Supporting Statement A

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Supporting Statement for the
Senior Credit Officer Opinion Survey on Dealer Financing Terms
(FR 2034; OMB No. 7100-0325)
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,
without revision, the Senior Credit Officer Opinion Survey on Dealer Financing Terms (SCOOS)
(FR 2034; OMB No. 7100-0325). This voluntary, partially ad hoc survey1 collects qualitative
and limited quantitative information from senior credit officers at responding financial
institutions on (1) stringency of credit terms, (2) credit availability and demand across the entire
range of securities financing and over-the-counter derivatives transactions, and (3) the evolution
of market conditions and conventions applicable to such activities. The FR 2034 survey is
conducted quarterly and contains 79 core questions divided into three broad sections, one
optional question, as well as additional questions on topics of timely interest.
The estimated total annual burden for the FR 2034 is 688 hours. There is no formal
reporting form for this information collection.
Background and Justification
The FR 2034 survey was originally modeled after the long-established Senior Loan
Officer Opinion Survey on Bank Lending Practices (FR 2018; OMB No. 7100-0058), which
provides qualitative information on changes in the supply of, and demand for, bank loans to
businesses and households. The information obtained from the FR 2018, which has been
conducted in different forms since 1964, provides valuable insights on developments in the credit
market and banking developments and informs the formulation of monetary policy.
This information has been particularly valuable in recent years because it has provided
the Board with insight into the effects of financial conditions on the availability of credit to
households and businesses. However, the global financial crisis highlighted that a significant
volume of credit intermediation has moved outside of the traditional banking sector, which is the
primary focus of the FR 2018. In addition, some of the instruments that are commonly used in
connection with such intermediation (including for the financing of securities positions and overthe-counter derivatives) may have functioned as transmission mechanisms for financial distress
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Certain criteria apply to information collections conducted under the Board’s ad hoc clearance process. Such
collections will (1) be reviewed and approved by the Board’s clearance officer and the Division director of the
sponsoring division, (2) display the appropriate OMB control number, expiration date, and PRA statement, (3) be
used only in cases where the obligation to respond is voluntary, (4) be conducted only and exactly as described in
the currently approved OMB submission, (5) involve only subject matter that is non-controversial and that will not
raise concerns for other Federal agencies, (6) include a detailed justification of the effective and efficient statistical
survey methodology that will be used to assess the data collected (if applicable), and (7) collect personally
identifiable information (PII) only to the extent necessary (if collecting sensitive PII (SPII), the collection
instruments must display the appropriate Privacy Act Statement). In addition, the information collection instruments
and respondent burden will be tracked internally and submitted to OMB. The FR 2034 will not be used to
substantially inform regulatory actions or policy decisions.

during the crisis by connecting seemingly separate parts of the financial system.
The Board therefore decided to expand the collection of qualitative information on the
availability of credit and leverage beyond the traditional banking sector to the extension of credit
by dealers. In 2010, the Federal Reserve implemented the FR 2034 to facilitate the regular
collection and analysis of information representing the informed judgment of market participants
on these additional forms of credit extension. Unlike the large domestically chartered
commercial banks and branches and agencies of foreign banks that are respondents to the
FR 2018, the FR 2034 targets respondents representing activities not conducted solely in a bank,
but rather in several different legal entities, focused on the consolidated entity.
Given the Board’s interest in financial stability, the information this survey collects is
critical to the monitoring of credit markets and capital market activity. Information gathered
from the core portion of the survey is also considered by the Federal Open Market Committee
(FOMC) as it sets monetary policy. The information from the ad hoc section of the survey is not
used to substantially inform regulatory actions or policy decisions. This information is not
available from other sources.
Description of Information Collection
The survey contains 79 core questions divided into three broad sections. The first section
focuses on credit terms applicable to counterparties of different types, spanning a variety of
different transactions. The second section contains credit terms applicable to over-the-counter
derivatives counterparties, distinguishing among contracts referencing different underlying
assets. The third section deals with information about the financing terms provided for certain
security positions. The optional question requests feedback on any other issues relating to credit
terms applicable to securities financing transactions and over-the-counter derivatives contracts.
In addition, a small number of ad hoc questions relating to current developments in credit and
capital markets are generally asked.
The Board understands that respondents use information technology to comply with these
provisions. The survey is conducted through Qualtrics, a web interface designed and maintained
by the Statistics Function of the Federal Reserve Bank of New York, with follow-up as necessary
via telephone.
Respondent Panel
The FR 2034 panel comprises up to 25 U.S. banking institutions and U.S. branches and
agencies of foreign banks, the majority of which are affiliated with a Primary Government
Securities Dealer;2 however, other types of respondents, such as other depository institutions,
bank holding companies, or other financial entities, may be surveyed when appropriate. With
respect to respondents that are primary dealers, the panel includes each primary dealer’s
consolidated entity, rather than the dealer itself. Respondents may also include institutions that,
while not primary dealers, play a significant role in over-the-counter derivatives or securities
2

