FR2052a_20180906_omb_emergency

Supporting Statement for the
Complex Institution Liquidity Monitoring Report
(FR 2052a; OMB No. 7100-0361)
Summary
The Board of Governors of the Federal Reserve System (Board), under delegated
authority from the Office of Management and Budget (OMB), has revised the Complex
Institution Liquidity Monitoring Report (FR 2052a; OMB No. 7100-0361) pursuant to its
authority to temporarily approve of a collection of information without providing opportunity for
public comment.1
The FR 2052a collects quantitative information on selected assets, liabilities, funding
activities, and contingent liabilities of certain large financial firms on a consolidated basis and by
material legal entity. Currently, bank holding companies and savings and loan holding
companies subject to the Liquidity Coverage Ratio rule (LCR rule) (U.S. firms) with total
consolidated assets of $50 billion or more and foreign banking organizations (FBOs) with
combined U.S. assets of $50 billion or more submit FR 2052a data, with the frequency based on
the asset size of the firm and whether it has been identified as a Large Institution Supervision
Coordinating Committee (LISCC) firm.
The FR 2052a is used to monitor the overall liquidity profile of institutions supervised by
the Board. These data provide detailed information on the liquidity risks within different
business lines (e.g., financing of securities positions, prime brokerage activities). In particular,
these data serve as part of the Board’s supervisory surveillance program in its liquidity risk
management area and provide timely information on firm-specific liquidity risks during periods
of stress. Analyses of systemic and idiosyncratic liquidity risk issues are then used to inform the
Board’s supervisory processes, including the preparation of analytical reports that detail funding
vulnerabilities.
The Board has temporarily revised the FR 2052a effective immediately to enable
institutions to report certain municipal obligations as high quality liquid assets (HQLA),
consistent with recent changes to the Board’s LCR rule.2 The estimated total annual burden for
the FR 2052a is 717,600 hours and would remain unchanged.
Background and Justification
The financial crisis of 2007 and 2008 highlighted the need for timely data to identify and
monitor liquidity risks at individual firms as well as in aggregate across the financial system.
The FR 2052a was created in 2014 to meet this need. The crisis highlighted the importance of
understanding intra-company flows and exposures within a consolidated institution. Capturing
such flows, particularly within large, systemically important, globally active U.S. banking
1

See 5 CFR part 1320, App.A(1)(a)(3)(A).
See Press Release, Board of Governors of the Federal Reserve System, Agencies issue interim final rule regarding
the treatment of certain municipal securities as high-quality liquid assets (August 22, 2018), available at
www.federalreserve.gov/newsevents/pressreleases/bcreg20180822a.htm.
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institutions, is a focus of the FR 2052a. As a single, consolidated view of a banking organization
is not sufficient to provide meaningful insight into the institution’s liquidity profile, the
FR 2052a gathers data disaggregated by material legal entity (parent company, broker/dealer
entities, bank entities, etc.). These data have contributed to supervisory monitoring efforts and
risk supervision by identifying potential impediments to the movement of liquidity across legal
entities. The FR 2052a report provides sufficient detail to monitor compliance of those
institutions subject to the LCR rule. Furthermore, the collection of these data assists with the
Federal Reserve’s macroprudential supervision. For example, some of the instruments that are
commonly used in conjunction with an institution’s funding and liquidity activities (e.g.,
financing of securities positions) also may have been at the center of stress points during periods
of systemic risk.
Description of Information Collection
Data from the FR 2052a are used to monitor the liquidity profile of and provide detailed
information on the liquidity risks within different business lines within a firm. Data from these
reports serve as part of the Federal Reserve’s supervisory surveillance program in its liquidity
risk management area and provide timely information on firm-specific liquidity risks during
periods of stress.
The FR 2052a includes a data structure that subdivides the three general categories of
inflows, outflows, and supplemental items into 10 distinct data tables. These tables are designed
to stratify the assets, liabilities, and supplemental components of a firm’s liquidity risk profile
based on products that can be described with common data structures, while still maintaining a
coherent framework for liquidity risk reporting.
The FR 2052a report also includes sections covering broad funding classifications by
product, outstanding balance, and purpose, each segmented by maturity date. Generally, each
section can be classified into one of the following categories:
 Section 1: Inflows-Assets: Institutions report assets such as unencumbered assets,
borrowing capacity from central banks or Federal Home Loan Banks (FHLBs),
unrestricted reserve balances at central banks, restricted reserve balances at central banks,
unsettled asset purchases, and forward asset purchases.
 Section 2: Inflows-Unsecured: Institutions report unsecured inflow transactions such as
onshore placement, offshore placements, required nostro balances, excess nostro
balances, outstanding draws on revolving facilities, and other unsecured loans.
 Section 3: Inflows-Secured: Institutions report secured inflow transactions such as
reverse repurchase agreements, securities borrowing transactions, dollar rolls, collateral
swaps, margin loans, other secured loans where the collateral is rehypothecatable, and
other secured loans where the collateral is not rehypothecatable.
 Section 4: Inflows-Other: Institutions report other inflow transactions such as
derivatives receivables, collateral called for receipt, sales in the to-be-announced market,
undrawn committed facilities purchased, lock-up balances, interest and dividends
receivables, a net 30-day derivatives receivables measure, principal payments receivable
on unencumbered investment securities, and other inflow transactions.

