FRY9_20180328_omb

Supporting Statement for the
Financial Statements for Holding Companies
(FR Y-9 family of reports; OMB No. 7100-0128)
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 following mandatory reports:
 Consolidated Financial Statements for Holding Companies
(FR Y-9C; OMB No. 7100-0128),
 Parent Company Only Financial Statements for Large Holding Companies
(FR Y-9LP; OMB No. 7100-0128), and
 Parent Company Only Financial Statements for Small Holding Companies
(FR Y-9SP; OMB No. 7100-0128).
The Board proposes to extend for three years, without revision, the other forms that make
up the FR Y-9 family of reporting forms. These include:
 Financial Statements for Employee Stock Ownership Plan Holding Companies
(FR Y-9ES; OMB No. 7100-0128) and
 Supplement to the Consolidated Financial Statements for Holding Companies
(FR Y-9CS; OMB No. 7100-0128).
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 proposes a number of revisions to the FR Y-9C requirements, most of which
are consistent with the changes to the Federal Financial Institutions Examination Council
(FFIEC) Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041,
and FFIEC 051; OMB No. 7100-0036).1 The revisions to the FR Y-9C include deletions of data
items, consolidations of existing data items into new data items, reductions in reporting
frequency, and new and revised reporting thresholds for certain data items.
The Board proposes changes to the reporting form and instructions on the FR Y-9C,
FR Y-9LP, and FR Y-9SP to implement accounting changes pertaining to equity securities under
Accounting Standards Update (ASU No. 2016-01, “Recognition and Measurement of Financial
Assets and Financial Liabilities”). These revisions are consistent with the changes to the Call
Report and are effective for reports reflecting the March 31, 2018, report date.
1

See 83 FR 939 (January 08, 2018).

The accounting changes pertaining to equity securities are effective beginning with the
reports reflecting the March 31, 2018, report date and June 30, 2018, for all other changes.
There are no changes to the FR Y-9ES or FR Y-9CS. A copy of the reporting forms, marked to
show the revisions, is provided in the attachment. As revised, the total annual reporting burden
for the FR Y-9 family of reports is estimated to be 181,531 hours, a decrease of 5,278 hours from
the current burden of 186,809 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 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 (1) critical and (2) 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. For example, financial data
from these reporting forms is 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 a 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 quarterly by toptier HCs with total consolidated assets of $1 billion or more.2
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 semiannually 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,
data on intangible assets, and data on intercompany transactions.
The FR Y-9ES collects financial data annually from ESOPs that are also HCs on their
benefit plan activities. 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
2

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

2

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 proposes a number of revisions to the FR Y-9C reporting requirements that
are consistent with recent changes to the Call Report (effective March 31, 2018, and June 30,
2018). Industry has often cited the importance of the alignment of the Call Report and FR Y-9C.
As discussed below, the changes to the Call Report resulted from an extensive analysis of
the uses of the data to include a series of nine surveys conducted over a 19-month period that
began in mid-July 2015 and ended in mid-February 2017. Based on the results of the user
surveys, the Board identified data items to be considered for removal, less frequent collection,
and new or revised reporting thresholds to reduce burden. The Board believes that consistent
changes should be made to the FR Y-9C to ensure burden reductions are fully realized.
Additionally, the Board proposes accounting changes pertaining to equity securities reporting.
The changes include:
 Deleting and combining of certain data items pertaining to (1) Goodwill and Other
intangible assets from Schedule HC, Balance Sheet, (2) U.S Government agency
obligations and structured financial products from Schedule HC-B, Securities,
(3) Structured financial products and certain loans and the unpaid principal balance of
such loans on Schedule HC-D, Trading Assets, (4) Certain over-the counter derivatives
on Schedule HC-L, Derivatives and Off-Balance sheet items, and (5) Purchased credit
card relationships and nonmortgage servicing assets from Schedule HC-M, Memoranda,
 Deleting two preprinted captions for other noninterest income on Schedule HI, Income
Statement and certain data items on Schedule HC-D, Trading Assets and Liabilities,
 Deleting Column B (Domestic Office) from Schedule HC-D, Trading Assets and
Liabilities,
 Reducing the reporting frequency from quarterly to semiannual and from quarterly to
annual for certain data items on the FR Y-9C report,
 Increasing and adding reporting thresholds for certain data items in four FR Y-9C
schedules,
 Revising the reporting forms and instructions to implement the reporting of equity
securities under ASU-2016-01, and
 Moving the reporting of “Goodwill” from Schedule HC to Schedule HC-M, Memoranda.
Discussion of Revisions
A. Deletions and Combining of Existing Data Items on the FR Y-9C
Based on the agencies’ five-year burden-reduction review of the Call Report and the
Board’s review of comparable information that HCs are required to report in the FR Y-9C, the
Board no longer needs the current level of detail for this information and has deleted and/or
combined the following data items:

3

(1)

(2)
(3)
(4)

