CECL_20190328_omb

Supporting Statement for the
Adoption of the Current Expected Credit Loss Methodology
(FR 2248; OMB No. 7100-0005),
(FR 2314 and FR 2314S; OMB No. 7100-0073),
(FR 2320; OMB No. 7100-0345),
(FR 2644; OMB No. 7100-0075),
(FR 2886b; OMB No. 7100-0086),
(FR Y-7N and FR Y-7NS; OMB 7100-0125),
(FR Y-8; OMB No. 7100-0126),
(FR Y-9C, FR Y-9LP, and FR Y-9SP; OMB No. 7100-0128), and
(FR Y-11 and FR Y-11S; OMB No. 7100-0244)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), extended for three years, with
revision, the following information collections, effective in 2019 and 2021:
 Domestic Finance Company Report of Consolidated Assets and Liabilities (FR 2248;
OMB No. 7100-0005),
 Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314)
and Abbreviated Financial Statements of Foreign Subsidiaries of U.S. Banking
Organizations (FR 2314S) (OMB No. 7100-0073),
 Quarterly Savings and Loan Holding Company Report (FR 2320; OMB No. 7100-0345),
 Weekly Report of Selected Assets and Liabilities of Domestically Chartered Commercial
Banks and U.S. Branches and Agencies of Foreign Banks (FR 2644; OMB No.
7100-0075),
 Consolidated Report of Condition and Income for Edge and Agreement Corporations
(FR 2886b; OMB No. 7100-0086),
 Financial Statements of U.S. Nonbank Subsidiaries Held by Foreign Banking
Organizations (FR Y-7N) and Abbreviated Financial Statements of U.S. Nonbank
Subsidiaries Held by Foreign Banking Organizations (FR Y-7NS) (OMB No.
7100-0125),1
 Holding Company Report of Insured Depository Institutions’ Section 23A Transactions
with Affiliates (FR Y-8; OMB No. 7100-0126),
 Consolidated Financial Statements for Holding Companies (FR Y-9C), Parent Company
Only Financial Statements for Large Holding Companies (FR Y-9LP), and Parent
Company Only Financial Statements for Small Holding Companies (FR Y-9SP) (OMB
No. 7100-0128),2 and
 Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies
(FR Y-11) and Abbreviated Financial Statements of U.S Nonbank Subsidiaries of U.S.
Holding Companies (FR Y-11S) (OMB No. 7100-0244).
1

This family of reports also contains the Capital and Asset Report for Foreign Banking Organizations (FR Y-7Q;
OMB No.7100-0125), which is not changing.
2
This family of reports also contains the Financial Statements for Employee Stock Ownership Plan Holding
Companies (FR Y-9ES; OMB No. 7100-0128) and Supplement to the Consolidated Statements for Holding
Companies (FR Y-9CS; OMB No. 7100-0128), which are not changing.

The reports identified in this supporting statement collect information pertaining to bank
holding companies (BHCs), savings and loan holding companies (SLHCs), securities holding
companies, and U.S. intermediate holding companies (collectively, holding companies), U.S.
nonbank subsidiaries of foreign banking organizations (FBOs), U.S nonbank subsidiaries of U.S
holding companies, foreign direct and indirect subsidiaries of domestic holding companies,
commercial banks and U.S. branches and agencies of foreign banks, Edge and agreement
corporations (collectively Edge corporations or Edges) and domestic finance companies.
In June 2016, the Financial Accounting Standard Board (FASB) issued Accounting
Standard Update 2016-13 (ASU 2016-13), which introduced the current expected credit loss
methodology (CECL) for estimating allowances for credit losses. ASU 2016-13 broadens the
scope of financial assets for which allowances for credit losses must be estimated. CECL is
applicable to all financial instruments measured at amortized cost (including loans held for
investment (HFI) and held to maturity (HTM) debt securities, investments in leases, and offbalance-sheet credit exposures. See Appendix B for more details on each of the changes to U.S.
generally accepted accounting principles (U.S. GAAP) resulting from ASU 2016-13.
In response to ASU 2016-13, the Board adopted changes to address the revised
accounting standards for the adoption of CECL across all of the reports listed above. The
effective dates for CECL revisions are described below. The reporting changes related to CECL
are tied to the approved regulatory capital rule related to the implementation and capital
transition for CECL (CECL Rule)3 by the Board, Federal Deposit Insurance Corporation (FDIC),
and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) and to the
corresponding CECL revisions to the Consolidated Reports of Condition and Income (Call
Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB No. 7100-0036).4
Additionally, the Board extended for three years, through the normal delegated review
process, certain revisions to the FR Y-9C that the Board previously approved on a temporary
basis.5 Specifically, the Board extended certain revisions to the FR Y-9C instructions pertaining
to the risk-weighting of high volatility commercial real estate (HVCRE) exposures and the
treatment of reciprocal deposits. As described further below, the revisions arose from
Congressional enactment of the Economic Growth, Regulatory Relief, and Consumer Protection
Act (EGRRCPA).
Finally, the Board has (1) clarified the reporting of unrealized holding gains and losses on
equity securities on the FR Y-9C report and (2) made several revisions to the FR 2886b report,
including updating references to applicable capital requirements and revised the eligibility
criteria for reporting the trading schedule and the accounting treatment of equity securities.
These revisions are effective for the March 31, 2019, report date.
The current annual burden for the FR 2314 and FR 2314S is 13,467 hours and would
increase by 1,197 hours with revisions. The current annual burden for the FR 2886b is 1,433
hours and would increase by 219 hours, primarily due to non-CECL related changes. The
3
4
5

See https://www.federalreserve.gov/newsevents/pressreleases/bcreg20181221a.htm.
See 84 FR 4131 (February 14, 2019).
See 83 FR 48990 (September 28, 2018).

