR Y-14Q and FR Y-14M materiality thresholds are
determined by the four-quarter average of 1) asset balances or 2) the ratio of asset balances to
Tier 1 capital. The four-quarter average is calculated using the asset balances or ratio of asset
balances to Tier 1 capital as of the end of each of the four most recent quarters. If either
threshold is met, the firm would be required to report the applicable schedule in the following
quarter for the FR Y-14Q. For the FR Y-14M, the firm would be required to report the applicable
schedule starting with the last month of the following quarter.

27

For example, for a firm that is subject to Category I standards, if its asset balances exceed
$5 billion based on a four-quarter average, or if the ratio of its asset balances to Tier 1 capital
exceeds 5 percent based on a four-quarter average, as of June 30, then the firm must file the
applicable schedule for the September reporting date. Firms are responsible for ensuring that
reporting expectations are being met. For existing FR Y-14 filers, the Board does not contact
firms when it must begin reporting a new schedule.
To address questions raised by firms approaching materiality thresholds, the Board has
clarified the calculation in the FR Y-14Q and FR Y-14M instructions.
Other Revisions
The Board proposed to update the instruction for FR Y-14A, Schedule A.7.a, item 36
(Provisions for Unfunded Off-Balance Sheet Credit Exposures) to reference FR Y-9C, Schedule
HI-B, part II, item M7 (Provisions for credit losses on off-balance sheet credit exposures). A
commenter noted that there is a difference in presentation between the FR Y-14A, FR Y-14Q,
and FR Y-9C as to the reporting of provisions for unfunded off-balance sheet credit exposures,
which it recommended the Board address. The commenter also asked that the Board update the
FR Y-9C reference included in FR Y-14Q, Schedule G.1, item 36 (Provisions for Unfunded OffBalance Sheet Credit Exposures). To ensure consistent reporting, the Board has moved the
reporting of the provisions for unfunded off-balance sheet credit exposures to Schedule A.1.a
(Income Statement) to be a component of item 91 (Total provisions during the quarter) on the
FR Y-14A. Additionally, the Board has updated item 36 of Schedule G.1 to reference FR Y-9C,
Schedule HI-B, part II, item M7. The Board has adopted this revision effective for the December
31, 2026, as of date.
The Board did not propose changes related to numeric formatting across the FR Y-14
reports. However, a commenter noted that fields related to loss given defaults (LGDs) and zip
codes have different numeric formatting across schedules. The Board recognizes this
inconsistency and will take this feedback under consideration when determining any future
revisions.
Effective for the March 31, 2024, as of date, the Board revised the FR Y-14 reports to
reflect full CECL implementation. Due to the timing of the initial notice, these changes were not
reflected in the proposed forms and instructions. A commenter noted this and requested that they
be removed. The Board confirms that these changes will remain reflected on the official FR Y-14
forms and instructions moving forward.
Counterparty
Submission of Fourth Quarter Data
The Board proposed to require an unstressed Schedule L submission as of the last
calendar date of the fourth quarter, in addition to the four submissions currently required. A
commenter asked that this revision not be implemented given the associated burden and because

28

there is no meaningful change in the data as of quarter-end as compared to the GMS as of date
submission.
The Board acknowledges the operational burden concerns raised by the commenter and
limited difference in submissions between the GMS as of date and quarter-end. Therefore, the
Board has not adopted the proposed revision.
Reporting of Counterparties Under the Firm-generated Scenario
The Board proposed to require the reporting of a firm’s top 25 counterparties and related
exposures under the firm-generated scenario on FR Y-14Q, Schedule L.5 (Derivatives and
Securities Financing Transactions Profile). A commenter stated that clarification was needed as
to the population of counterparties; specifically, the commenter asked if a counterparty that is
already captured by one of the two existing ranking methodologies must also be included under
the new ranking methodology. The Board confirms that a counterparty is only required to be
reported under one Schedule L.5 ranking methodology. The Board has clarified the instructions
to reduce ambiguity and has adopted this revision effective for the December 31, 2026, as of
date.
Assumptions Associated with the Reporting of CVA Sensitivities
The Board proposed to require the reporting of FR Y-14Q, Schedule L.4 (Aggregate and
Top 10 CVA Sensitivities by Risk Factor) under certain Board-provided assumptions (margin
period of risk of 10 business days, keeping CSA thresholds flat, no gains from netting, and no
credit downgrade triggers). A commenter requested that the Board clarify the definitions of “no
gains from netting” and “keeping CSA thresholds flat” and provide an illustrative example.
Additionally, the commenter asked that the Board include these details in a separate proposal for
an appropriate opportunity for firms to provide feedback, given the potential impact to stress
testing due to these changes.
The Board recognizes the ambiguity of the proposed assumptions “no gains from netting”
and “keeping CSA thresholds flat,” as they do not currently exist elsewhere in the Schedule L
instructions. However, “margin period of risk of 10 days” and “no credit downgrade triggers” are
currently used in reporting certain FR Y-14Q, Schedule L.2 (Expected Exposure Profile by
Counterparty) fields. The Board has determined that implementing just these two assumptions
will achieve the intended outcome of consistent reporting and not require additional clarification.
Lastly, the Board confirms that there are no stress testing methodology changes associated with
this revision. By implementing consistent assumptions, the Board will receive comparable and
higher-quality data from all firms.
The Board has revised the instructions to specify that the CVA sensitivities on Schedule
L.4 are to be reported under the assumptions “margin period of risk of 10 days” and “no gains
from netting.” The Board has adopted this revision effective for the December 31, 2026, as of
date.

