FRY9_20170905_omb

Supporting Statement for the
Financial Statements for Holding Companies
(FR Y-9 family of reports; OMB No. 7100-0128)
Amendments to the Capital Plan and Stress Test Rules; Regulations Y and YY
(Docket No. R-1548; RIN 7100-AE59)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated
authority from the Office of Management and Budget (OMB), proposes to extend for three years,
with revision, the mandatory Financial Statements for Holding Companies (FR Y-9; OMB No.
7100-0128). This family of reports is comprised of the following five reports:
 Consolidated Financial Statements for Holding Companies (FR Y-9C)
 Parent Company Only Financial Statements for Large Holding Companies (FR Y-9LP)
 Parent Company Only Financial Statements for Small Holding Companies (FR Y-9SP)
 Financial Statements for Employee Stock Ownership Plan Holding Companies
(FR Y-9ES)
 Supplement to the Consolidated Financial Statements for Bank Holding Companies
(FR Y-9CS)
Pursuant to the Bank Holding Company Act of 1956, as amended (BHC Act), and the
Home Owners’ Loan Act (HOLA), the Board requires bank holding companies (BHCs), savings
and loan holding companies (SLHCs), securities holding companies (SHCs), and U.S
Intermediate Holding Companies (IHCs) (collectively “holding companies” (HCs)) to provide
standardized financial statements to fulfill the Board’s statutory obligation to supervise these
organizations. HCs file the FR Y-9C and FR Y-9LP quarterly, the FR Y-9SP semiannually, the
FR Y-9ES annually, and the FR Y-9CS on a schedule that is determined when this supplement is
used.
The Board adopted a final rule that revises the capital plan and stress test rules for BHCs
with $50 billion or more in total consolidated assets and U.S. IHCs of foreign banking
organizations. The final rule amends the FR Y-9LP to include new line item 17 of PC-B
Memoranda (Total nonbank assets of a holding company subject to the Federal Reserve Board’s
capital plan rule) for purposes of identifying large and noncomplex firms subject to the capital
plan rule. This amendment will be effective as of March 31, 2017. No changes are proposed for
the FR Y-9C, FR Y-9SP, FR Y-9ES, or FR Y-9CS. The total annual reporting burden for the
proposed FR Y-9 family of reports is estimated to be 195,648 hours, an increase of 63 hours
from the current burden of 195,585 hours.
Background and Justification
The FR Y-9C, FR Y-9LP, and FR Y 9SP serve as standardized financial statements for
the consolidated HC and its parent; the FR Y-9ES is a financial statement for HCs that are
Employee Stock Ownership Plans (ESOPs). The Board also has the authority to use the FR Y-

9CS (a free-form supplement) to collect additional information deemed to be critical and needed
in an expedited manner.
The FR Y-9 family of reporting forms continues to be the primary source of financial
data on HCs that examiners rely on between on-site inspections. Financial data from these
reporting forms are used to detect emerging financial problems, to review performance and
conduct pre-inspection analysis, to monitor and evaluate capital adequacy, to evaluate HC
mergers and acquisitions, and to analyze an HC’s overall financial condition to ensure the safety
and soundness of its operations.
Description of Information Collection
The FR Y-9C consists of standardized financial statements similar to the Call Reports
filed by commercial banks. It collects consolidated data from HCs and is filed by top-tier HCs
with total consolidated assets of $1 billion or more.1
The FR Y-9LP includes standardized financial statements filed quarterly on a parent
company only basis from each HC that files the FR Y-9C. In addition, for tiered HCs, a separate
FR Y-9LP must be filed for each lower-tier HC.
The FR Y-9SP is a parent company only financial statement filed by smaller HCs.
Respondents include HCs with total consolidated assets of less than $1 billion. This report is
designed to obtain basic balance sheet and income data for the parent company, as well as data
on its intangible assets and intercompany transactions.
The FR Y-9ES collects financial data on the benefit plan activities of ESOPs that are also
HCs. It consists of four schedules: a Statement of Changes in Net Assets Available for Benefits,
a Statement of Net Assets Available for Benefits, Memoranda, and Notes to the Financial
Statements.
The FR Y-9CS is a supplemental report that the Board may utilize to collect additional
data deemed to be critical and needed in an expedited manner from HCs. The data are used to
assess and monitor emerging issues related to HCs and the report is intended to supplement the
other FR Y-9 reports, which are used to monitor HCs between on-site inspections. The data
items included on the FR Y-9CS may change as needed.
Proposed Revisions
The Board adopted a final rule that revises the capital plan and stress test rules for BHCs
with $50 billion or more in total consolidated assets and U.S. IHCs of foreign banking
organizations. Under the final rule, large and noncomplex firms (those with total consolidated
assets of at least $50 billion but less than $250 billion, nonbank assets of less than $75 billion,
and that are not U.S. global-systemically important banks) are no longer subject to the provisions