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current annual burden for the FR Y-7N and FR Y-7NS is 2,707 hours and would increase by 127
hours. The current annual burden for the FR Y-9 is 110,898 hours and would increase by 61
hours. The current annual burden for the FR Y-11 and FR Y-11S is 13,662 hours and would
increase 1,575 hours. The current annual burden for all other reports would remain unchanged
due to the negligible impact on these reports. For detailed annual burden information on each
report, see the burden tables under the Estimates of Respondent Burden section at the end of this
supporting statement.
Background and Justification
The FR 2248 collects data from a sample of finance companies to follow emerging trends
in household and business credit. It requests balance sheet data on major categories of household
and business receivables and on major liabilities. These data are then used to construct estimates
of household and business credit from the finance company industry and published in the Federal
Reserve’s Consumer Credit (G.19), Finance Companies (G.20), and Financial Accounts of the
United States (Z.1) statistical releases.
The FR 2314 family of reports collects financial information for direct or indirect foreign
bank and nonbank subsidiaries of U.S. state member banks (SMBs), Edge corporations, and
holding companies. These reports gather data on the assets, liabilities, and earnings of such
subsidiaries, and the data are used to monitor the growth, profitability, and activities of these
foreign companies. The data help the Board identify present and potential problems of these
companies, monitor their activities in specific countries, and develop a better understanding of
activities within the international banking industry and within specific institutions. This
information, coupled with information from the Foreign Branch Reports of Condition
(FFIEC 030; OMB No. 7100-0071), provides a picture of the breadth and scope of international
banking operations for U.S. holding companies both individually and in the aggregate.
The FR 2320 report collects financial information and organizational structure data from
SLHCs that are exempt from filing other Federal Reserve regulatory reports (Exempt SLHCs).6
This information 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 FR 2644 is a balance sheet report that is collected from a sample of domestically
chartered commercial banks and U.S. branches and agencies of foreign banks. The data is used
in conjunction with other data to construct estimates of bank credit, sources and uses of bank
funds, and a balance sheet for the entire banking system. These estimates are used to analyze
current banking and monetary conditions. The Board publishes the data in aggregate form in the
weekly H.8 statistical release, Assets and Liabilities of Commercial Banks in the United States,
which is followed closely by other government agencies, the banking industry, the financial
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To be exempt, an SLHC must meet one of the following criteria: (1) the SLHC was formed under section
10(c)(9)(C) of the Home Owners’ Loan Act (HOLA) and the consolidated assets of its saving association
subsidiaries make up less than 5 percent of the total consolidated assets of the SLHC or (2) its top-tier holding
company is an insurance company that only prepares financial statements using statutory accounting principles.

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press, and other users. The H.8 release provides a balance sheet for the banking industry as a
whole, as well as data disaggregated by its large domestic, small domestic, and foreign-related
bank components.
The FR 2886b collects financial data from Edge corporations. The Federal Reserve uses
the FR 2886b data to help plan and target the scope of examinations of Edges and in the
evaluation of applications. Data from the FR 2886b are also used to monitor aggregate
institutional trends, such as growth in assets and the number of offices, changes in leverage, and
the types and locations of customers and to monitor and identify present and potential problems
with Edge corporations. As domestic deposit-taking institutions, banking Edges conduct
activities that affect the nation’s money supply even though they are treated as foreign offices for
most reporting purposes. The Federal Reserve uses the FR 2886b data, in conjunction with data
from the Call Report, in the construction of the monetary aggregates and aggregate statistics on
bank credit, nondeposit funds, and assets and liabilities of commercial banks. In addition, the
Federal Reserve uses the data in the construction of the flow of funds accounts and in the
compilation of structure data on foreign bank activity.
The FR Y-7N and FR Y-7NS collect financial information for U.S. nonbank subsidiaries
held by FBOs other than through a U.S. BHC or bank. The Federal Reserve uses the data
collected by the FR Y-7N and the FR Y-7NS to assess an FBO’s ability to be a continuing source
of strength to its U.S. operations and to determine compliance with U.S. laws and regulations.
The FR Y-7Q is used to collect consolidated regulatory capital and asset information from all
FBOs.
The FR Y-8 report collects information from holding companies in order to monitor
transactions between a subsidiary depository institutions and its parent holding company or other
affiliates. The data collected by the FR Y-8 is used to monitor bank exposures to affiliates and to
ensure insured depository institutions’ compliance with section 23A of the Federal Reserve Act
and the Board’s Regulation W. Additionally, FR Y-8 data on derivative transactions between
insured depository institutions and their affiliates enables supervisory staff to better monitor
trends in inter-affiliate derivative transactions on an aggregate basis. This information, coupled
with enhanced on-site supervision of derivative transactions between insured depository
institutions and their affiliates at large banking organizations, aids the Federal Reserve in
evaluating the effect of derivative transactions between insured depository institutions and their
affiliates.
The FR Y-9C, FR Y-9LP, and FR Y-9SP serve as standardized financial statements for the
consolidated holding company, and the FR Y-9ES is a financial statement for holding companies
that are Employee Stock Ownership Plans (ESOPs). The FR Y-9CS is a free-form supplement
that the Board may use to collect additional information it deems 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 holding companies 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 holding companies mergers and acquisitions, and to

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analyze a holding company’s overall financial condition to ensure the safety and soundness of its
operations.
The FR Y-11 family of reports collects financial information for individual U.S. nonbank
subsidiaries of domestic holding companies. This data is essential for monitoring the
subsidiaries’ potential impact on the condition of the holding company or its subsidiary banks.
The FR Y-11 family of reports is necessary because other data collected by the Board on a
consolidated and parent company only basis does not reveal the extent of problems that may
exist within a holding company’s nonbank subsidiaries because the size and operations of bank
subsidiaries can mask the operations of nonbank subsidiaries in a consolidated report. In
addition to providing information used in the supervision of holding companies, the FR Y-11
family of reports provides information to assist the Board in the formulation of regulations and
supervisory policies
Description of the Information Collection
The FR 2248 is a voluntary report that collects monthly balance sheet and, where
appropriate, off-balance-sheet data on major categories of consumer and business credit
receivables and on major short-term liabilities held or securitized by finance companies. For
quarter-end months (March, June, September, and December) additional asset and liability items
are collected to provide a full balance sheet.
The mandatory FR 2314 consists of an income statement and balance sheet schedules that
collect information on changes in equity capital, the allowance for loan and lease losses, offbalance-sheet data items, loans, and a memoranda section. A parent U.S. banking organization
must file the FR 2314 quarterly, as of the last calendar day of March, June, September, and
December, for its subsidiary if the subsidiary is owned or controlled by a parent U.S. holding
company that has total consolidated assets of $500 million or more as of June 30 of the
preceding year or files the FR Y-9C to meet supervisory needs, or the subsidiary is owned or
controlled by an SMB or an Edge Corporation that has total consolidated assets equal to or
greater than $500 million, and the subsidiary has (1) total assets of $1 billion or more, (2) total
off-balance-sheet activities of $5 billion or more, (3) equity capital of at least 5 percent of the
top-tier organization’s consolidated equity capital, or (4) operating revenue of at least 5 percent
of the top-tier organization’s consolidated operating revenue. The FR 2314 is filed annually, as
of December 31, for each individual subsidiary that does not meet the criteria for filing quarterly
and that has total assets of at least $500 million but less than $1 billion.
The FR 2314S is a mandatory, abbreviated report that collects net income, total assets,
equity capital, and total off-balance-sheet data items. The FR 2314S is filed annually, as of
December 31, for each individual subsidiary that does not meet the criteria for filing the FR 2314
and with assets of at least $250 million but less than $500 million.
The FR 2320 is a mandatory report that collects select balance sheet and income
statement data on a parent only and consolidated basis and supplemental organizational structure
data from Exempt SLHCs. The FR 2320 is filed quarterly by the top-tier Exempt SLHCs.