29

Netting When Calculating Net CE
The Board proposed to clarify the instructions to describe how a firm can net exposures
when calculating net current exposure for SFTs. The initial notice stated that this would address
questions and issues raised in FR Y-14 Q&As #Y140001627 and #Y140001614. A commenter
pointed out that Q&A #Y140001627 has not been published and therefore commenters cannot
verify if the proposed revision adequately addresses the question. In September 2024, the Board
published the content of #Y140001627 in FR Y-14 Q&A #Y140001698.
Other Revisions
The Board proposed to clarify that firms should use the International Swaps and
Derivatives Association, Inc., publication of the 2013 Standard Credit Support Annex for the
basis of classifying derivatives as SCSA and use Old-CSA for agreements made prior to this
publication. A commenter stated that the proposed instruction language was ambiguous and that
clarification was required as to the relevant date to be used for reporting. To address this possible
ambiguity, the Board has clarified the instructions to reflect that firms should use the date when
the contractual terms become binding. The Board has adopted this revision effective for the
December 31, 2026, as of date.
The Schedule L form that was included in the initial proposal contained two fields related
to the variable payoff of CDS. A commenter pointed out that the Federal Register notice did not
discuss these fields and that the proposed instructions did not provide instructions for how to
report them. Therefore, the commenter requested clarifications and detailed instructions. The
fields were erroneously included in the Schedule L form and the Board has removed them from
the final version.
A commenter reiterated concerns over the reporting of client cleared derivatives
exposures on Schedules L.1-L.4 and requested that they remain out of scope. Additionally, the
commenter stated that FR Y-14 Q&A #Y14001503 has created conflicting guidance regarding
the treatment of client cleared derivatives. The initial notice did not contemplate any revisions
related to the reporting of client cleared derivatives and the Board does not believe #Y14001503
creates conflicting guidance, as it restates the FR Y-14Q instruction’s distinction for reporting
the two types of client-cleared derivative exposures, back-to-back derivatives (considered a
direct exposure) and guaranteed derivatives (an indirect exposure). Only direct exposures for
which a firm computes CVA for its public financial statements should be reported in Schedule
L.1-L.4 regular/unstressed submissions. Direct exposures should be reported in Schedule L.1-L.4
for CCAR/stressed submissions irrespective of the firm’s accounting practice for financial
reporting. Firms should continue to report these exposures in accordance with the FR Y-14
instructions. The Board will consider if additional clarifications are required in the future and
would propose any changes in a Federal Register notice.