(5)

(6)

(7)

(8)

(9)
(10)
(11)

(12)

(13)

(14)

(15)

(16)

Delete data items:
Delete Schedule HI, Memoranda data items 6(f) and 6(h): Delete net change in the fair
value of financial instruments under a fair value option 6(f) and gains on bargain
purchases 6(h),
Delete Schedule HC-D, column B, for Domestic Offices,
Delete Schedule HC-D, data item 6(a), Column A, Loans secured by real estate. This
information will be reported in the appropriate sub-items on Schedule HC-D,
Delete Schedule HC-D, memoranda item 1(a), column A, pertaining to the Unpaid
principal balance of loans measured at fair value for loans secured by real estate. This
information will be reported in the appropriate sub-items on Schedule HC-D,
Delete Schedule HC-D, memoranda item 6, on retained beneficial interests,
Delete and combine data items:
Delete Schedule HC, data items 10(a) and 10(b) Goodwill and Other intangible Assets:
Combine these two items into single item 10, Intangible Assets and include Goodwill as a
separate item on Schedule M, Memorandum item 12(b),
Delete Schedule HC-B, data items 2(a) and 2(b), columns A through D, U.S. Government
Agency Obligations issued by U.S government agencies and issued by U.S Government
sponsored agencies: Combine into new data item 2, U.S Government Agency
Obligations,
Delete Schedule HC-B, data items 5(b)(1) through 5(b)(3), columns A through D,
Structured financial products (cash, synthetic, and hybrid): Combine into new data item
5(b), Structured financial products,
Schedule HC-D, data items 5(a)(1) through 5(a)(3), Structured financial products (cash,
synthetic, and hybrid): Combine into new data item, 5(a), Structured financial products,
Delete Schedule HC-D, 6(a)(1), 6(a)(2), 6(a)(4) and 6(a)(5), on Loans secured by real
estate: Combine in new data item 6(a)2, All other loans secured by real estate,
Delete Schedule HC-D, data items 6(a)(3)(a) through 6(a)(3)(b)(ii), on certain residential
loans: Combine into new data item 6(a)(1), Loans secured by 1-4 family residential
properties,
Delete Schedule HC-D, data items 6(c)(1) through 6(c)(4), on certain consumer loans:
Combine into new data item 6(c), Loans to individuals for household, family, and other
personal expenditures,
Delete Schedule HC-D, memoranda items 1(a)(1), 1(a)(2), 1(a)(4), and 1(a)(5), on the
Unpaid Principal balance of loans measured at fair value: Combine into new memo item
1(a)(2), All other loans secured by real estate,
Delete Schedule HC-D, memoranda items 1(a)(3)(a) through 1(a)(3)(b)(ii), on the unpaid
principal balance of certain residential loans measured at fair value: Combine into new
memo item, 1(a)(1), Loans secured by 1-4 family residential properties,
Delete Schedule HC-D, memoranda items 1(c)(1) through 1(c)4, on certain consumer
loans: Combine into new memo item 1(c), Loans to individuals for household, family
and other personal expenditures,
Delete Column B on Schedule HC-L, data items 15(a) through 15(b)(8), pertaining to
Monoline Financial Guarantors: Consolidate this information into column E,
Corporations and all other Counterparties, and

4

(17) Delete Schedule HC-M, data item 12(b), on purchased credit card relationships and
nonmortgage servicing assets: Combine in HC-M, data item 12(c), All other identifiable
intangible assets.
B. Changes in Existing Reporting Frequency on the FR Y-9C
The Board has reduced the frequency of certain data items from quarterly to semiannual
(June 30 and December 31 only) and from quarterly to annual (December only) as the Board no
longer needs this data in the FR Y-9C report as frequently. The revisions include the following:
Semiannual Reporting
(1) Schedule HI, memoranda item 16, on Noncash income from negative amortization on
closed-end loans
(2) Schedule HC-B, memoranda item 3, on the amortized cost of held-to maturity securities
sold or transferred to available-for-sale or trading securities
(3) Schedule HC-C, memoranda items 5(a) and 5(b), on purchased credit impaired loans
(4) Schedule HC-C, memoranda items 6(a), 6(b), and 6(c), on closed-end loans with negative
amortization features
(5) Schedule HC-C memoranda items 12(a), 12(b), 12(c) and 12(d), on loans and leases held
for investment that acquired in a business combination
(6) Schedule HC-L, data items 1(b)(1) and 1(b)(2), on certain unused credit lines
(7) Schedule HC-N, Past Due and Nonaccrual Loans, Leases, and Other Assets, memoranda
items 7 and 8, pertaining to nonaccrual loans, and memoranda items 9(a) and 9(b), on
purchased credit-impaired loans
Annual reporting
(8) Schedule HC-M, data items 7(a) and 7(b), on captive insurance and reinsurance.
C. New Reporting Thresholds and Increases in Existing Reporting Threshold on the
FR Y-9C
After reviewing the Board’s data needs along with industry comments and feedback
received on the Call Reports requesting a higher threshold for disclosing components of other
noninterest income and other noninterest expense in Schedule HI,3 the Board will increase the
percentage portion of the existing threshold for reporting other noninterest income components
in memoranda items 6(a) through 6(j) and other noninterest expense components in memoranda
items 7(a) through 7(p). The threshold for disclosing components of other noninterest income
and other noninterest expense would be amounts greater than $100,000 that exceed seven percent
of Schedule HI, item 5(l) and item 7(d), respectively.4 This percentage is currently three percent.
The Board considered alternative percentage thresholds of five percent and ten percent. Upon
evaluating the impact of each percentage threshold, the Board determined that a percentage
threshold of seven percent would provide a meaningful reduction in reporting burden without a
loss of data that would be necessary for supervisory or other public policy purposes. The Board
3