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The FR 2644 is a voluntary report that collects weekly data on the outstanding amount of
selected balance sheet items, including items on loans, securities, and borrowings, from a sample
of member and nonmember domestically chartered commercial banks and U.S. branches and
agencies of foreign banks. Data collected on this report parallel the quarterly Call Report.
The FR 2886b report is mandatory, and comprises a balance sheet, income statement,
2 schedules reconciling changes in capital and reserve accounts, and 11 supporting schedules.
Banking Edges must file all supporting schedules; investment Edges file only 4 of the 11
supporting schedules.7 Edges must file the FR 2886b report quarterly if their total consolidated
assets exceed $50 million, and must file annually if their total consolidated assets are $50 million
or less.
The FR Y-7N is a mandatory report that consists of an income statement, balance sheet
schedules that collect information on changes in equity capital, changes in the allowance for loan
and lease losses, off-balance-sheet data items, loans, and a memoranda section. All FBOs file
the FR Y-7N quarterly for their significant nonbank subsidiaries. Subsidiaries are defined as
significant if they have total assets of at least $1 billion or off-balance-sheet activities (including
commitments to purchase foreign currencies and U.S. dollar exchange, all other futures and
forwards contracts, option contracts, and the notional value of interest rate swaps, exchange
swaps and other swaps) of $5 billion or more, as of the end of a quarter. FBOs commence
quarterly reporting for these subsidiaries at the end of the quarter in which the subsidiaries meet
the significance threshold. The FR Y-7N is filed annually, as of December 31, for each
individual nonbank subsidiary that does not meet the criteria for filing quarterly and that has total
assets of at least $500 million, but less than $1 billion.
The FR Y-7NS is a mandatory, abbreviated report that collects net income, total assets,
equity capital, and total off-balance-sheet data items. The FR Y-7NS is filed annually, as of
December 31, by top-tier FBOs for each individual nonbank subsidiary that does not meet the
filing criteria for the detailed report and with total assets of at least $250 million, but less than
$500 million.
The FR Y-7Q is a mandatory report that collects consolidated capital and asset
information from all FBOs. Part 1 of the reporting form collects the following information:
tier 1 capital, total risk-based capital, risk-weighted assets, total consolidated assets, total
combined assets of U.S. operations, net of intercompany balances and transactions between U.S.
domiciled affiliates, branches, and agencies, and total U.S. non-branch assets. In addition, FBOs
that have elected to be treated as financial holding companies (FHC) also must provide separate
capital schedules on Part 2 of the FR Y-7Q quarterly for each lower-tier FBO operating a branch,
agency, Edge corporation, or commercial lending company in the United States. The FR Y-7Q
is filed quarterly by FBOs if the top-tier FBO or any FBO in its tiered structure has effectively
elected to be an FHC and by FBOs with total consolidated assets of $50 billion or more,
7

The four supporting schedules that investment and agreement corporations must file are: Trading Assets and
Liabilities; Derivatives and Off-Balance-Sheet Items; Claims on and Liabilities to Related Organizations; and Past
Due and Nonaccrual Loans, Leases, and Other Assets. Institutions are only required to report the Trading Assets and
Liabilities schedule if they report $2 million or more in trading assets in Schedule RC Item 5 in any of the four
preceding quarters.

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regardless of FHC status. The FR Y-7Q is filed annually if the FBO or any FBO in its tiered
structure has not effectively elected to be a FHC and the FBO has total consolidated assets of
less than $50 billion.
The FR Y-8 is a mandatory report filed quarterly by all U.S. top-tier BHCs, IHCs and
SLHCs, and by FBOs that directly own or control a U.S. subsidiary insured depository
institution. If an FBO indirectly controls a U.S. insured depository institution through a
domestic U.S. holding company, the domestic U.S. holding company must file the FR Y-8. A
respondent must file a separate FR Y-8 report for each U.S. insured depository institution it
controls.
The FR Y-9C is a mandatory report that consists of standardized financial statements
similar to the Call Reports filed by commercial banks. It collects consolidated data from holding
companies and is filed quarterly by top-tier holding companies with total consolidated assets of
$1 billion or more.8
The FR Y-9LP is a mandatory report that includes standardized financial statements filed
quarterly on a parent company only basis from each holding company that files the FR Y-9C. In
addition, for tiered holding companies, a separate FR Y-9LP must be filed for each lower-tier
holding company.
The FR Y-9SP is a mandatory parent company only financial statement filed
semiannually by holding companies 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, and
data on its intangible assets and intercompany transactions.
The FR Y-9ES is a mandatory report that collects financial data annually from ESOPs that
are also holding companies on their benefit plan activities. It consists of four schedules:
Statement of Changes in Net Assets Available for Benefits, 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 holding companies. The data
are used to assess and monitor emerging issues related to holding companies, and the report is
intended to supplement the other FR Y-9 reports, which are used to monitor holding companies
between on-site inspections. The data items included on the FR Y-9CS may change as needed.
The FR Y-11 is a mandatory report that consists of an income statement, balance sheet,
schedules that collect information on changes in equity capital, the allowance for loan and lease
losses, off-balance-sheet data items, loans, and a memoranda section. Domestic holding
companies file the FR Y-11 reports for their U.S. nonbank subsidiaries. A top-tier holding
company must file the FR Y-11 quarterly for each nonbank subsidiary that it owns and controls
if the top-tier holding company has total consolidated assets of $500 million or more as of
June 30 of the preceding year or files the FR Y-9C to meet supervisory needs and the subsidiary
8

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

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meets any one of the following criteria: (a) total assets of $1 billion or more, (b) total offbalance-sheet activities of $5 billion or more, (c) equity capital of at least 5 percent of the top-tier
holding company’s consolidated equity capital, or (d) operating revenue of at least 5 percent of
the top-tier holding company’s consolidated operating revenue. The FR Y-11 is filed annually,
as of December 31, by top-tier holding companies for each individual nonbank subsidiary that
does not meet the criteria for filing quarterly and with total assets of at least $500 million, but
less than $1 billion.
The FR Y-11S is an abbreviated report that collects four data items: net income, total
assets, equity capital, and total off-balance-sheet data items. The FR Y-11S is a mandatory
report and is filed annually, as of December 31, by top-tier holding companies for each
individual nonbank subsidiary that does not meet the criteria for filing the FR Y-11 and with
total assets of at least $250 million, but less than $500 million.
Summary of Adopted Revisions
1. Adopted CECL Revisions-ASU 2016-13
Effective Dates for Adopted Revisions
The effective dates for adopting CECL vary depending on whether a firm is a public
business entity (PBE), a Securities and Exchange Commission (SEC) report filer, or an early
adopter. For institutions that are PBEs and also are SEC filers, as both terms are defined in U.S.
GAAP, the new credit losses standard is effective for fiscal years beginning after December 15,
2019, including interim periods within those fiscal years. For a PBE that is not an SEC filer, the
credit losses standard is effective for fiscal years beginning after December 15, 2020, including
interim periods within those fiscal years. For an institution that is not a PBE, the credit losses
standard is effective for fiscal years beginning after December 15, 2020, and for interim period
financial statements for fiscal years beginning after December 15, 2021. For regulatory
reporting purposes, early application of the new credit losses standard will be permitted for all
institutions for fiscal years beginning after December 15, 2018, including interim periods within
those fiscal years. See Appendix A for more details surrounding CECL adoption by entity type,
as well as the table summarizing the possible effective dates.9
Due to the different effective dates for ASU 2016-13, the period over which institutions
may be implementing this ASU ranges from the first quarter of 2019 through the fourth quarter
of 2022. December 31, 2022, will be the first quarter-end of which all institutions would be
required to prepare their reports in accordance with ASU 2016-13. It is expected that the
majority of institutions will implement the standard in the first or fourth quarter of 2021.
Schedule titles or specific data item captions resulting from the change in nomenclature upon the
adoption of CECL generally would not be reflected in the reporting forms until March 31, 2021,

9

See CECL FAQs, question 36, for examples of how and when institutions with non-calendar fiscal years must
incorporate the new credit losses standard into their regulatory reports. The CECL FAQs and a related link to the
joint statement can be found on the Board’s website:
https://www.federalreserve.gov/supervisionreg/srletters/sr1708a1.pdf.

