The OCC uses the information provided
through the FFIEC 101 to assess and monitor the levels and
components of each institution's risk-based capital requirements
and the adequacy of their capital under the Advanced Capital
Adequacy Framework, which is a significant component of safety and
soundness. The changes include removing two items related to
reporting of credit valuation adjustments (CVA) and exposure
default (EAD), as the agencies no longer need banks to report this
information in those items.
The Office of the
Comptroller of the Currency (OCC) requests approval from the Office
of Management and Budget (OMB) to revise the Federal Financial
Institutions Examination Council (FFIEC) Regulatory Capital
Reporting for Institutions Subject to the Advanced Capital Adequacy
Framework (FFIEC 101) under the emergency clearance provisions of
OMB’s regulations. The revisions to the FFIEC 101 that are the
subject of this request arise from the Economic Growth, Regulatory
Relief, and Consumer Protection Act (EGRRCPA) and have been
approved by the FFIEC, of which the OCC, Board of Governors of the
Federal Reserve System (Board), and Federal Deposit Insurance
Corporation (FDIC) (the agencies) are members. The Board and the
FDIC have also submitted a similar request for OMB review to
request this information from banks under their supervision. The
Federal Deposit Insurance Act (FDI Act) and the International
Lending Supervision Act of 1983 (ILSA) require the agencies to have
risk-based capital requirements and to ensure that banks maintain
adequate capital. The Board uses these data to assess and monitor
the levels and components of each reporting entity’s risk-based
capital requirements and the adequacy of the entity’s capital under
the framework. These data also allow the OCC to evaluate the
quantitative impact and competitive implications of the framework
on individual respondents and on the financial industry. The
reporting schedules also assist banks in understanding expectations
surrounding the system development necessary for implementation and
validation of the framework. The submitted data that is released
publicly also provide other interested parties with information
about banks’ risk-based capital. Finally, the submitted data
supplement on-site examination processes. The agencies propose to
revise the FFIEC 101 to allow institutions subject to the advanced
approaches rule to estimate and report high volatility commercial
real estate (HVCRE) exposures on Schedules B and G of the FFIEC 101
in a manner consistent with section 214 of EGRRCPA. To avoid the
regulatory burden associated with applying different definitions
for HVCRE exposures within a single organization, the agencies
propose to allow an institution subject to the advanced approaches
rule to estimate and report HVCRE exposures on Schedules B and G of
the FFIEC 101 using the definition under section 214 effective for
the June 30, 2018, report date. Institutions may refine their
estimates in good faith as they obtain additional information, but
they will not be required to amend FFIEC 101 reports previously
filed for report dates on or after June 30, 2018, as these
estimates are adjusted. Alternatively, institutions may report
HVCRE exposures in a manner consistent with the current definition
contained in the agencies’ regulatory capital rules, until the
agencies take further action. The current total annual burden for
the FFIEC 101 is estimated to be 37,800 hours and would remain
unchanged based on the proposed revisions.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.