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Under certain circumstances described in the General Instructions, HCs with assets under $1 billion may be
required to file the FR Y-9C.

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of the Board’s capital plan rule whereby the Board may object to a capital plan on the basis of
qualitative deficiencies in the firm’s capital planning process. Accordingly, these firms will no
longer be subject to the qualitative component of the annual Comprehensive Capital Analysis
and Review (CCAR). The final rule also modifies certain regulatory reports to collect additional
information on nonbank assets and to reduce reporting burdens for large and noncomplex firms.
For all bank holding companies subject to the capital plan rule, the final rule simplifies the initial
applicability provisions of both the capital plan and the stress test rules, reduces the amount of
additional capital distributions that a bank holding company may make during a capital plan
cycle without seeking the Board’s prior approval, and extends the range of potential as-of dates
the Board may use for the trading and counterparty scenario component used in the stress test
rules.
The final rule amends the FR Y-9LP to include new line item 17 of PC-B Memoranda
(Total nonbank assets of a holding company subject to the Board’s capital plan rule) for purposes
of identifying large and noncomplex firms subject to the capital plan rule. Under the final rule, a
top-tier holding company that is subject to the Board’s capital plan rule is required to report on
the FR Y-9LP the average dollar amount for the calendar quarter (as calculated on a monthly
basis during the calendar quarter) of its total nonbank assets of consolidated nonbank
subsidiaries, whether held directly or indirectly or held through lower-tier holding companies,
and its direct investments in unconsolidated nonbank subsidiaries, associated nonbank
companies, and those nonbank corporate joint ventures over which the bank holding company
exercises significant influence (collectively, “nonbank companies”). This amendment will be
effective as of March 31, 2017.
Nonbank companies, for purposes of this measure, exclude (1) all national banks, state
member banks, state nonmember insured banks (including insured industrial banks), federal
savings associations, federal savings banks, thrift institutions (collectively for purposes of this
proposed item 17, “depository institutions”) and (2) except for an Edge Act or agreement
corporation designated as “Nonbanking” in the box on the front page of the Consolidated Report
of Condition and Income for Edge and Agreement Corporations (FR 2886b; OMB No. 71000086), any subsidiary of a depository institution (for purposes of this proposed item 17,
“depository institution subsidiary”).
All intercompany assets and operating revenue among the nonbank companies should be
eliminated, but assets and operating revenue with the reporting holding company; any depository
institution; any depository institution subsidiary; and for a reporting holding company that is a
subsidiary of a foreign banking organization, any branch or agency of the foreign banking
organization or any non-U.S. subsidiary, non-U.S. associated company, or non-U.S. corporate
joint venture of the foreign banking organization that is not held through the reporting holding
company, should be included. For example, eliminate the loans made by one nonbank company
to a second nonbank company, but do not eliminate loans made by one nonbank company to the
parent holding company; depository institution; depository institution subsidiary; or for a
reporting holding company that is a subsidiary of a foreign banking organization, any branch or
agency of the foreign banking organization or any non-U.S. subsidiary, non-U.S. associated
company, or non-U.S. corporate joint venture of the foreign banking organization that is not held
through the reporting holding company.