30

Wholesale
Reporting Treatment of Nondepository Financial Institutions
The Board proposed to require the reporting of fields 52 through 82 on FR Y-14Q,
Schedule H.1 (Corporate), the “Obligor Financial Data Section,” for NDFIs. The Board received
several comment letters on this proposed revision. One commenter noted that the Obligor
Financial Data section may be overly broad and that there are obligors for which financial data is
not used in the underwriting process or collected from NDFIs on an ongoing basis. The
commenter suggested that the Board add clarifying language to Schedule H.1 such that financial
data is not required in situations in which it is not used in underwriting and credit risk
monitoring. Similarly, the commenter requested that the Board exclude special purpose entities,
special purpose vehicles, and fronting risk facilities from obligor financial data reporting as it
would be burdensome to provide and of minimal supervisory benefit. Another commenter
suggested that the obligor financial data for fronting risk facilities be based on the primary credit
facility obligor to better reflect underwriting practices and ensure consistent reporting.
One commenter stated that the FR Y-14Q collection of NDFI financial data should only
require firms to report financial data that is collected during the underwriting and credit risk
management process to reflect existing market practices. Otherwise, the commenter
recommended that long-term debt and short-term debt only be required if collected by firms on
an ongoing basis, given the sensitive information these fields may reveal about an NDFI’s
activities, and that minimum thresholds be established for reporting certain financial data fields
that may not be material to all NDFIs.
Another commenter expressed strong support for the proposed revisions related to the
collection of NDFI data and, in the spirit of financial stability, that the Board make the data
publicly available and maintain regulatory awareness of possible risks attributable to NDFIs at
banks with total assets below $100 billion.
As the Obligor Financial Data section was constructed to cover a range of obligors and
financial data, the Board understands that every field of the financial data section may not be
pertinent to underwriting and credit risk monitoring for all NDFI obligors. The Board notes that
Section C (Technical Details) of the FR Y-14Q General Instructions states, “If information is not
available or not applicable and no such options are offered, the field should be left blank.” As
such, the Board acknowledges certain fields may not be populated but expects firms to report as
complete data as possible and would engage firms through the supervisory process if pertinent
data is omitted. This language also obviates the need for materiality thresholds, as suggested by
another commenter. Recognizing the commenter’s statements that the items in the financial data
section are generally not applicable for loans to special purpose entities, special purpose
vehicles, and fronting credit facilities, the Board has modified the instructions to exclude these
entities from obligor financial data reporting. Lastly, the Board reiterates that the FR Y-14
reports are confidential supervisory information, and the Board does not expect to disclose
information reported on the FR Y-14Q regarding an individual NDFI’s activities, given the
sensitive nature of this information. The Board has adopted this revision effective for the
December 31, 2026, as of date.

31

To balance regulatory burden and risk coverage, the FR Y-14 respondent panel is firms
with $100 billion or more in total consolidated assets. However, the Board can monitor smaller
firms’ NDFI exposures through the supervisory process and other regulatory reports, such as the
FR Y-9C. If additional data is deemed necessary, the Board may request it from the relevant
firms.
Additionally, the Board proposed to add a “NDFI Obligor Type” field to Schedule H.1 in
which firms would have had multiple options to specify the NDFI type to which the facility was
extended. To ease operational burden, several commenters requested that the Board align the
proposed NDFI categories on the FR Y-14 with those proposed for the Call Report.33 Further, for
consistency, a commenter asked that the Board propose corresponding revisions to the FR Y-9C.
If the FR Y-14 includes NDFI categories beyond the proposed Call Report categories, a
commenter requested that the Board provide definitions and guidance for the FR Y-14-specific
categories. Lastly, commenters asked that the Board align the implementation date across reports
for related NDFI revisions.
The Board understands the value in aligning regulatory reports and aims to do so
whenever possible. To ensure that the FR Y-14 aligns with the FR Y-9C, the Board proposed
revisions that would add the five proposed FR Y-9C NDFI categories as options to Schedule,
H.1, item 26 (Line Reported on FR Y-9C).34 However, these five categories are not sufficiently
granular for stress testing purposes and to ensure that supervisors sufficiently understand the
risks NDFIs may pose to the largest banks. The Board aims to provide clear reporting guidance
and has revised the Schedule H.1 instructions to provide firms detailed information on
classifying the FR Y-14-specific NDFI types and on the proposed “NDFI Obligor Type” field to
address issues raised by commenters. The Board has adopted this revision effective for the
December 31, 2026, as of date.
Reporting of Financial Sponsors
The Board proposed to add three fields to Schedule H.1 to capture whether an obligor is
controlled by a financial sponsor, and, if so, that financial sponsor’s name and legal entity
identifier. The Board received several comments on this revision stating that the proposed fields
are overly broad and suggesting clarifications to improve the consistency of reporting. First,
commenters stated that the proposed instructions are unclear as to whether entities can be
financial sponsors, as opposed to individuals. Second, commenters asserted that the definition of
financial sponsor is overly broad and suggested that the Board adopt a minimum ownership
percentage or narrow the definition to reflect only financial sponsors that have legal authority
over the policies of the obligor. Additionally, a commenter stated that the Board should clarify
how to report an obligor that has more than one financial sponsor and whether financial sponsor
reporting is required for all obligors with a financial sponsor or only for NDFI obligors. Lastly, a
commenter asked whether there are masking considerations for individual financial sponsors as
currently exist elsewhere on the FR Y-14.

33
34

See 88 FR 89489 (December 27, 2023).
See 89 FR 80244 (October 2, 2024).