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as outlined in the following schedule-by-schedule descriptions of the changes to the affected
reporting schedules.
Because of the staggered adoption dates, the Board is implementing the CECL revisions
in stages. First, the Board revised the reporting form and instructions, added data items and
schedules for certain impacted reports effective for March 31, 2019. The changes included
guidance stating how institutions that have adopted ASU-2016-13 should report the data items
related to the “provision for credit losses” and “allowance for credit losses, as applicable. Next,
for the transition period from March 31, 2021, through December 31, 2022, the reporting form
and instructions for each impacted schedule title or data item will be updated to include guidance
stating how institutions that have not adopted ASU 2016-13 should report the “provision for loan
and lease losses” or the “allowance for loan and lease losses,” as applicable.
The table below summarizes the effective dates for the 2019 and 2021 CECL revisions.

Report
FR 2644
FR 2248
FR 2320
FR Y-8
FR 2314 and FR 2314S
FR 2886b
FR Y-7N and FR Y-7NS
FR Y-9C
FR Y-9LP
FR Y-11 and FR Y-11S
FR Y-9SP

Add Items, Add,
Footnotes and or Revise
Instructions
03/27/2019
03/31/2019
03/31/2019
03/31/2019
03/31/2019
03/31/2019
03/31/2019
03/31/2019
03/31/2019
03/31/2019
06/30/2019

Revise Item Captions
01/06/2021
01/31/2021

03/31/2021
03/31/2021
03/31/2021
03/31/2021
03/31/2021
03/31/2021
06/30/2021

Adopted CECL Revisions
The Board adopted revisions to all regulatory reports listed in the Summary section in
response to ASU 2016-13 in order to align the information reported with the new standard as it
relates to the credit losses for loans and leases, including off-balance sheet credit exposures.
These revisions address the broadening of the scope of financial assets for which an allowance
for credit losses assessment must be established and maintained, along with the elimination of
the existing model for PCI assets. The revisions for the FR Y-9C are described in detail, mostly
on a schedule-by-schedule basis. The CECL revisions to all the other reports mirror the
revisions to the FR Y-9C, where applicable.
CECL is applicable to all financial instruments carried at amortized cost (including HFI
loans and HTM debt securities as well as trade and reinsurance receivables and receivables that
relate to repurchase agreements and securities lending agreements), net investments in leases,
and off-balance-sheet credit exposures not accounted for as insurance, including loan
commitments, standby letters of credit, and financial guarantees. Under ASU 2016-13,

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institutions will record credit losses through an allowance for credit losses for AFS debt
securities rather than as a write-down through earnings for other-than-temporary impairment
(OTTI). The broader scope of financial assets for which allowances must be estimated under
ASU 2016-13 results in the reporting of additional allowances, and related charge-off and
recovery data and changes to the terminology used to describe allowances for credit losses. To
address the broader scope of assets that will have allowances under ASU 2016-13, the Board
changed the allowance nomenclature to consistently use “allowance for credit losses” followed
by the specific asset type as relevant, e.g., “allowance for credit losses on loans and leases” and
“allowance for credit losses on HTM debt securities.
By broadening the scope of financial assets for which the need for allowances for credit
losses must be assessed to include HTM and AFS debt securities, the new standard eliminates the
existing OTTI model for such securities. Subsequent to a firm’s adoption of ASU 2016-13, the
concept of OTTI will no longer be relevant and information on OTTI will no longer be captured.
The new standard also eliminates the separate impairment model for PCI loans and debt
securities. Under CECL, credit losses on PCD financial assets are subject to the same credit loss
measurement standard as all other financial assets carried at amortized cost. Subsequent to an
institution’s adoption of ASU 2016-13, information on PCI loans will no longer be captured.
While the standard generally does not change the scope of off-balance sheet credit
exposures subject to an allowance for credit loss assessment, the standard does change the period
over which the firm should estimate expected credit losses. For off-balance sheet credit
exposures, a firm will estimate expected credit losses over the contractual period in which they
are exposed to credit risk. For the period of exposure, the estimate of expected credit losses
should consider both the likelihood that funding will occur and the amount expected to be funded
over the estimated remaining life of the commitment or other off-balance sheet exposure. In
contrast to the existing practices, the FASB decided that no credit losses should be recognized
for off-balance sheet credit exposures that are unconditionally cancellable by the issuer. The
exclusion of unconditionally cancellable commitments from the allowance for credit losses
assessment on off-balance sheet credit exposures requires clarification to applicable reporting
instructions.
As of the new accounting standard’s effective date, institutions will apply the standard
based on the characteristics of financial assets as follows:
 Financial assets carried at amortized cost (that are not PCD assets) and net investments in
leases: A cumulative-effect adjustment for the changes in the allowances for credit losses
will be recognized in retained earnings, net of applicable taxes, as of the beginning of the
first reporting period in which the new standard is adopted. The cumulative-effect
adjustment to retained earnings should be reported in FR Y-9C Schedule HI-A, item 2,
“Cumulative effect of changes in accounting principles and corrections of material
accounting errors,” and explained in Notes to the Income Statement for which a
preprinted caption, “Adoption of Current Expected Credit Losses Methodology – ASC
Topic 326,” will be provided in the text field for this item.
 Purchased credit-deteriorated financial assets: Financial assets classified as PCI assets
prior to the effective date of the new standard will be classified as PCD assets as of the