See 82 FR 2444 (January 9, 2017).
The Board increased the dollar portion of this reporting threshold from $25,000 to $100,000 effective
September 30, 2016.
4

5

has changed the reporting threshold for reporting information on trading revenues in
Memorandum items 9(a) through 9(e). Currently, these items are completed by holding
companies that reported average trading assets of $10 million or more for any quarter of the
preceding calendar year. The Board has modified the reporting threshold for Memorandum
items 9(a) through 9(e) to instruct that these items be completed by holding companies that
reported total trading assets of $10 million or more for any quarter of the preceding calendar
year, as the Board no longer needs this information from institutions with lower levels of trading
assets.
The Board has added a reporting threshold of $10 billion or more in total assets before
HCs must complete Schedule HC-B, memoranda items 5(a) though 5(f) and 6(a) through 6(g),
columns A through D, as the Board no longer needs this information from HCs with under $10
billion in total assets.
On Schedule HC-D, the Board has changed the reporting threshold for the overall
Schedule so that the Schedule would be applicable to HCs with total trading assets of $10 million
or more in any of the four preceding calendar quarters from the current threshold of $2 million in
average trading assets over this same period. The Board no longer needs to collect this detailed
data from HCs with a lesser amount of trading assets. In addition, the Board has added a
reporting threshold of $10 billion or more in total trading assets before an institution would be
required to complete Memorandum items 2(a) though 5(f) and 7(a) through 10, as the Board no
longer needs this level of detail report from HCs with a lesser amount of trading assets.
On Schedule HC-K, Quarterly Averages, the Board has added a reporting threshold for
data item 4(a) on average trading assets. This item would only need to be completed by HCs
with $10 million or more in total trading assets in any of the four preceding calendar quarters.
This new reporting threshold is consistent with the revised threshold for completing Schedule
HC-D discussed above. The Board no longer needs this information each quarter from HCs with
less than $10 million in trading assets.
On Schedule HC-L, the Board has added a reporting threshold for data item 8, Spot
Foreign Exchange contracts. This item would only need to be completed by HCs with $100
billion or more in total assets because the Board no longer needs this information from HCs with
total assets less than $100 billion.
D. Revised Data Items and Instructions
1. Reporting Revisions to Address Changes in Accounting for Equity Investments on the FR Y9C, FR Y-9LP, and FR Y-9SP.
In January 2016, the Financial Accounting Standards Board (FASB) issued ASU 2016-01,
“Recognition and Measurement of Financial Assets and Financial Liabilities.” In its summary of
this ASU, the FASB described how one of the main provisions of the ASU differs from current
U.S. generally accepted accounting principles (GAAP) as follows:

6

The amendments in this Update supersede the guidance to classify equity
securities with readily determinable fair values into different categories (that is,
trading or available-for-sale) and require equity securities (including other
ownership interests, such as partnerships, unincorporated joint ventures, and
limited liability companies) to be measured at fair value with changes in the fair
value recognized through net income. A holding company’s equity investments
that are accounted for under the equity method of accounting or result in
consolidation of an investee are not included within the scope of this Update.
The FASB further stated in the summary that “an entity may choose to measure equity
investments that do not have readily determinable fair values at cost minus impairment, if any,
plus or minus changes resulting from observable price changes in orderly transactions for the
identical or a similar investment of the same issuer.”
Holding companies must apply ASU 2016-01 for FR Y-9C purposes in accordance with
the effective dates set forth in the ASU. For HCs that are public business entities, as defined in
U.S. GAAP, ASU 2016-01 is effective for fiscal years beginning after December 15, 2017,
including interim periods within those fiscal years. For example, an HC with a calendar year
fiscal year that is a public business entity must begin to apply ASU 2016-01 in its FR Y-9C for
the March 31, 2018, report date. For all other HCs, the ASU is effective for fiscal years
beginning after December 15, 2018, and interim periods within fiscal years beginning after
December 15, 2019. For example, an HC with a calendar year fiscal year that is not a public
business entity must begin to apply ASU 2016-01 in its FR Y-9C Report for December 31, 2019.
One outcome of the change in accounting for equity investments under ASU 2016-01 is
the elimination of the concept of available-for-sale (AFS) equity securities, which are measured
at fair value on the balance sheet with changes in fair value recognized through other
comprehensive income. At present, the historical cost and fair value of AFS equity securities,
i.e., investments in mutual funds and other equity securities with readily determinable fair values
that are not held for trading, are reported in FR Y-9C Schedule HC-B, item 7, columns C and D,
respectively. The total fair value of AFS securities, which includes both debt and equity
securities, is then carried forward to the FR Y-9C report balance sheet and reported in Schedule
HC, item 2(b). In the FR Y-9C report, the total fair value of AFS securities reported in Schedule
HC, item 2(b), also is reported in item 1, column A, of Schedule HC-Q, Assets and Liabilities
Measured at Fair Value on a Recurring Basis. These HCs then report in columns C, D, and E of
item 1 a breakdown of their AFS debt securities by the level in the fair value hierarchy within
which the fair value amounts of these securities fall (Level 1, 2, or 3). Any balance sheet netting
adjustments to these fair value amounts are reported in column B of item 1.
In addition, the total fair value of AFS securities is reported in Schedule HC-R, Part II,
for risk-weighting purposes under the regulatory capital rules. This fair value amount is reported
in Schedule HC-R, Part II, item 2(b), column A, except for the fair value of those AFS securities
that qualify as securitization exposures, which is reported in Schedule HC-R, Part II, item 9(b),
column A. To the extent appropriate under the regulatory capital rules, adjustments to the fair
values reported in column A of items 2(b) and 9(b) are reported in column B. The adjusted
amount in item 2(b) is then allocated to the appropriate risk-weight category in columns C

7

through N. The adjusted amount of AFS securitization exposures in item 9(b) is reported by
risk-weight category in column Q or by risk-weighted asset amount in column T or U based on
the risk-weighting approach or approaches applied by an institution.
At present, the accumulated balance of the unrealized gains (losses) on AFS equity
securities, net of applicable income taxes, that have been recognized through other
comprehensive income is included in accumulated other comprehensive income (AOCI), which
is reported in the equity capital section of the FR Y-9C report balance sheet in Schedule HC,
item 26(b). With the elimination of AFS equity securities on the effective date of ASU 2016-01,
the net unrealized gains (losses) on these securities that had been included in AOCI will be
reclassified (transferred) from AOCI into the retained earnings component of equity capital,
which is reported on the FR Y-9C balance sheet in Schedule HC, item 26(a). After the effective
date, changes in the fair value of (i.e., the unrealized gains and losses on) a HC’s equity
securities that would have been classified as AFS had the previously applicable accounting
standards remained in effect will be recognized through net income rather than other
comprehensive income.
The effect of the elimination of AFS equity securities as a distinct asset category upon a
HC’s implementation of ASU 2016-01 carries over to the regulatory capital rules. Under these
rules, HCs that are eligible to and have elected to make the AOCI opt-out election deduct net
unrealized losses on AFS equity securities from common equity tier 1 capital and include 45
percent of pretax net unrealized gains on AFS equity securities in tier 2 capital. For purposes of
reporting regulatory capital components and ratios in the FR Y-9C, the deduction of these net
unrealized losses is currently effected through the combination of Schedule HC-R, Part I, items
9(a), “LESS: Net unrealized gains (losses) on available-for-sale securities,” and 9(b), “LESS:
Net unrealized loss on available-for-sale preferred stock classified as an equity security under
GAAP and available-for-sale equity exposures.” The inclusion of 45 percent of pretax net
unrealized gains in tier 2 capital currently occurs through the reporting of this percentage of an
HC’s gains in Schedule HC-R, Part I, item 31, “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.” When ASU 2016-01 takes effect and the classification of equity
securities as AFS is eliminated for accounting and reporting purposes under U.S. GAAP, the
concept of unrealized gains and losses on AFS equity securities will likewise cease to exist.
Another outcome of the change in accounting for equity investments under ASU 2016-01
is that equity securities and other equity investments without readily determinable fair values that
are within the scope of ASU 2016-01 and are not held for trading must be measured at fair value
through net income, rather than at cost (less impairment, if any), unless the measurement election
described above is applied to individual equity investments. In general, HCs currently report
their holdings of such equity securities without readily determinable fair values as a category of
other assets in the FR Y-9C report, Schedule HC-F, item 4. The total amount of an HC’s other
assets is reported on the FR Y-9C report balance sheet in Schedule HC, item 11.
At present, AFS equity securities and equity investments without readily determinable
fair values are included in the quarterly averages reported in Schedule HC-K. Holding
companies report the quarterly average for “All other securities” in item 4 of this schedule and