32

The Board confirms that entities as well as individuals can be considered financial
sponsors, and has revised the instructions for clarity. Relatedly, the Board has revised the
instructions to ensure that information on individuals is masked, consistent with practice in other
portions of the FR Y-14Q. The Board recognizes the ambiguity of the proposed financial sponsor
fields and has implemented a 25 percent minimum ownership threshold, consistent with the
Shared National Credit report, for the purposes of reporting a financial sponsor to address
commenters’ concerns. The Board modified the instructions to reflect that financial sponsor
reporting applies to all corporate obligors, not just NDFIs, and that firms should report the
financial sponsor with the greatest ownership percentage in the case of multiple sponsors.
Finally, the Board modified the instructions to clarify that firms should provide the financial
sponsor as of the reporting date. With these adjustments, the Board has adopted this revision
effective for the December 31, 2026, as of date.
Additional Options for the Reporting of Security Type
The Board proposed to add twelve options to Schedule H.1, item 36 (Security Type)
covering an array of known collateral types. Commenters stated that the Board should provide
definitions for these new options or introduce alternative granularity. The Board understands that
providing additional guidance can be valuable where ambiguity may exist. As with the existing
item 36 options, the Board believes that the proposed options are clear as to their applicability
and instructs firms to report this field to their best understanding. If ambiguity persists, firms
should submit questions with specific details to the FR Y-14 Q&A system. The Board has
adopted this revision effective for the December 31, 2026, as of date.
Reporting of Fee Information
The Board proposed to add five fields to each FR Y-14Q, Schedule H.1 and Schedule H.2
(Commercial Real Estate) to capture facility fee structure. A commenter requested that this
revision not be implemented as fee structures can vary greatly, would present substantial burden
to report consistently, and provide minimal supervisory benefit. Another commenter requested
clarification as to whether amendment and renewal fees should be considered closing fees, and
whether this determination should be tied to the concept of a “major modification” as currently
defined by the “Origination Date” fields.
In light of the comments, the Board has not adopted the proposed items related to fees
collected (as opposed to assessed). However, the Board believes there to be a strong supervisory
benefit to collecting data on assessed closing fees, facility fees, and unused commitment fees as
these can be an important element of a loan’s pricing and economics. If fees are material, the
loan’s interest rate provides an incomplete view of the loan’s compensation structure; therefore,
fee information is critical for supervisors to comprehensively understand a loan’s riskiness. In
addition, information on loan fee structures may help the board improve the accuracy of its
projection of PPNR on loans. As suggested by a commenter, the Board has clarified that the
reporting of renewal and amendment fees as closing fees should be based on major
modifications. The Board has adopted this revision effective for the December 31, 2026, as of
date.

33

Reporting of Collateral Market Value
The Board proposed to modify the instructions of Schedule H.1, item 93 (Collateral
Market Value) to require the reporting of collateral valuations for all facilities with commitments
based on collateral. A commenter stated that the proposed revision did not include sufficient
information regarding required reporting and that further guidance should be provided as to the
scope of reporting and how to report for facilities that do not require periodic valuations of
collateral. The Board has clarified the instructions such that the “Collateral Market Value” field
is required for all facilities that are not reported as “Unsecured” in line item 36 (Security Type).
Additionally, the Board has added guidance to instruct firms to report the value assessed at
origination for facilities that do not undergo ongoing evaluations. The Board has adopted this
revision effective for the December 31, 2026, as of date.
Loan Covenant Violation Information
The Board proposed to add an item to Schedule H.1 to capture if a loan covenant exists,
whether the covenant has been violated, and, if so, whether the agreement has been amended. A
commenter asked that the reporting of covenant information not be adopted as it may not be
reflected in firm financial systems and that ambiguities exist regarding the definition of loan
covenant violations, particularly for non-financial covenants, which could minimize the data’s
benefits. To ensure consistent reporting, another commenter requested that definitions be
provided for each allowable value.
Collecting data on covenants is important as covenant violations can serve as an early
warning signal for loan distress and credit default. By conferring contractual rights to creditors,
covenant violations function similarly to payment defaults but are more frequent and occur well
before actual payment default. Therefore, this information is valuable for credit risk monitoring
and modeling. However, the Board recognizes the commenter’s points on the ambiguity of nonfinancial covenants and associated violations, and has modified the field from what was
proposed to exclude non-financial covenants. The Board has adopted the proposed revision with
this modification, and has added additional guidance on financial covenants and violations to the
instructions to ensure consistent reporting across firms.
Loan Amortization Reporting
The Board proposed to collect data on loan amortization in Schedule H.1. Citing the
burden and minimal benefit of amortization data for corporate loans, a commenter requested that
the Board not adopt this revision. Recognizing the burden and amortization structure of corporate
loans, the Board has determined that this proposed item is not necessary and has not adopted this
revision.
Units of Size for Property Size Reporting
The Board proposed to clarify that square feet should be used when reporting Schedule
H.2, item 39 (Property Size) for healthcare properties. A commenter stated that number of beds
is the industry standard for measuring healthcare properties and suggested that this be reflected