10



effective date. For all financial assets designated as PCD assets as of the effective date,
an institution will be required to gross up the balance sheet amount of the financial asset
by the amount of its allowance for expected credit losses as of the effective date, resulting
in an adjustment to the amortized cost basis of the asset to reflect the addition of the
allowance for credit losses as of that date. For loans held for investment and HTM debt
securities, this allowance gross-up as of the effective date of ASU 2016-13 should be
reported in the appropriate columns of Schedule HI-B, Part II, item 6, “Adjustments,”
and should be explained in the Notes to the Income Statement for which a preprinted
caption, “Effect of adoption of current expected credit losses methodology on allowances
for credit losses on loans and leases held for investment and held-to-maturity debt
securities,” will be provided in the text field for this item. Subsequent changes in the
allowance for credit losses on PCD financial assets will be recognized by charges or
credits to earnings through the provision for credit losses. The institution will continue to
accrete the noncredit discount or premium to interest income based on the effective
interest rate on the PCD financial assets determined after the gross-up for the CECL
allowance as of the effective date of adoption, except for PCD financial assists in
nonaccrual status.
AFS and HTM debt securities: A debt security on which OTTI had been recognized
prior to the effective date of the new standard will transition to the new guidance
prospectively (i.e., with no change in the amortized cost basis of the security). The
effective interest rate on such a debt security before the adoption date will be retained and
locked in. Amounts previously recognized in accumulated other comprehensive income
related to cash flow improvements will continue to be accreted to interest income over
the remaining life of the debt security on a level-yield basis. Recoveries of amounts
previously written off relating to improvements in cash flows after the date of adoption
will be recognized in income in the period received.
Schedule HI

To address the broader scope of financial assets for which a provision will be calculated
under ASU 2016-13, the Board revised Schedule HI, item 4, from “Provision for loan and lease
losses” to “Provision for Credit losses on financial assets,” effective March 31, 2021. To address
the elimination of the concept of OTTI by ASU 2016-13, effective December 31, 2022, the
Board removed Schedule HI, Memorandum item 17, “Other-than-temporary impairment losses
on held-to-maturity and available-for-sale debt securities recognized in earnings.” Under the
new standard, institutions will recognize credit losses on HTM and AFS debt securities through
an allowance for credit losses, and the Board will collect information on the allowance for credit
losses on these two categories of debt securities in Schedule HI-B as discussed below. From
March 31, 2019, through September 30, 2022, the report form and instructions for Memorandum
item 17 include guidance stating that Memorandum item 17 is to be completed only by
institutions that have not adopted ASU 2016-13.
Schedule HI-B
To address the broader scope of financial assets for which allowances will be calculated
under ASU 2016-13 and for which charge-offs and recoveries will be applicable, the Board

11

changed the title of Schedule HI-B effective March 31, 2021, from “Charge-offs and Recoveries
on Loans and Leases and Changes in Allowance for Loan and Lease Losses” to “Charge-offs and
Recoveries on Loans and Leases and Changes in Allowance for Credit Losses.”
In addition, effective March 31, 2021, to address the change in allowance nomenclature
arising from the broader scope of allowances under ASU 2016-13, the Board revised Schedule
HI-B, Part I, Memorandum item 4, from “Uncollectible retail credit card fees and finance
charges reversed against income (i.e., not included in charge-offs against the allowance for loan
and lease losses)” to “Uncollectible retail credit card fees and finance charges reversed against
income (i.e., not included in charge-offs against the allowance for credit losses on loans and
leases).”
To further address the broader scope of financial assets for which allowances will be
calculated under ASU 2016-13, the Board revised Schedule HI-B, Part II, to also include
changes in the allowances for credit losses on HTM and AFS debt securities. Effective March
31, 2019, the Board changed the title of Schedule HI-B, Part II, from “Changes in Allowance for
Loan and Lease Losses” to “Changes in Allowances for Credit Losses.”
In addition, effective March 31, 2019, Schedule HI-B, Part II, was expanded from one
column to a table with three columns titled:
 Column A: Loans and leases held for investment;
 Column B: Held-to-maturity debt securities;
 Column C: Available-for-sale debt securities.
From March 31, 2019, through September 30, 2022, the reporting form and the
instructions for Schedule HI-B, Part II, include guidance stating that Columns B and C are to be
completed only by institutions that have adopted ASU 2016-13.
In addition, effective March 31, 2019, Schedule HI-B, Part II, item 4, was revised from
“Less: Write-downs arising from transfers of loans to a held-for-sale account” to “Less: Writedowns arising from transfers of financial assets” to capture changes in allowances from transfers
of loans from held-to-investment to held-for-sale and from transfers of securities between
categories, e.g., from the AFS to the HTM category. Further, effective March 31, 2019,
Schedule HI-B, Part II, item 5, was revised from “Provision for loan and lease losses” to
“Provision for credit losses” to capture the broader scope of financial assets included in the
schedule.
Effective March 31, 2019, or the first quarter in which a holding company reports its
adoption of ASU 2016-13, whichever is later, Schedule HI-B, Part II, item 6, “Adjustments,”
will be used to capture the initial impact of applying ASU 2016-13 as of the effective date in the
period of adoption as well as the initial allowance gross-up for PCD assets as of the effective
date. Item 6 also will be used to report the allowance gross-up upon the acquisition of PCD
assets on or after the effective date.
In the memorandum section of Schedule HI-B, Part II, to address the change in allowance
nomenclature arising from the broader scope of allowances under ASU 2016-13 the Board

12

revised the caption for Memorandum item 3, effective March 31, 2021, from “Amount of
allowance for loan and lease losses attributable to retail credit card fees and finance charges” to
“Amount of allowance for credit losses on loans and leases attributable to retail credit card fees
and finance charges.” Also, in the memorandum section of Schedule HI-B, Part II, effective
December 31, 2022, the Board has removed existing Memorandum item 4, “Amount of
allowance for post-acquisition credit losses on purchased credit impaired loans accounted for in
accordance with AICPA Statement of Position 03-3” as ASU 2016-13 eliminates the concept of
PCI loans and the separate credit impairment model for such loans. From March 31, 2019,
through September 30, 2022, the reporting form and instructions for Schedule HI-B, Part II,
Memorandum item 4, specify that this item should be completed only by institutions that have
not yet adopted ASU 2016-13.
Given that the scope of ASU 2016-13 is broader than the three financial asset types to be
included in the table in Schedule HI-B, Part II, effective March 31, 2019, the Board added new
Memorandum item 5, “Provisions for credit losses on other financial assets carried at amortized
cost,” and Memorandum item 6, “Allowance for credit losses on other financial assets carried at
amortized cost,” to Schedule HI-B, Part II, at the same time. For purposes of Memorandum
items 5 and 6, other financial assets include all financial assets measured at amortized cost other
than loans and leases held for investment and HTM debt securities. From March 31, 2019,
through September 30, 2022, the reporting form and instructions for Schedule HI-B, Part II,
include guidance stating that Memorandum items 5 and 6 are to be completed only by
institutions that have adopted ASU 2016-13.
Schedule HI-C
Schedule HI-C currently requests allowance information for specific categories of loans
held for investment that is disaggregated on the basis of three separate credit impairment models,
and the amounts of the related recorded investments, from institutions with $1 billion or more in
total assets. ASU 2016-13 eliminates these separate credit impairment models and replaces them
with CECL for all financial assets measured at amortized cost. As a result of this change,
effective March 31, 2021, the Board changed the title of Schedule HI-C from “Disaggregated
Data on the Allowance for Loan and Lease Losses” to “Disaggregated Data on Allowances for
Credit Losses.”
To capture disaggregated data on allowances for credit losses from institutions that have
adopted ASU 2016-13, the Board created Schedule HI-C, Part II, “Disaggregated Data on
Allowances for Credit Losses,” effective March 31, 2019. The existing table in Schedule HI-C,
which includes items 1 through 6 and columns A through F, would be renamed “Part I.
Disaggregated Data on the Allowance for Loan and Lease Losses.” From March 31, 2019,
through September 30, 2022, the reporting form and instructions for Schedule HI-C, Part I, will
include guidance stating that only those institutions that have not adopted ASU 2016-13 should
complete Schedule HI-C, Part I.
Part II of this schedule contains six loan portfolio categories and the unallocated category
for which data are currently collected in existing Schedule HI-C along with the following