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While the FR Y-9LP collects another measure of nonbank assets (line item 15 of PC-B
Memoranda (Total combined nonbank assets of nonbank subsidiaries)), the new nonbank assets
measure differs in several important ways. Specifically, new line item 17 excludes assets of an
insured industrial bank, federal savings association, federal savings bank, or thrift institution and
includes assets of an Edge or agreement corporation designated as “Nonbanking” in the box on
the front page of the FR 2886b. It also includes the value of an investment in an unconsolidated
nonbank company that is held directly by the holding company. While these elements may be
sourced from other reporting forms, the new line item is necessary to reflect the elimination of
intercompany transactions among these nonbank companies, as described above.
Frequency
The Board proposes no changes to the reporting frequency of the FR Y-9 family of
reports. The current reporting frequencies provide adequate timely data to meet the analytical
and supervisory needs of the Board.
Time Schedule for Information Collection
The FR Y-9C and FR Y-9LP are filed quarterly as of the last calendar day of March,
June, September, and December. The filing deadline for the FR Y-9C is 40 calendar days after
the March 31, June 30, and September 30 as-of dates and 45 calendar days after the
December 31 as of date. The filing deadline for the FR Y-9LP is 45 calendar days after the
quarter end as of date. The FR Y-9SP is filed semiannually as of the end of June and December.
The filing deadline for the FR Y-9SP is 45 calendar days after the as of date. The annual FR Y9ES is collected as of December 31 and the filing deadline is July 31, unless an extension is
granted for filing by October 15.
The data from the FR Y-9 family of reports that are not given confidential treatment are
available to the public on the FFIEC website www.ffiec.gov/nicpubweb/nicweb/NicHome.aspx.
Legal Status
The Board’s Legal Division determined that the FR Y-9 family of reports is authorized
by section 5(c) of the Bank Holding Company Act (12 U.S.C. § 1844(c)), section 10 of Home
Owners’ Loan Act (12 U.S.C.§ 1467a(b)), section 618 of the Dodd-Frank Act (12 U.S.C. §
1850a(c)(1)), section 165 of the Dodd-Frank Act (12 U.S.C. § 5365), and section 252.153(b)(2)
of Regulation YY (12 CFR 252.153(b)(2)). These reports are mandatory. In general, the Board
does not consider the financial data in these reports to be confidential. However, a respondent
may request confidential treatment pursuant to sections (b)(4), (b)(6), and (b)(8) of the Freedom
of Information Act (5 U.S.C. §§ 552(b)(4), (b)(6), and (b)(8)). The applicability of these
exemptions would need to be reviewed on a case by case basis.
Consultation Outside the Agency
On September 30, 2016, the Board published a notice of proposed rulemaking in the
Federal Register (81 FR 67239) for public comment. The comment period for this notice expired

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on November 25, 2016. The Board did not receive any specific comments related to the
Paperwork Reduction Act (PRA) analysis. On February 3, 2017, the Board published a final rule
in the Federal Register (82 FR 9308). The final rule is effective on March 6, 2017.
Estimates of Respondent Burden
The current annual reporting burden for the FR Y-9 family of reports is estimated to be
195,585 hours and would increase to 195,648 hours as shown in the following table. The average
estimated hours per response for FR Y-9LP filers would increase from 5.25 hours to 5.27 hours,
an increase of 0.02 hours associated with the revisions in the final rule. These reporting
requirements represent 1.56 percent of total Federal Reserve System paperwork burden.
Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

654
13
792
4,122
88
236

4
4
4
2
1
4

50.17
51.42
5.25
5.40
0.50
0.50

131,245
2,674
16,632
44,518
44
472
195,585

654
13
792
4,122
88
236

4
4
4
2
1
4

50.17
51.42
5.27
5.40
0.50
0.50

Total

131,245
2,674
16,695
44,518
44
472
195,648

Change

63

Number of
respondents2
Current
FR Y-9C – non AA HCs
FR Y-9C – AA HCs
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Total
Proposed
FR Y-9C – non AA HCs
FR Y-9C – AA HCs
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS

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Of these respondents, 4,132 are considered a small entity (5 FR Y-9C, 562 FR Y-9LP, 3,485 FR Y-9SP, and
80 FR Y-9ES) as defined by the Small Business Administration (i.e., entities with $550 million or less in total
assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-smallbusiness-size-standards.

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The total cost to the public is estimated to increase from $10,737,617 to $10,741,075 for the
revised FR Y-9.3
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 cost to the Federal Reserve System for collecting and processing the FR Y-9 family
of reports is estimated to be $1,922,600 per year.

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Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at
$67, 15% Lawyers at $67, and 10% Chief Executives at $93). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages
May 2016, published March 31, 2017, www.bls.gov/news.release/ocwage.nr0.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

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