34

on the FR Y-14. To align with industry standards, the Board has revised the instructions to
require “Property Size” to be reported in number of beds for healthcare properties. The Board
has adopted this revision effective for the December 31, 2026, as of date.
Unused Commitments
The Board proposed to update the Schedule H language to clarify which commitments
must be reported. A commenter stated that commitments where the lender is not under any legal
obligation to extend credit or purchase assets should be out of scope for Schedule H. The
proposed revision aimed to align the FR Y-14 language regarding unused commitments with that
of the FR Y-9C, and did not change the scope of the reported commitments. The Board will
consider if changes are necessary to either the FR Y-14 and FR Y-9C and would propose such
changes in a Federal Register notice. Firms should report on Schedule H any unused
commitment that the firm reports in FR Y-9C, Schedule HC-L and that would be reported in one
of the applicable FR Y-9C loan categories if such loan were drawn. The Board has adopted this
revision for the December 31, 2026, as of date.
Other Comments
The Board did not propose any changes to the population of loans that should be reported
on Schedule H.1. However, a commenter requested that the Board exclude non-purpose margin
loans to be consistent with proposed revisions to the Call Report.35 The Board notes that it
proposed and finalized corresponding revisions to the FR Y-9C that would require non-purpose
loans secured predominantly by securities with readily determinable fair value to be reported in
FR Y-9C, Schedule HC-C, item 9.b.(1) (Loans for purchasing or carrying securities).36
Therefore, these loans are not be reported in Schedule H.1, as item 9.b.(1) is not a reportable
category.
The Board did not propose any Schedule H revisions related to CDS hedging. However, a
commenter suggested that the Board add items to Schedule H.1 and Schedule H.2 to indicate if a
loan is hedged via a CDS derivative and the percentage of the loan that is hedged. As indicated
by recent supplemental data collections on synthetic securitizations, the Board is committed to
exploring the impact of risk-mitigating activities and may as a result propose changes to the
FR Y-14 in the future. At this time, the Board is not adopting any revisions to Schedule H that
would capture CDS hedge positions.
Retail
Alignment Between Loan-level and Portfolio-level First Lien Schedules
The Board proposed to add the fields “Total Debt from Loans Involuntarily Terminated,”
“Total Net Recoveries,” and “Total Credit Enhancements Received” to FR Y-14M, Schedule A.2
(Domestic First Lien Closed-end 1-4 Family Residential Portfolio Level Table). Commenters
noted that the proposed fields instruct firms to include real estate owned (REO) loans, but the
35
36

See 88 FR 89489 (December 27, 2023).
See 89 FR 80244 (October 2, 2024) and 90 FR 56756 (December 8, 2025).