13

portfolio categories for which allowance information will begin to be reported for HTM debt
securities.
The Board reevaluated the proposed portfolio categories for which disaggregated
allowance information would begin to be reported by institutions after adoption of ASU 2016-13
for held-to-maturity (HTM) debt securities on Schedule HI-C, Part II, on the FR Y-9C. The
Board determined that separate reporting of allowances on HTM mortgage-backed securities
issued or guaranteed by U.S. government agencies or sponsored agencies and other HTM
mortgage-backed securities is not needed because, at present, the former category of mortgagebacked securities would likely have zero expected credit losses. As a result, the Board will
combine these portfolio categories and collect only one data item, rather than two data items, for
the total allowances on an institution’s HTM mortgage-backed securities.
1.
2.
3.
4.
5.

Securities issued by states and political subdivisions in the U.S.
Mortgage-backed securities (MBS) (including CMOs, REMICs, and stripped MBS)
Asset-backed securities and structured financial products
Other debt securities
Total

For each category of loans in Part II of Schedule HI-C, institutions report the amortized
cost and the allowance balance in Columns A and B, respectively. The amortized cost amounts
to be reported would exclude the accrued interest receivable that is reported in “Other assets” on
the balance sheet. For each category of HTM debt securities in Part II of Schedule HI-C,
institutions would report the allowance balance. The amortized cost and allowance information
on loans and the allowance information on HTM debt securities would be reported quarterly and
would be completed only by institutions with $1 billion or more in total assets, as is currently
done with existing Part I of Schedule HI-C.
The Board will use the securities-related information gathered in Part II of the schedule to
monitor the allowance levels for the categories of HTM debt securities specified above. Further,
with the removal of FR Y-9C item for OTTI losses recognized in earnings (Schedule HI,
Memorandum item 17), Schedule HI-C, Part II, will become another source of information
regarding credit losses of HTM debt securities, in addition to data reported in Schedule HI-B,
Part II. From March 31, 2019, through September 30, 2022, the reporting form and instructions
for Schedule HI-C, Part II, include guidance stating that only those institutions with $1 billion or
more in total assets that have adopted ASU 2016-13 should complete Schedule HI-C, Part II.
In addition, effective December 31, 2022, the Board will remove the existing Schedule
HI-C, Part I. Schedule HI-C, Part II, would then be the only table remaining within this schedule
and the “Part II” designation would be removed.
Notes to the Income Statement- Predecessor Financial Items
Effective March 31, 2021, the Board will address the broader scope of financial assets for
which a provision will be calculated under ASU 2016-13. From March 31, 2019, through
September 30, 2022, the reporting form and instructions for line item 4, “Provision for loan and

14

lease losses,” includes guidance that only institutions that have adopted ASU 2016-13 should
report the provision for credit losses in this item. Effective March 31, 2021, the Board will
revise line item 4 from “Provision for Loan and Lease losses” to “Provision for Credit Losses.”
Notes to the Income Statement
Effective March 31, 2019, the Board added a preprinted caption to the text field, that
would be titled “Adoption of Current Expected Credit Losses Methodology – ASC Topic 326.”
Institutions will use this item to report the cumulative-effect adjustment (net of applicable
income taxes) recognized in retained earnings for the changes in the allowances for credit losses
on financial assets and off-balance sheet credit exposures as of the beginning of the fiscal year in
which the institution adopts ASU 2016-13. Providing a preprinted caption for this data item,
rather than allowing each holding company to enter its own description for this cumulative-effect
adjustment, will enhance the Board’s ability to compare the impact of the adoption of ASU
2016-13 across institutions. From March 31, 2019, through December 31, 2022, the reporting
form and instructions for Notes to the Income Statement, specify that this item is to be completed
only in the quarter-end FR Y-9C for the remainder of the calendar year in which a holding
company adopts ASU 2016-13. The Board anticipates that this preprinted caption would be
removed after all holding companies have adopted ASU 2016-13.
To address the broader scope of financial assets for which an allowance will be
maintained under ASU 2016-13, effective March 31, 2019, the Board added two preprinted
captions to the text field that would be titled “Initial allowances for credit losses recognized upon
the acquisition of purchased deteriorated assets on or after the effective date of ASU 2016-13”
and “Effect of adoption of current expected credit losses methodology on allowances for credit
losses on loans and leases held for investment and held-to-maturity debt securities.” The latter of
these preprinted captions is used to capture the change in the amount of allowances from
initially applying ASU 2016-13 on these two categories of assets as of the effective date of the
accounting standard in the period of adoption, including the initial gross-up for any PCD assets
held as of the effective date. From March 31, 2019, through September 30, 2022, the reporting
form and instructions specify that these items are to be completed only by holding companies
that have adopted ASU 2016-13 and, for the latter preprinted caption, only in the quarter-end
FR Y-9C report for the remainder of the calendar year in which an institution adopts ASU 201613. The Board anticipates the latter preprinted caption would be removed after all institutions
have adopted ASU 2016-13.
Schedule HC
To address the broader scope of financial assets for which allowances will be estimated
under ASU 2016-13, the Board revised the reporting form and instructions to specify which
assets should be reported net of an allowance for credit losses on the balance sheet and which
asset categories should be reported gross of such an allowance. The Board determined that the
only financial asset category for which separate (i.e., gross) reporting of the amortized cost10 and
the allowance is needed on Schedule HC continues to be item 4.b, “Loans and leases held for
10

Amortized cost amounts to be reported by asset category would exclude any accrued interest receivable on assets
in that category that is reported in “Other assets” on the balance sheet.