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Section 5: Outflows-Wholesale: Institutions report wholesale outflow transactions such
as asset-backed commercial paper single-seller outflows, asset-back commercial paper
multi-seller outflows, collateralized commercial paper, asset-backed securities, covered
bonds, tender option bonds, other asset-backed financing, commercial paper, onshore
borrowing, offshore borrowing, unstructured long-term debt, structured long-term debt,
government supported debt, unsecured notes, structured notes, wholesale certificates of
deposit, draws on committed facilities, free credits, and other unsecured wholesale
outflow transactions.
Section 6: Outflows-Secured: Institutions report secured outflow transactions such as
repurchase agreements, securities lending transactions, dollar rolls, collateral swaps,
FHLB Advances, outstanding secured funding from facilities at central banks, customer
short transactions, firm short transactions, and other secured outflow transactions.
Section 7: Outflows-Deposits: Institutions report deposit outflow transactions such as
transactional accounts, non-transactional relationship accounts, non-transactional nonrelationship accounts, operational accounts, non-operational accounts, operational escrow
accounts, non-reciprocal brokered accounts, affiliated sweep accounts, non-affiliated
sweeps accounts, other product sweep accounts, reciprocal accounts, other third-party
deposits, and other deposit accounts.
Section 8: Outflows-Other: Institutions report other outflow transactions such as
derivatives payables, collateral called for delivery, purchases in the to-be-announced
market, credit facilities, liquidity facilities, retail mortgage commitments, trade finance
instruments, potential derivative valuation changes, loss of rehypothecation rights and
collateral required due to changes in financial condition, excess customer margin,
commitments to lend on margin to customers, interest and dividends payables, a net 30day derivatives payables measure, other outflows related to structured transactions, and
other cash outflow transactions.
Section 9: Supplemental-Informational: Institutions report supplemental information
such as initial margin posted and received, variation margin posted and received,
collateral dispute receivables and deliverables, collateral that may need to be delivered,
collateral that the institution could request to be received, collateral that could be
substituted by the institution or a counterparty, long and short market value of client
assets, gross client wires received and paid, subsidiary liquidity that cannot be
transferred, 23A capacity, outflows or inflows from closing out hedges early, and
potential outflows from non-structured or structured debt maturing beyond 30 days where
the institution is the primary market maker in that debt.
Section 10: Supplemental-Foreign Exchange: Institutions report foreign exchange
information such as foreign exchange spot, forwards and futures, and swap transactions.

All U.S firms with total consolidated assets of $700 billion or more or with assets under
custody of $10 trillion or more, and all FBOs with combined U.S. assets of $250 billion or more,
report data elements denominated in major currencies, while other data elements denominated in
non-major currencies are converted into United States Dollars (USD) and flagged as converted.
All other reporting entities report exclusively in USD by flagging data as converted as
appropriate. All entities that are required to comply with the LCR Rule are considered material
entities for the purpose of the report. The FR 2052a has proven to be a useful tool for Federal