8

this average reflects AFS equity securities at historical cost. A quarterly average for total
consolidated assets is reported in item 5 of Schedule HC-K. Among its uses, average total
consolidated assets serves as the starting point for determining the denominator for the tier 1
leverage ratio under the regulatory capital rules. The quarterly average for total consolidated
assets currently reflects AFS equity securities at the lower of cost or fair value and equity
securities without readily determinable fair values at historical cost.
The Board considered the changes to the accounting for equity investments under ASU
2016-01 and the effect of these changes on the manner in which data on equity securities and
other equity investments is currently reported in the FR Y-9C report. The Board also notes that,
because of the different effective dates for ASU 2016-01 for public business entities and all other
entities, as well as the varying fiscal years across the population of HCs that file FR Y-9C report,
the period over which HCs will be implementing this ASU ranges from the first quarter of 2018
through the fourth quarter of 2020. December 31, 2020, will be the first quarter-end FR Y-9C
report date as of which all HCs would be required to prepare their FR Y-9C reports in
accordance with ASU 2016-01. As a result, the Board will revise the reporting of information on
equity securities and other equity investments in response to the ASU that would be introduced
in the FR Y-9C report effective March 31, 2018, but would not be fully phased in until the FR Y9C reflecting the December 31, 2020, report date. The Board has sought to use footnotes to
instruct institutions about the reporting for equity securities during the extended transition period
instead of adding a number of data items.
The FR Y-9C revisions related to equity securities are as follows:
(1) To provide transparency to the effect of unrealized gains and losses on equity
securities not held for trading on an institution’s net income during the year-to-date reporting
period in Schedule HI, Income Statement, and to clearly distinguish these gains and losses from
the rest of an HC’s income (loss) from its continuing operations, Schedule HI, item 8, would be
revised effective March 31, 2018, by creating new items 8(a), “Income (loss) before unrealized
holding gains (losses) on equity securities not held for trading, applicable income taxes, and
discontinued operations,” and 8(b), “Unrealized holding gains (losses) on equity securities not
held for trading.” In addition to unrealized holding gains (losses) during the year-to-date
reporting period on such equity securities with readily determinable fair values, HCs also would
report in new item 8(b) the year-to-date changes in the carrying amounts of equity investments
without readily determinable fair values not held for trading (i.e., unrealized holding gains
(losses) for those measured at fair value through earnings; impairment, if any, plus or minus
changes resulting from observable price changes for those equity investments for which this
measurement election is made). Existing Schedule HI, item 8, “Income (loss) before applicable
income taxes and discontinued operations,” would be renumbered as item 8(c), and would be the
sum of items 8(a) and 8(b). From March 31, 2018, through September 30, 2020, the instructions
for item 8(b) and the reporting form for Schedule HI would include guidance stating that item
8(b) is to be completed only by HCs that have adopted ASU 2016-01. Institutions that have not
adopted ASU 2016-01 would leave item 8(b) blank when completing Schedule HI. Finally, from
March 31, 2018, through September 30, 2020, the instructions for Schedule HI, item 6(b),
“Realized gains (losses) on available-for-sale securities,” and the reporting form for Schedule HI
would include guidance stating that, for institutions that have adopted ASU 2016-01, item 6(b)

9

includes realized gains (losses) only on AFS debt securities. Effective December 31, 2020, the
caption for item 6(b) would be revised to “Realized gains (losses) on available-for-sale debt
securities.”
(2) In Schedule HC, Balance Sheet, a new item 2(c), “Equity securities with readily
determinable fair values not held for trading,” would be added effective March 31, 2018. From
March 31, 2018, through September 30, 2020, the instructions for item 2(c) and the reporting
form for Schedule HC would include guidance stating that item 2(c) is to be completed only by
HCs that have adopted ASU 2016-01. Holding companies that have not adopted ASU 2016-01
would leave item 2(c) blank. During this period, the instructions for Schedule HC, item 2(b),
“Available-for-sale securities,” would explain that HCs that have adopted ASU 2016 01 should
include only debt securities in item 2(b). Effective December 31, 2020, the caption for item 2(b)
would be revised to “Available-for-sale debt securities” and all HCs would report their holdings
of equity securities with readily determinable fair values not held for trading in item 2(c).
(3) In Schedule HC-B, Securities, item 7, “Investments in mutual funds and other equity
securities with readily determinable fair values,” would be removed effective December 31,
2020. From March 31, 2018, through September 30, 2020, the instructions for item 7 and the
reporting form for Schedule HC-B would include guidance stating that item 7 is to be completed
only by institutions that have not adopted ASU 2016-01. Holding companies that have adopted
ASU 2016-01 would leave item 2(c) blank.
(4) In Schedule HC-F, Other Assets, the caption for item 4 would be changed from
“Equity securities that DO NOT have readily determinable fair values” to “Equity investments
without readily determinable fair values” effective March 31, 2018. The types of equity
securities and other equity investments currently reported in item 4 would continue to be
reported in this item. However, after the effective date of ASU 2016-01 for an HC, the securities
the HC reports in item 4 would be measured in accordance with the ASU.
(5) In Schedule HC-K, Quarterly Averages, the caption for item 1(c), “All other
securities,” would be changed to “All other debt securities and equity securities with readily
determinable fair values not held for trading purposes” effective March 31, 2018. From
March 31, 2018, through September 30, 2020, the instructions for item 4 and the reporting form
for Schedule HC-K would include guidance indicating that, for HCs that have adopted ASU
2016-01, the quarterly average for equity securities with readily determinable fair values should
be based on fair value and, for HCs that have not adopted ASU 2016-01, the quarterly average
for such equity securities (i.e., AFS equity securities) should be based on historical cost.
Effective December 31, 2020, this guidance would indicate that the quarterly average for equity
securities with readily determinable fair values not held for trading should be based on fair value,
which would apply to all HCs. In addition, for Schedule HC-K, item 5, “Total consolidated
assets,” the instructions for this item and the Schedule HC-K reporting form would include
guidance from March 31, 2018, through September 30, 2020, stating that, for purposes of
reporting the quarterly average for total assets:
 Holding companies that have adopted ASU 2016-01 should reflect the quarterly average
for equity securities with readily determinable fair values at fair value and the quarterly
average for equity securities without readily determinable fair values at their balance

