FR2320_20141216_omb

Supporting Statement for
the Quarterly Savings and Loan Holding Company Report
(FR 2320; OMB No. 7100-0345)
Summary
The Board of Governors of the Federal Reserve System, under delegated authority from
the Office of Management and Budget (OMB), proposes to extend for three years, without
revision, the mandatory Quarterly Savings and Loan Holding Company Report (FR 2320; OMB
No. 7100-0345). The FR 2320 collects select parent only and consolidated balance sheet and
income statement financial data and organizational structure data from savings and loan holding
companies (SLHCs) exempt from initially filing Federal Reserve regulatory reports. 1
The FR 2320 is used by the Federal Reserve to analyze the overall financial condition of
exempt SLHCs to ensure safe and sound operations. These data assist the Federal Reserve in the
evaluation of a diversified holding company and in determining whether an institution is in
compliance with applicable laws and regulations. The annual burden is estimated to be 180
hours.
Background and Justification
The Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act)
was enacted into law on July 21, 2010. Title III of the Dodd-Frank Act transferred all former
Office of Thrift Supervision (OTS) authorities (including rulemaking) related to SLHCs and their
non-depository subsidiaries to the Board of Governors of the Federal Reserve System on July 21,
2011. Consequently, the Federal Reserve became responsible for the consolidated supervision of
SLHCs beginning July 21, 2011. Previously, all SLHCs continued to submit all OTS regulatory
reports under the OTS SLHC reporting scheme using the existing processing system, the
Electronic Filing System (EFS) established by the OTS, through December 31, 2011. However,
on February 6, 2012, the Board of Governors approved the implementation of the FR 2320 for
exempt SLHCs. The FR 2320 report replaced the OTS Thrift Financial Report (TFR; OMB No.
1557-0255) Schedule HC for these organizations, effective March 31, 2012.
Description of Information Collection
The FR 2320 collects select parent only and consolidated balance sheet and income
statement, financial data (a total of 31 data items) and organizational structure data from SLHCs
exempt from initially filing Federal Reserve regulatory reports. 2

1

An exempt SLHC meets one of the following criteria (1) formed under section 10(c)(9)(C) of the Home Owners’
Loan Act (HOLA) whose saving association subsidiaries’ consolidated assets make up less than 5 percent of the
total consolidated assets of the SLHCs, or (2) its top-tier holding company is an insurance company that only
prepares financial statements using statutory accounting principles.
2
The Federal Reserve regards information submitted in response to line items 24, 25, and 26 as confidential.

Respondent Panel
The respondents include:
(1) grandfathered SLHCs whose:
(a) savings association subsidiaries’ consolidated assets make up less than 5
percent of the total consolidated assets of the grandfathered SLHC on an
enterprise-wide basis as calculated annually as of June 30th, using the four
previous quarters (which includes the quarter-ended June 30th reporting period),
for any of these four quarters; and
(b) where more than 50 percent of the assets of the grandfathered unitary SLHC
are derived from activities that are not otherwise permissible under HOLA on an
enterprise-wide basis as calculated annually as of June 30th, using the assets
reported as of June 30th, OR
(2)
(a) where more than 50 percent of the assets of the SLHC are derived from the
business of insurance on an enterprise-wide basis as calculated annually as of
June 30th, using the assets reported as of June 30th; and
(b) the SLHC does not submit reports to the SEC pursuant to Section 13 or 15(d)
of the Securities Exchange Act of 1934.
The FR 2320 is generally filed by the top-tier SLHC if that SLHC is exempt from filing
the Federal Reserve’s existing regulatory reports. However, if a top-tier SLHC is not required to
file the FR 2320, then a lower-tier SLHC must file the FR 2320. Such determination as to which
SLHC will be required to file the FR 2320 will be made by the appropriate district Federal
Reserve Bank. In addition, lower-tier SLHCs may voluntarily file the FR 2320 or may be
required to file (in addition to the top-tier SLHC) for safety and soundness purposes at the
discretion of the district Federal Reserve Bank.
Time Schedule for Information Collection
The FR 2320 is filed quarterly as of the end of March, June, September, and December,
using the Federal Reserve’s Internet Electronic Submission (IESUB) application. 3 If a SLHC
has a quarter-end other than a calendar quarter-end, data from the fiscal quarter ending within the
calendar quarter may be used to complete the FR 2320. With certain exceptions, micro data are
considered public information and are available through the Board’s Freedom of Information
Office.
Legal Status
The Board’s Legal Division has determined that section 10 of the HOLA, authorize the
Federal Reserve to collect information on the FR 2320. (12 U.S.C. § 1467a(b)(2)), as amended
by Pub. L. No. 111-201, § 369(8).
The Board’s Legal Division has also determined that data items C572, C573, and C574
3

http://www.frbservices.org/centralbank/reportingcentral/index.html

2

on Schedule HC—may be protected from disclosure under exemption 4 of the Freedom of
Information Act (FOIA). Commercial or financial information may be protected from disclosure
under exemption 4 if disclosure of such information is likely to cause substantial competitive
harm to the provider of the information. See 5 U.S.C. § 552(b)(4); National Parks &
Conservation Ass’n v. Morton, 498 F.2d 765 (D.C. Cir. 1974). The data items listed above
pertain to new or changed pledges, or capital stock of any subsidiary savings association that
secures short-term or long-term debt or other borrowings of the SLHC; changes to any class of
securities of the SLHC or any of its subsidiaries that would negatively impact investors; and
defaults of the SLHC or any of its subsidiaries during the quarter. Disclosure of this type of
information is likely to cause substantial competitive harm to the SLHC providing the
information and thus this information may be protected from disclosure under FOIA
exemption 4.
With regard to the remaining data items on Schedule HC, the Board’s Legal Division has
determined that institutions may request confidential treatment for any FR 2320 data item or for
all FR 2320 data items, and confidential treatment will be reviewed on a case-by-case basis.
Consultation Outside the Agency
On September 24, 2014, the Federal Reserve published a notice in the Federal Register
(79 FR 57101) requesting public comment for 60 days on the extension, without revision, of the
Quarterly Savings and Loan Holding Company Report. The comment period for this notice
expired on November 24, 2014. The Federal Reserve did not receive any comments. On
December 15, 2014, the Federal Reserve published a final notice in the Federal Register (79 FR
74088).
Estimate of Respondent Burden
The annual burden for the FR 2320 is estimated to be 180 hours as shown in the
following table. The estimated hours per response is based on the hourly estimate previously
associated with Schedule HC. The Federal Reserve believes this estimate is reasonable given
that no changes are proposed to the data items to be collected. The FR 2320 reporting
requirements represent less than 1 percent of the total Federal Reserve System paperwork
burden.

FR 2320

Number of
respondents

Estimated
annual
frequency

Estimated
average hours
per response

18

4

2.5

Estimated
annual
burden hours
180

The current annual cost to the public of these reports is estimated to be $9,162. 4
4

Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual

3

Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The annual cost to the Federal Reserve System for this report is estimated to be $93,900

burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$61, 15% Lawyers at $63, and 10% Chief Executives at $86). Hourly rate for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
2013, www.bls.gov/news.release/ocwage.nr0.htm Occupations are defined using the BLS Occupational
Classification System, www.bls.gov/soc/.

4