35

general instructions for Schedule A instruct firms to exclude REO loans from Schedule A.2,
which the commenters suggested the Board resolve. A commenter also asked that the Board
address the discrepancy between Schedule A.2 and Schedule A.1 (Domestic First Lien Closedend 1-4 Family Residential Loan Level Table) as to the applicable reporting period for the new
fields.
The Board recognizes that, given the exclusion of REO balances from Schedule A.2,
most liquidated loans would not be captured by the proposed additional fields, limiting their
utility. Therefore, in light of the burden associated with reporting additional fields, the Board has
not adopted this proposed revision.
Owner-Occupied Nonfarm Nonresidential Loans
The Board proposed to specify that scored or delinquency managed owner-occupied
nonfarm nonresidential (NFNR) loans, as reported in FR Y-9C, Schedule HC-C, line item
1.3.(1), should be reported on FR Y-14Q, Schedule A.9 (U.S. Small Business). The Board also
proposed to specify that scored owner-occupied NFNR loans be reported as small business loans
(line item 2.b) on FR Y-14Q, Schedule M.1 (Quarter-end Balances) and to add a line item to
FR Y-14Q, Schedule M.2 (FR Y-9C Reconciliation) for scored owner-occupied NFNR loans.
For consistency, the Board proposed to enable the reporting of FR Y-14Q, Schedule K,
Column F (Scored Loans) for line item 7.d.1 (Domestic Owner Occupied NFNR) and clarify that
Column F only applies to owner-occupied NFNR loans. A commenter noted that the proposed
revisions appear to be duplicative and burdensome, while another commenter asked that the
Board clarify whether both scored and delinquency managed loans are to be included in
Schedule A.9, as the proposed instructions only mentioned delinquency managed loans.
The Board confirms that both scored and delinquency managed owner-occupied NFNR
loans should be reported on Schedule A.9 and has revised the instructions to add a reference to
scored loans. Consistent with the nature of Schedule K to address data gaps, the Board confirms
that Column F is only required if the firm does not already report Schedule A.9; therefore, this
revision does not introduce duplicative reporting requirements. The Board has revised the
Schedule K instructions to clarify this expectation. If a firm meets the Schedule A.9 reporting
threshold, it should report its owner-occupied NFNR loans on Schedule A.9 in the same manner
as other small business loans. If the firm does not meet the Schedule A.9 reporting threshold, it
must report its owner-occupied NFNR balances on Schedule K, Column F.
The Board agrees that opening line item 7.d.1 is duplicative, as the same population of
loans is collected by the “No loan category specific line.” To maintain current reporting
processes, the Board has removed this duplication such that firms should continue to report these
loans in the “Not loan category specific” row, as applicable. The Board has adopted this revision
effective for the December 31, 2026, as of date.
Reporting of International and Domestic Credit Card Loans
The Board proposed to define all credit card loans by office location, not borrower
domicile, and to revise the FR Y-14Q retail schedule instructions to clarify that only loans held

36

in foreign offices should be reported on the international sub-schedules. To avoid confusion, the
Board also proposed to add “United States” to Region 1 of the “Geography” field for all
international retail sub-schedules. Given these revisions, a commenter suggested that a
corresponding definition be implemented on the domestic retail sub-schedules and requested
clarification as to how to report international domiciles on FR Y-14Q, Schedule A.2 (U.S. Auto
Loan). Similarly, a commenter noted that the FR Y-14M instructions should be revised to
address loans with respect to property located outside the United States.
To address the commenter’s concerns and accurately capture loans held by domestic
offices to international domiciles, the Board has added an “Other Regions” option to the
“Geography” field of the FR Y-14Q domestic retail sub-schedules. The Board has also clarified
that loans should be classified by office location for purposes of reporting the FR Y-14M and
provided guidance as to how to report international domiciles in the geography fields. The Board
has adopted this revision effective for the December 31, 2026, as of date.
Upon implementation of this revision, FR Y-14 Q&As #Y140000700, #Y140001258,
#Y140001176, and #Y140000994 are no longer relevant and will be updated accordingly.
Revenue and Loss Sharing Agreements
The Board proposed to implement the collection of private credit card revenue- and losssharing agreements (RLSAs) to FR Y-14M, Schedule D (Domestic Credit Card). A commenter
requested that the Board clarify if item 70 (Loss Sharing) on Schedule D.1 only requires the
reporting of accounts that are part of loss-sharing agreements and that item 70 captures the type
of loss sharing agreement to which the account is subject. The commenter also asked that the
Board clarify whether revenue-sharing agreements should be reported in item 45 (All Other
Noninterest Income) on Schedule D.2 and whether dollar amounts reported in item 48 (Other
Loss Share Credits) should include credit losses associated with both loss-sharing agreements
and profit-sharing agreements for which losses are included as part of the calculated profit. The
commenter recommended a new line item be added to Schedule D.2 for purposes of reporting the
dollar amount paid or received with respect to PPNR associated with revenue- or profit-sharing
agreements. Additionally, the commenter asked that the Board make Schedule D.1 and D.2
consistent with respect to reporting RLSA credits and asked whether amounts should be gross,
not net, of sharing credits or payments received. Another commenter asked that the Board clarify
if revenue-sharing agreements are also to be reported, as the proposed instructions only mention
loss-sharing agreements.
The Board has subsequently proposed additional revisions to better capture credit card
revenue and loss sharing agreements for use in the supervisory stress test.37 Therefore, the Board
is not adopting this revision.
Other Comments
The Board proposed to revise the FR Y-14 to remove and replace all references to
LIBOR. Commenters noted that certain fields impacted by this change are origination fields that
37

See 90 FR 51856 (November 18, 2025).