10



sheet carrying amounts (i.e., fair value or, if elected, cost minus impairment, if any, plus
or minus changes resulting from observable price changes) and
Holding companies that have not adopted ASU 2016-01 should reflect the quarterly
average for equity securities with readily determinable fair values at the lower of cost or
fair value and the quarterly average for equity securities without readily determinable fair
values at historical cost.

Subsequently, effective December 31, 2020, the instructions for item 5 and the
Schedule HC-K reporting form would indicate that, for equity securities not held for trading, the
quarterly average for total assets should reflect such securities with readily determinable fair
values at fair value and those without readily determinable fair values at their balance sheet
carrying amounts.
(6) In Schedule HC-Q, the caption for item 1, “Available-for-sale securities,” would be
changed to “Available-for-sale debt securities and equity securities with readily determinable fair
values not held for trading purposes” effective March 31, 2018. From March 31, 2018, through
September 30, 2020, the instructions for item 1 and the reporting form for Schedule HC-Q would
include guidance stating that, for HCs that have adopted ASU 2016-01, the amount reported in
item 1, column A, must equal the sum of Schedule HC, items 2(b) and 2(c), and for HCs that
have not adopted ASU 2016-01, the amount reported in item 1, column A, must equal Schedule
HC, item 2(b). Effective December 31, 2020, this guidance would indicate that the amount
reported in item 1, column A, must equal the sum of Schedule HC, items 2(b) and 2(c).
(7) In Schedule HC-R, Part I, Regulatory Capital Components and Ratios, the
instructions for item 9(a) and the Schedule HC-R reporting form would include guidance from
March 31, 2018, through September 30, 2020, stating that, for HCs that have not adopted ASU
2016-01, item 9(a) should include net unrealized gains (losses) on AFS debt and equity securities
and, for HCs that have adopted the ASU, item 9(a) should include net unrealized gains (losses)
on AFS debt securities. During this same period, the instructions for item 9(b) and the Schedule
HC-R reporting form would include guidance indicating that item 9(b) is to be completed only
by HCs that have not adopted ASU 2016-01. Effective December 31, 2020, item 9(b) would be
removed and the caption for item 9(a) would be revised to “LESS: Net unrealized gains (losses)
on available-for-sale debt securities.” In addition, from March 31, 2018, through September 30,
2020, the instructions for Schedule HC-R, Part I, item 31, and the Schedule HC-R reporting form
would include guidance indicating that item 31 is to be completed only by HCs that have not
adopted ASU 2016-01. During this period, HCs that have adopted the ASU would leave item 31
blank. Then, effective December 31, 2020, item 31 would be removed from Schedule HC-R,
Part I.
(8) In Schedule HC-R, Part II, Risk-Weighted Assets, revisions would be made to change
the caption for item 2(b) to “Available-for-sale debt securities and equity securities with readily
determinable fair values not held for trading,” effective March 31, 2018.
The Board has made changes to the FR Y-9LP and FR Y-9SP to mirror the FR Y-9C
reporting revisions related to the accounting for equity investments under ASU 2016-01. The
income statement for these reports will be revised to clearly distinguish between unrealized gains

11

and losses on equity securities not held for trading from the rest of a HC’s income (loss) from its
continuing operations. Additionally, the balance sheet and supplemental schedules for these
reports will also be revised where applicable to distinguish reporting for those HCs that have
adopted the provisions of ASU 2016-01 and those HCs who have not adopted this ASU.
2. Reporting of Goodwill and Intangible assets.
The Board has moved the reporting of goodwill from Schedule HC, item 10(a), to
Schedule HC-M, item 12(b), and combined existing items 10(a) and 10(b) on Schedule HC into
new data item 10, Intangibles Assets. This revision to Schedule HC was requested by a
commenter on the August 2016 Call Report proposal to facilitate institutions’ reporting by
making their Call Report processes more efficient and better focused.5 While the Board believes
the reporting and disclosure of an HC’s goodwill detail is important, the Board is indifferent as
to the location of the information in the FR Y-9C report.
Frequency
The Board has made no changes to the reporting frequency for 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 and Publication
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 asof date. The FR Y-9SP is filed semiannually as of the last calendar day 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 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)), 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.
5

See 82 FR 2444 (January 9, 2017) for discussion of the comments received on the August 2016 Call Report.