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Reserve staff to monitor the liquidity position of the large financial firms that are required to
complete it.
Adopted Revisions
The Board has revised the FR 2052a report effective immediately. These revisions arise
from the Board’s amendment of the LCR rule in accordance with the Economic Growth,
Regulatory Relief, and Consumer Protection Act (EGRRCPA). As required by section 403 of
EGRRCPA, the Board has amended its LCR rule within 90 days of the enactment of EGRRCPA
to treat investment grade municipal obligations that are liquid and readily-marketable as level 2B
HQLA for purposes of their liquidity regulations. Therefore, the Board has revised the asset
categories in the FR 2052a instructions to enable institutions to report certain municipal
obligations that meet all the requirements for inclusion as HQLA under section 20 of the LCR
rule, as amended.3 Specifically, the Board has amended the Assets Category Table in Appendix
III of the FR 2052a instructions such that the description of the asset classification code “IG2-Q”
is sufficiently inclusive of municipal obligations that may qualify as HQLA under the LCR rule.
In order for the FR 2052a to reflect section 403 of EGRRCPA and the recent
amendments to the LCR rule, the Board cannot comply with the normal clearance process and
still receive the data in a timely manner. Therefore, the Board has determined that the revisions
to the FR 2052a described above must be instituted quickly and public participation in the
approval process would substantially interfere with the Board’s ability to perform its statutory
obligations arising from EGRRCPA.
Time Schedule for Information Collection
FR 2052a data is reported monthly for (1) U.S. firms with $50 billion or more in total
consolidated assets, but less than $700 billion in total consolidated assets and less than $10
trillion in assets under custody and (2) FBOs that are not identified as LISCC firms and have $50
billion or more in combined U.S. assets. Daily reporting is required for (1) U.S. firms with $700
billion or more in total consolidated assets or $10 trillion or more in assets under custody and
(2) FBOs identified as LISCC firms. There are no changes to the time schedule of the FR 2052a
report. The current reporting schedule provides adequate timely data to meet the analytical and
supervisory needs of the Board.
Legal Status
The FR 2052a is authorized pursuant to section 5 of the Bank Holding Company Act
(12 U.S.C. 1844), section 8 of the International Banking Act (12 U.S.C. 3106), and section 165
of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act)
(12 U.S.C. 5365), and is mandatory.
Financial institution information required by the FR 2052a is collected as part of the
Board’s supervisory process. Therefore, such information is entitled to confidential treatment
under exemption 8 of the Freedom of Information Act (FOIA) (5 U.S.C. 552(b)(8)). In addition,
3

See 12 CFR Part 249.20.

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the institution information provided by each respondent would not be otherwise available to the
public and its disclosure could cause substantial competitive harm. Accordingly, it is entitled to
confidential treatment under the authority of exemption 4 of the FOIA (5 U.S.C. 552(b)(4)),
which protects from disclosure trade secrets and commercial or financial information.
Consultation Outside the Agency
The Board consulted with other U.S. regulatory authorities, including the Office of the
Comptroller of the Currency and Federal Deposit Insurance Corporation, in the development of
FR 2052a. In addition, data sharing agreements are being constituted with other U.S. regulatory
agencies with supervisory responsibilities over subject institutions to monitor compliance with
the LCR rule and to ensure there are no redundant data collections. The Board will follow this
temporary approval with a review under normal clearance procedures, during which comments
will be solicited for the typical 60-day period. All comments received on paperwork burden will
be considered in finalizing the collection.
Estimate of Respondent Burden
The current total annual burden for the FR 2052a is estimated to be 717,600 hours and
would remain unchanged. These reporting requirements represent 6.7 percent of the total
Federal Reserve System’s paperwork burden.

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Number of
respondents4

FR 2052a
Monthly
U.S. BHCs and SLHCs with
total consolidated assets ≥ $50
billion but total consolidated
assets < $250 billion and
foreign exposure < $10 billion
and FBOs with U.S. assets ≥
$50 billion but U.S. assets <
$250 billion that are not
identified as LISCC firms

Annual
Frequency

Estimated
average hours
per response

Estimated
annual burden
hours

32

12

120

46,080

U.S. BHCs and SLHCs with
total consolidated assets ≥ $250
billion or foreign exposure >
$10 billion but total
consolidated assets < $700
billion and with < $10 trillion in
assets under custody and FBOs
with U.S. assets ≥ $250 billion
that are not identified as LISCC
firms

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12

120

11,520

Daily
U.S. BHCs and SLHCs with
total consolidated assets ≥ $700
billion or with ≥ $10 trillion in
assets under custody and FBOs
identified as LISCC firms

12

250

220

660,000

Total

717,600

The total cost to the public is estimated to be $40,221,480.5

4

Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $550 million in total assets) www.sba.gov/document/support--table-size-standards.
5
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
$69, 15% Lawyers at $68, and 10% Chief Executives at $94). 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 2017, published March 30, 2018, www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using
the BLS Occupational Classification System, www.bls.gov/soc/.

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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 estimated cost to the Federal Reserve System for collecting and processing the
FR 2052a is $532,800.

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