15

investment,” because of the large relative size and importance of these assets and their related
allowances to the overall balance sheet for most institutions. For other financial assets within the
scope of CECL, the Board instructed holding companies to report these assets at amortized cost11
net of the related allowance for credit losses on Schedule HC.
Effective March 31, 2021, the Board revised Schedule HC, item 2.a, from “Held-tomaturity securities” to “Held-to-maturity securities, net of allowance for credit losses.” From
March 31, 2019, through December 31, 2020, the Board added a footnote to Schedule HC, item
2.a, specifying that holding companies should “report this amount net of any applicable
allowance for credit losses.” Additionally, for Schedule HC, item 3.b, “Securities purchased
under agreements to resell,” and Schedule HC, item 11, “Other assets,” effective March 31,
2019, the Board added a footnote to these items specifying that holding companies should
“report this amount net of any applicable allowance for credit losses.” From March 31, 2019,
through September 30, 2022, the reporting form and the instructions for Schedule HC, items 2.a,
3.b, and 11, specify that reporting such items net of any related allowances for credit losses is
applicable only to those institutions that have adopted ASU 2016-13. Given that AFS debt
securities are carried on Schedule HC at fair value, the Board did not propose any changes to
Schedule HC, item 2.b, “Available-for-sale securities,” and instead institutions will report
allowances for credit losses on AFS debt securities only in Schedule HI-B, Part II.
In addition, to address the change in allowance nomenclature arising from the broader
scope of allowances under ASU 2016-13, the Board revised Schedule HC, item 4.c, from “LESS:
Allowance for loan and lease losses” to “LESS: Allowance for credit losses on loans and leases”
effective March 31, 2021. Effective March 31, 2019, the Board added a footnote to this item
specifying that institutions who have adopted ASU 2016-13 should report the allowance for
credit losses on loans and leases in this item.
Schedule HC-B
Effective March 31, 2019, the Board revised the instructions to Schedule HC-B to clarify
that for institutions that have adopted ASU 2016-13, allowances for credit losses should not be
deducted from the amortized cost amounts reported in columns A and C of this schedule.12 In
other words, institutions should continue reporting the amortized cost of HTM and AFS debt
securities in these two columns of Schedule HC-B gross of their related allowances for credit
losses.
Schedule HC-C
Effective March 31, 2021, to address the change in allowance nomenclature, the Board
will revise the reporting form and the instructions for Schedule HC-C by replacing references to
the allowance for loan and lease losses in statements indicating that the allowance should not be
deducted from loans and leases in this schedule with references to the allowance for credit losses.

11

See footnote 10.
Amortized cost amounts to be reported by securities category in Schedule HC-B would exclude any accrued
interest receivable on the securities in that category that is reported in “Other assets” on the balance sheet.
12

16

Thus, loans and leases will continue to be reported gross of any allowances or allocated transfer
risk reserve in Schedule HC-C.
In addition, to address the elimination of PCI assets by ASU 2016-13, the Board will
remove Schedule HC-C, Part I, Memorandum items 5.a and 5.b, in which institutions report the
outstanding balance and balance sheet amount, respectively, of PCI loans held for investment
effective December 31, 2022. The agencies determined that these items were not needed after
the transition to PCD loans under ASU 2016-13 because the ASU eliminates the separate credit
impairment model for PCI loans and applies CECL to all loans held for investment measured at
amortized cost. From March 31, 2019, through September 30, 2022, the reporting form and the
instructions for Schedule HC-C, Memorandum items 5.a and 5.b, specify that these items should
be completed only by institutions that have not yet adopted ASU 2016-13.
Additionally, since ASU 2016-13 supersedes ASC 310-30, the Board will revise
Schedule HC-C, Memorandum item 12, “Loans (not subject to the requirements of AICPA
Statement of Position 03-3) and leases held for investment that were acquired in business
combinations with acquisition dates in the current calendar year,” effective December 31, 2022.
As revised, the loans held for investment reported in Memorandum item 12 will be those not
considered purchased credit deteriorated per ASC 326. From March 31, 2019, through
September 30, 2022, the Board revised the reporting form and the instructions for Schedule HCC, by adding a statement explaining that, subsequent to adoption of ASU 2016-13, a holding
company should report only loans held for investment not considered purchased credit
deteriorated per ASC 326 in Schedule HC-C, Memorandum item 12.
Schedule HC-F
To address the broader scope of financial assets for which an allowance will be
applicable under ASU 2016-13, the Board specified that assets within the scope of the ASU that
are included in Schedule HC-F should be reported net of any applicable allowances for credit
losses. Effective March 31, 2019, the Board revised the reporting form and the instructions for
Schedule HC-F by adding a statement explaining that, subsequent to adoption of ASU 2016-13, a
holding company should report asset amounts in Schedule HC-F net of any applicable
allowances for credit losses.
In addition, effective March 31, 2019, the Board added a footnote to item 1, “Accrued
interest receivable” on the reporting form and a statement to the instructions for item 1 that
specifies that holding companies should exclude from this item any accrued interest receivables
that is reported elsewhere on the balance sheet as part of the related financial asset’s amortized
cost.
HC-G
To address ASU 2016-13’s exclusion of off-balance sheet credit exposures that are
unconditionally cancellable from the scope of off-balance sheet credit exposures for which
allowances for credit losses should be measured, the Board revised the reporting form and
instructions for Schedule HC-G, item 3, “Allowance for credit losses on off-balance-sheet credit

17

exposures,” effective March 31, 2019. As revised, the reporting form and instructions would
state that holding companies that have adopted ASU 2016-13 should report in item 3 the
allowance for credit losses on those off-balance sheet credit exposures that are not
unconditionally cancellable.
Schedule HC-K
Effective March 31, 2019, the Board revised the instructions to Schedule HC-K to clarify
that, for institutions that have adopted ASU 2016-13, allowances for credit losses should not be
deducted from the related amortized cost amounts when calculating the quarterly averages for all
debt securities.
Schedule HC-N
To address the elimination of PCI assets by ASU 2016-13, the Board will remove
Schedule HC-N, Memorandum items 9.a and 9.b, in which institutions report the outstanding
balance and balance sheet amount, respectively, of past due and nonaccrual PCI loans effective
December 31, 2022. The Board determined that these items were not needed for PCD loans
under ASU 2016-13 given that the ASU eliminates the separate credit impairment model for PCI
loans and applies CECL to PCD loans and all other loans held for investment measured at
amortized cost. From March 31, 2019, through September 30, 2022, the reporting form and the
instructions for Schedule HC-N, Memorandum items 9.a and 9.b, specify that these items should
be completed only by holding companies that have not yet adopted ASU 2016-13.
Schedule HC-R
In December 2018, the agencies approved a final rule amending their capital rule to
address CECL.13 The final rule included revised terminology for the allowance balance eligible
for inclusion in regulatory capital.14 The Board has made a conforming terminology revision for
the reporting of regulatory capital on Schedule HC-R.
In connection with the CECL Rule, the Board adopted a number of revisions to Schedule
HC-R to incorporate new terminology and the approved optional regulatory capital transition.
Unless otherwise indicated, the revisions to Schedule HC-R discussed below would take effect
March 31, 2019, (or the first quarter-end report date thereafter following the effective date on
any final rule) and would apply to those institutions that have adopted CECL.
The CECL Rule introduces a newly defined regulatory capital term, allowance for credit
losses (ACL), which replaces the allowance for loan and lease losses (ALLL), as defined under
the capital rules for holding companies that adopt CECL. The CECL Rule also provides that
credit loss allowances for PCD assets held by these holding companies should be netted when
determining the carrying value, as defined in the CECL Rule, and, therefore, only the resulting
13