37

are not expected to change, and therefore asked if firms can continue to report LIBOR options
for historical loans that originated with a LIBOR rate. The Board has modified the instructions to
retain the LIBOR-related options for the “ARM Index” fields on FR Y-14M, Schedules A.1 and
B.1. The Board confirms that firms should continue to report LIBOR-related options for loans
that were originated with LIBOR rates. The Board has adopted this revision effective for the
December 31, 2026, as of date.
The Board proposed to clarify that the “Workout Type” fields on FR Y-14M, Schedule
A.1 and B.2 should be left blank if the loan has never been in loss mitigation. A commenter
asked that the Board clarify the difference between reporting “0” and “Null” for these fields. The
Board has clarified the instructions such that “0” is to be used in the month following completion
of a workout plan and that “Null” is to be used in following months or when a loan has never
been subject to loss mitigation. The Board has adopted this revision effective for the December
31, 2026, as of date.
The Board did not propose to retire fields from FR Y-14M, Schedule C (Address
Matching), but a commenter requested that certain fields related to mailing information be
retired. The Board has proposed to retire these fields in a subsequent proposal.38
The Board did not propose changes to FR Y-14M, Schedule B.1, item 95 (Unpaid
Principal Balance (Net)), but a commenter pointed out that the current instructions do not reflect
a FR Y-14 Q&A. Specifically, the commenter noted the Q&A indicated the Board would remove
the language stating that the unpaid principal balance should equal the book value on regulatory
filings. The Board has proposed to remove this language from item 95 in a subsequent
proposal.39
Balances
The Board proposed to create a new FR Y-14Q, Schedule M (Balances) sub-schedule to
collect data on loans and leases covered by shared-loss agreements (SLAs) with the FDIC. A
commenter initially asked that this sub-schedule not be adopted given the time required for
implementation. However, after further consideration, the commenter clarified that they do not
object to the adoption of this sub-schedule. The commenter also stated that the Board should
provide guidance as to how to report unfunded commitments covered by SLAs with the FDIC.
To expand the scope of SLA data, the Board has modified the instructions and template
to collect data on the committed balance (funded plus unfunded balance) of loans covered by
SLAs with the FDIC. The Board also confirms that the sub-schedule is only required from firms
that have SLAs with the FDIC as of the reporting date, as indicated in the instructions. The
Board has adopted this revision effective for the December 31, 2026, as of date.

38
39

See 90 FR 51856 (November 18, 2025).
Id.

38

Trading
Small Business Investment Companies
The Board proposed to add “SBIC Interests” to FR Y-14Q, Schedule F (Trading) as an
industry group to capture funded and unfunded equity interests in SBICs. Commenters generally
expressed support for capturing SBIC exposures separate from other forms of private equity;
however, commenters also suggested that the Board broaden the scope of what is considered an
“SBIC Interest” for Schedule F reporting purposes. Specifically, one commenter argued that all
SBIC interests other than “Participating Security SBICs” be reported in the SBIC industry group,
as opposed to only “Standard Debenture” SBICs. Another commenter stated that the proposed
revision should incorporate non-leveraged SBICs in addition to “Standard Debenture” SBICs.
Additionally, a commenter asked that the Board consider a further adjustment to the SBIC loss
rate in the supervisory stress test, and, to do so, collect the percentage of underlying SBIC
investments that are equity and debt.40
Based on the feedback and data provided by the commenters, the Board has determined
that it is appropriate to collect data on all SBIC types, other than “Participating Security SBICs.”
The Board has added an “SBIC Interests - Other” industry group to Schedule F.24 to capture
exposures to SBICs other than Standard Debenture SBICs and Participating Security SBICs. The
proposed “SBIC Interests” industry group has been renamed “SBIC Interests - Standard
Debenture.” As in all areas of the stress test, the Board will continually monitor and analyze the
data to determine if the SBIC loss rate is appropriately calibrated in the supervisory stress test. If
supplementary data is required in the future, the Board may request it from firms, including the
debt-to-equity split of the fund’s underlying assets. The Board has adopted this revision effective
for the December 31, 2026, as of date.
Other Comments
The Board did not propose any changes to the reporting of non-fair value private equity
investments or seed capital invested in mutual funds and exchange traded funds (ETFs).
However, a commenter stated that the Board should exclude non-fair value private equity
investments from FR Y-14Q, Schedule F.24 (Private Equity) as the macroeconomic scenario is
more appropriate for estimating the stressed losses of these exposures. Similarly, the commenter
asked that seed capital invested in mutual funds and exchange traded funds be excluded from
Schedule F.24, as these funds generally invest in liquid marketable securities and therefore
should not be treated as private equity when estimating stressed loss.
As discussed in the 2025 Supervisory Stress Test Methodology document, private equity
exposures are stressed using the severely adverse macroeconomic scenario. If the Board
determines that additional information is needed to conduct the supervisory stress test, it may
request supplemental data from firms.