12

Consultation Outside the Agency
On January 2, 2018, the Board published an initial notice in the Federal Register (83 FR
123) requesting public comment for 60 days on the proposal to extend, with revision, the FR Y9C, FR Y-9LP, and the FR Y-9SP and to extend, without revision, the FR Y-9ES and the FR Y9CS. The comment period expired on March 5, 2018. The final proposal is unchanged from the
version that went out for public comment, except for the addition of the instructional
clarifications discussed below.
The Board received one comment from a banking association that, while supporting the
Federal Reserve’s efforts to align the FR Y-9 series with the Call Report, recommended that
revisions to the FR Y-9 reports occur only once a year, that those revisions become effective on
March 31, and that the finalization of revisions occur prior to September 30 of the previous year
in order to allow HCs sufficient time to implement the revisions.
In the past, the Board typically has followed a schedule of making revisions only once
per year, generally starting in the March 31 report. However, the proposal was part of a threephase process occurring over the course of the last year to align the FR Y-9 series with the threephase process for the Call Reports. As a result, certain revisions to the FR Y-9 reports made
through the current process have or will become effective with reports reflecting dates other than
March 31. The Board will strive to return to an annual schedule for future revisions, with
revisions becoming effective for the March 31 report, unless the revisions must be implemented
at a different time due to changes in law, regulation, or accounting standards. With respect to the
time HCs are given to implement revisions to the FR Y-9C reports, the Board notes, however,
that it is important to have such changes become effective on the same timeline as changes to the
Call Reports, to prevent inconsistencies between the FR Y-9C reports and the Call Reports. The
Board will strive to provide more lead time for firms to implement revisions to the FR Y-9
reports while also ensuring alignment with the Call Report.
Additionally, the commenter urged the Board to conduct a comprehensive review of all
reports that it requires banks and their affiliates to file, including the identification and removal
of obsolete, overlapping, or unnecessary line items and a review of the threshold indicators (such
as size and complexity) that institutions must meet before they are required to provide data on
various products and activities.
In lieu of conducting a comprehensive review of all reports simultaneously, the Federal
Reserve performs a thorough review of each regulatory report at least every three years as part of
the Paperwork Reduction Act (PRA) review process. The PRA review process led to burdenreducing changes recently, for example, when the Board terminated the FR 2052b, and the Board
recently proposed burden-reducing changes, for example, for the FR Y-8.6 Also, in 2015, the
Federal Reserve raised the asset threshold of its Small Bank Holding Company Policy Statement,
which allows qualifying holding companies to operate with higher levels of debt than would
normally be permitted, from $500 million to $1 billion. The Federal Reserve also raised the
6

The Liquidity Monitoring Report (FR 2052b; OMB No. 7100-0361) and the Bank Holding Company Report of
Insured Depository Institutions’ Section 23A Transactions with Affiliates (FR Y-8; OMB No. 7100-0126).

13

threshold for reporting the FR Y-9C from $500 million to $1 billion. In March 2017, the Board,
together with the Federal Deposit Insurance Corporation (FDIC) and the Office of the
Comptroller of the Currency (OCC) (collectively, the “agencies”), issued a report pursuant to the
Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), which also
included several initiatives to reduce burden. Because the Board’s current process frequently
leads to the types of changes that the commenter suggested could result from a comprehensive
review, the Board will not pursue the approach advocated by the commenter.
The commenter also recommended that the Federal Reserve establish an industry task
force or advisory committee to help identify outdated or overlapping data items in Federal
Reserve reports and identify burdens associated with these reports. In response to this comment,
the Board will continue to offer outreach in connection with significant revisions to the FR Y-9C
reports. Additionally, the Federal Reserve frequently responds to questions from individual
institutions regarding the requirements of the FR Y-9C reports and often addresses issues that
could affect multiple institutions through quarterly correspondence to affected institutions. As
required under the PRA, the Federal Reserve also offers an opportunity for members of the
banking industry to comment on proposed changes to the FR Y-9C report or to make any
additional suggestions for improving, streamlining, or clarifying the FR Y-9C report. As a
result, the Board will not establish an industry task force or advisory committee as advocated by
the commenter.
The commenter further noted that two recent or pending amendments to U.S. Generally
Accepted Accounting Practices (GAAP) would create inconsistencies between the requirements
of the FR Y-9C family of reports and GAAP. These proposals concern accounting for leases
(ASU 2016-02) and pensions (ASU 2017-07).7 The Board will consult with the FDIC and the
OCC regarding these accounting changes.
The commenter noted that the proposal to add a reporting threshold of $10 billion or
more in total trading assets on Schedule HC-D, memorandum items 2 through 10, and the
proposal to add a reporting threshold of $10 million or more in total trading assets in any of the
four preceding calendar quarters on Schedule HC-K, line item 4, should be updated to add
language for meeting the FDIC’s definition of a large or highly complex institution,8 similar to a
Call Report change that is effective, June 30, 2018. The Board will not require institutions that
meet the FDIC’s definition of a large or highly complex institution (that is used for deposit
insurance assessment purposes) to report these items because these data are not needed at the
7