A list of the current Primary Dealers in Government Securities is available at
https://www.newyorkfed.org/markets/primarydealers.html.

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financing activities.
Frequency and Time Schedule
The FR 2034 survey is conducted once each quarter (May, August, November, and
February) by the Statistics Function of the Federal Reserve Bank of New York. The survey is
sent to the panel of respondents a few weeks in advance to review the questions. Once the survey
is officially open, respondents have two weeks to complete it. The Statistics Function
electronically transmits the survey responses to the Board.
Public Availability of Data
The Board tabulates and summarizes the data in the Senior Credit Officer Opinion
Survey on Dealer Financing Terms public release, which is made available on the Board’s
website.3 In addition, selected aggregate survey results may be discussed in Governor’s
speeches, and may be published in Federal Reserve Bulletin articles and in the annual Monetary
Policy Report to Congress.
Legal Status
The FR 2034 is authorized by sections 2A and 12A of the Federal Reserve Act (FRA).
Section 2A of the FRA requires the Board and FOMC maintain long-run growth of the monetary
and credit aggregates commensurate with the economy’s long run potential to increase
production, so as to promote effectively the goals of maximum employment, stable prices, and
moderate long-term interest rates (12 U.S.C. § 225a). Section 12A of the FRA further requires
the FOMC to implement regulations relating to the open market operations conducted by Federal
Reserve Banks with a view to accommodating commerce and business and with regard to their
bearing upon the general credit situation of the country (12 U.S.C. § 263). The Board and FOMC
use the information obtained through the FR 2034 to discharge these responsibilities.
Responding to the FR 2034 is voluntary.
Although the Board discloses aggregate data about the responses it receives to the
FR 2034, it generally does not disclose individual respondent information. To the extent that
information submitted in response to the FR 2034 is made available to the public, it would not be
considered confidential and would not raise a question of confidentiality. However, to the extent
that the information that 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.4 If a respondent 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
3
4

See https://www.federalreserve.gov/data/scoos.htm.
See Food Marketing Institute v. Argus Leader Media, 139 S. Ct. 2356, 2364 (2019).

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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 2034 may be 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 may also be exempt from disclosure under exemption 8.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On January 13, 2025, the Board published an initial notice in the Federal Register (90
FR 2701) requesting public comment for 60 days on the extension, without revision, of the
FR 2034. The comment period for this notice expired on March 14, 2025. The Board did not
receive any comments. The Board adopted the extension, without revision, of the FR 2034 as
originally proposed. On April 30, 2025, the Board published a final notice in the Federal
Register (90 FR 17934).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2034 is 688
hours. Actual respondent burden for this survey would likely vary depending on how many of
the authorized surveys are carried out and on the specific content of each questionnaire.5 The
burden estimate was adjusted up using the standard Board burden calculation methodology.
These reporting requirements represent less than 1 percent of the Board’s total paperwork
burden.
FR 2034
Current

Estimated
number of
respondents6
25

Estimated
Estimated
Estimated
annual
average hours annual burden
frequency per response
hours
4
6.88
688

The estimated total annual cost to the public for the FR 2034 is $49,639.7

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Actual burden underlying the assumed response time varies considerably not only from survey to survey,
depending on the number and nature of the questions, but also among respondents for any one survey.
6
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.
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Total cost to the responding public is estimated using the following formula: total burden hours, multiplied by the
cost of staffing, where the cost of staffing is calculated as a percent of time for each occupational group multiplied
by the group’s hourly rate and then summed (30% Office & Administrative Support at $24, 45% Financial
Managers at $87, 15% Lawyers at $88, and 10% Chief Executives at $126). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2024, published April 2, 2025, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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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 this
survey is $39,200.

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