40

See the “Private Equity” section of the 2025 Stress Test Methodology
(https://www.federalreserve.gov/publications/files/2025-june-supervisory-stress-test-methodology.pdf) for the
modeling approach for SBIC exposures.

39

The Board will research and monitor the risks posed by seed capital investments in
mutual funds and ETFs and consider the value of any reporting or methodology changes.
Capital
Incremental Submissions
The Board proposed to clarify that a FR Y-14A, Schedule C (Regulatory Capital
Instruments) “Incremental” submission is required if a firm makes a distribution such that the
dollar amount exceeds the firm’s final planned capital distribution, as measured on an aggregate
basis beginning in the fourth quarter of the planning horizon through the quarter at issue, even if
that change is not reflected on Schedule C. A commenter suggested that the Board clarify the
scope of payments to be reported and the process envisioned for Incremental submissions. The
commenter also noted that tracking certain interest expenses or other payments that are
immaterial and establishing a process for reporting may present a burden to firms.
Per the Schedule C instructions, an Incremental submission is required at the time the
firm seeks approval for additional capital distributions pursuant to 12 CFR 225.8(j) or within 15
days after making any capital distribution pursuant to that section, or a capital distribution in
excess of the firm’s final planned capital distribution. Consistent with FR Y-14 Q&A
#Y140001459, the proposed revision sought to clarify that an Incremental submission is required
even if the distribution that exceeds the planned amount is not captured by Schedule C. This
means that, in certain instances, an Incremental submission may be unchanged when compared
to the “Original” or “Adjusted” Schedule C submission. The Board does not intend to collect
data on these distributions outside of Schedule C. The Board has adopted this revision effective
for the December 31, 2026, as of date.
Securities
The Board proposed to revise FR Y-14Q, Schedule B.2, item 15 (ASU 2017-12 ASU
Hedge Designations) to reflect the updated portfolio layer method (PLM) of hedge accounting.
Additionally, the Board proposed to retire Schedule B.2, item 11 (Hedged Cash Flow). A
commenter stated that FR Y-14Q, Schedule B (Securities) does not comprehensively capture
PLM hedges and suggested that the Board introduce a new Schedule B sub-schedule to collect
this information. As mentioned in FR Y-14 Q&A #Y140001696, the current data collection used
to support the securities modeling was designed to capture more traditional hedges and does not
consistently and comprehensively capture PLMs. The Board has since proposed revisions to
Schedule B that would more comprehensively capture data on hedges, including PLMs.41
Therefore, the Board has not adopted the proposed revisions to items 11 and 15.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-14 reports is
761,839 hours, and would increase to 774,828 hours with the revisions. The increase in burden
hours reflects the implementation burden associated with the addition of two firms to the
41

See 90 FR 51856 (November 18, 2025).

40

FR Y-14 reporting panel. These reporting requirements represent approximately 10.3 percent of
the Board’s total paperwork burden.
FR Y-14
Current
FR Y-14A
FR Y-14Q
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Current Total
Proposed
FR Y-14A
FR Y-14Q
FR Y-14M
Implementation
Ongoing automation revisions
Attestation implementation
Attestation ongoing
Proposed Total

Estimated
number of
respondents42

Estimated
annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

35
35
33
0
35

1
4
12
1
1

1,373
1,865
1,049
7,200
480

48,055
261,100
415,404
0
16,800

0
8

1
1

4,800
2,560

0
20,480
761,839

35
35
33
2

1
4
12
1

1,372
1,858
1,048
7,200

48,020
260,120
415,008
14,400

35
0
8

1
1
1

48043
4,800
2,560

16,800
0
20,480
774,828

Change

12,989

42

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. The estimated number of respondents for the
FR Y-14M is lower than for the FR Y-14Q and FR Y-14A because, in recent years, certain respondents to the
FR Y-14A and FR Y-14Q have not met the materiality thresholds to report the FR Y-14M due to their lack of
mortgage and credit activities. The Board expects this situation to continue for the foreseeable future.
43
Because the OASiS submission process is substantially similar to that of Intralinks, that change does not result in
an increase in estimated burden.

41

The estimated total annual cost to the public for the FR Y-14 reports is $56,642,730, and
would increase to $57,608,462 with the revisions.44
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 Y-14 reports is $3,152,900. The estimated one-time cost to implement the revisions is
$111,600.

44

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/.

42