The commenter noted that in the December 31, 2017, FR Y-9C Supplemental Instructions, institutions were
instructed to report the (right-to-use) ROU asset under the new lease accounting standard in Schedule HC, item
6, Premises and fixed assets, and the related lease liability in Schedule HC-M, item 14, Other borrowed
money. The commenter stated that this reporting is inconsistent with GAAP and that the new accounting
standard, operating lease ROU assets and operating lease liabilities should generally not be reported in the
same line as finance lease assets and liabilities because this creates a seemingly unnecessary conflict between
regulatory reporting and U.S. GAAP reporting. Additionally, the commenter noted that guidance pertaining to
the accounting for pension expenses (ASU 2017-07) that became effective January 1, 2018, were not included
in the December 31, 2017, FR Y-9C Supplemental Instructions and that the current instructions on the FR Y9C and the Call Report need to be updated to incorporate the new accounting changes.
8
Schedule RC-O, Memoranda item 6 of the Call Report instructions has detailed information on the FDIC’s
definition of a large or highly complex institution.

14

holding company level; however, the Board will allow these institutions to provide the data on a
voluntary basis if it is easier to be consistent with their Call Report filings. Additionally, the
commenter asked for clarification on whether the proposed $10 billion threshold on Schedule
HC-D, memorandum items 2 through 10, is based on the prior four quarters or a point in time.
The revised draft report form will indicate that this reporting threshold would be based on
trading assets as of the end of each quarter.
The commenter noted several inconsistences on the FR Y-9C instructions when
compared to the Call Report pertaining to the implementation of equity securities and various
other line item discrepancies. The Call Report instructions were updated after the publication of
the FR Y-9 proposal was published. The Board agrees with these changes and has revised the
FR Y-9C family of forms so that they align all applicable line items to the Call Report.
Additional editorial updates to the report form and instructions will be made to address the
comments pertaining to the FR Y-9LP report.
The revisions will be implemented, as proposed, with the changes in response to the
comment noted above. Modifications for all changes would be effective for reports reflecting
the June 30, 2018, report date, except that the modifications for equity securities would be
effective for reports reflecting the March 31, 2018, report date. On March 21, 2018, the Board
published a final notice in the Federal Register (83 FR 12395).
Estimate of Respondent Burden
The current annual reporting burden for the FR Y-9 family of reports is estimated to be
186,809 hours and would decrease to 181,531 hours as shown in the following table. The
average estimated hours per response for non-advanced approaches FR Y-9C filers would
decrease from 49.14 hours to 47.11 hours, a decrease of 2.03 hours associated with the revisions
to the FR Y-9C requirements. The average estimated hours per response for advanced
approaches FR Y-9C filers would decrease from 50.39 hours to 48.36 hours, a decrease of 2.03
hours associated with the revisions to the FR Y-9C requirements. These reporting requirements
represent 1.68 percent of total Federal Reserve System paperwork burden.

15

Estimated
average hours
per response

Estimated
annual burden
hours

Number of
respondents9

Annual
frequency

632
18
780
3,889
80
236

4
4
4
2
1
4

49.14
50.39
5.27
5.40
0.50
0.50

124,226
3,628
16,442
42,001
40
472
186,809

632
18
780
3,889
80
236

4
4
4
2
1
4

47.11
48.36
5.27
5.40
0.50
0.50

Total

119,094
3,482
16,442
42,001
40
472
181,531

Change

(5,278)

FR Y-9
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

The total cost to the public is estimated to decrease from the current level of $10,255,814 to
$9,966,052 for the revised FR Y-9.10
Sensitive Questions
These collections of information contain 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 reports
is estimated to be $2,221,100.
9

Of these respondents, 4,132 are considered small entities (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 less than $550 million in total
assets) www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-smallbusiness-size-standards. Respondent count is as of March 31, 2017, for the FR Y-9C and FR Y-9LP and
December 31, 2016 for the FR Y-9SP. The FR Y-9ES is an estimate based on current NIC structure. The FR Y9CS is based on the last use of the report.
10
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/.

16