See https://www.federalreserve.gov/newsevents/pressreleases/bcreg20181221a.htm.
The agencies’ final rule uses the term “adjusted allowances for credit losses” for regulatory capital purposes to
distinguish such allowances from allowances for credit losses for accounting purposes.
14

18

net amount is be subject to risk-weighting. In addition, in the CECL Rule, the agencies have
provided each institution the option to phase in the day-one regulatory capital effects that may
result from the adoption of ASU 2016-13 over the three-year period beginning with the
institution’s CECL effective date.15
Allowances for Credit Losses Definition and Treatment of Purchase Credit
Deteriorated Assets
In general, under the CECL Rule, holding companies that have adopted CECL will be
required to report ACL amounts instead of ALLL amounts that are currently reported. Effective
December 31, 2022, the Board will remove references to ALLL and replaced them with
references to ACL on the reporting form for Schedule HC-R. From March 31, 2019, through
September 30, 2022, the Board revised the instructions to Schedule HC-R to direct institutions
that have adopted CECL to use ACL instead of ALLL in calculating regulatory capital. The
revisions to the instructions would affect Schedule HC-R, Part I. Regulatory Capital
Components and Ratios, item 30.a, “Allowance for loan and lease losses includable in tier 2
capital,” and Schedule HC-R, Part II. Risk-Weighted Assets, items 6, “LESS: Allowance for
loan and lease losses,” 26, “Risk-weighted assets for purposes of calculating the allowance for
loan and lease losses 1.25 percent threshold,” 28, “Risk-weighted assets before deductions for
excess allowance of loan and lease losses and allocated risk transfer risk reserve,” and 29,
“LESS: Excess allowance for loan and lease losses.”
In addition, consistent with the CECL Rule, assets and off-balance sheet credit exposures
for which any related credit loss allowances are eligible for inclusion in regulatory capital would
be calculated and reported in Schedule HC-R Part II. Risk-Weighted Assets on a gross basis.
Therefore, the Board revised the instructions for Schedule HC-R, Part II. Risk-Weighted Assets,
items 2.a, “Held-to-maturity securities”; 3.b., “Securities purchased under agreements to resell”;
5.a., “Residential mortgage exposures” held for investment; 5.b, “High volatility commercial real
estate exposures” held for investment; 5.c, Held-for-investment “Exposures past 90 days or more
or on nonaccrual”; 5.d, “All other exposures” held for investment; 8, “All other assets,” and 9.a,
“On-balance sheet securitization exposures: Held-to-maturity securities”; to explain that holding
companies that have adopted CECL should report and risk-weight their loans and leases held for
investment, HTM securities, and other financial assets measured at amortized cost gross of their
credit loss allowances, but net of the associated allowances on PCD assets.16
In addition, effective March 31, 2019, the Board added a new Memorandum item 5 to,
Schedule HC-R, Part II that would collect data by asset category on the “Amount of allowances
for credit losses on purchased credit-deteriorated assets.” The amount of such allowances for
15

A non-PBE with a calendar year fiscal year that does not early adopt CECL would first report under CECL as of
December 31, 2021, even though the non-PBE’s CECL effective date is January 1, 2021. Thus, under the CECL
Rule, such a non-PBE should use the phase-in percentage applicable to the first year of the three-year transition
period only for the December 31, 2021, report date (i.e., one quarter), not the four quarters that begin with the first
report under CECL. The non-PBE may use the applicable phase-in percentages for all four quarters of the second
and third years after the CECL effective date (i.e., 2022 and 2023). The same principle would apply to the optional
phase-in by a non-PBE with a non-calendar fiscal year.
16
Amortized cost amounts to be reported by asset category in Schedule HC-R, Part II, would exclude any accrued
interest receivable on assets in that category that is reported in “Other assets” on the Call Report balance sheet.

19

credit losses are reported separately for “Loans and leases held for investment” in Memorandum
item 5.a, “Held-to-maturity debt securities” in Memorandum item 5.b, and “Other financial
assets measured at amortized cost” in Memorandum item 5.c. The instructions for Schedule
HC-R, Part II, Memorandum item 5, specify that these items should be completed only by
holding companies that have adopted ASU 2016-13.
The Board included footnotes for the affected items on the forms to highlight the revised
treatment of those items for institutions that have adopted CECL.
CECL Transition Provision
Under the CECL Rule, a holding company that experiences a reduction in retained
earnings as of the effective date of CECL for the holding company as a result of the holding
company’s adoption of CECL may elect to phase in the regulatory capital impact of adopting
CECL (electing institution). As described in the CECL Rule, an electing holding company
should indicate in its FR Y-9C report whether it has elected to use the CECL transition provision
beginning in the quarter that it first reports its credit loss allowances as measured under CECL.
To identify which holding companies are electing holding companies, the Board revised
Schedule HC-R, Part I, Regulatory Capital Components and Ratios, by adding a new item 2.a in
which a holding company that has adopted CECL would report whether it has or does not have a
CECL transition election in effect as of the quarter-end report date. Each holding company will
complete item 2.a beginning in the FR Y-9C for its first reporting under CECL and in each
subsequent FR Y-9C report thereafter until item 2.a is removed from the report. Until an holding
company has adopted CECL, it will leave item 2.a blank. Effective March 31, 2025, the Board
will remove item 2.a from Schedule HC-R, Part I, because the optional three-year phase-in
period will have ended for all electing institutions by the end of the prior calendar year. If an
individual electing holding company’s three-year phase-in period ends before item 2.a is
removed (e.g., its phase-in period ends December 31, 2022), the holding company would change
its response to item 2.a and report that it does not have a CECL transition election in effect as of
the quarter-end report date.
During the CECL transition period, an electing holding company would need to make
adjustments to its retained earnings, temporary difference deferred tax assets (DTAs), AACL,
and average total consolidated assets for regulatory capital purposes. An advanced approaches
institution also would need to make an adjustment to its total leverage exposure. These
adjustments are described in detail in the CECL Rule.
The Board revised the instructions to Schedule HC-R, Part I, Regulatory Capital
Components and Ratios, items 2, “Retained earnings”; 30.a, “Allowance for loan and lease
losses includable in tier 2 capital”; item 36, “Average total consolidated assets,” as well as
Schedule HC-R, Part II, Risk-Weighted Assets, item 8, “All other assets,” consistent with the
adjustments to these items for the applicable transitional amounts as described in the CECL Rule
for reporting by electing institutions to report the adjusted amounts. The Board has included
footnotes on the reporting forms to highlight the changes to these items for electing institutions.

20

Schedule HC-V
The Board clarified in the instructions effective March 31, 2019, that all assets of
consolidated variable interest entities should be reported net of applicable allowances for credit
losses by holding companies that have adopted ASU 2016-13. Net reporting on Schedule HC-V
by such holding companies is consistent with the changes to Schedules HC and HC-F. Similarly,
effective March 31, 2019, the reporting form for Schedule HC-V specifies that holding
companies that have adopted ASU 2016-13 should report assets net of applicable allowances.
FR 2248, FR 2314, FR 2314S, FR 2320, FR 2644, FR 2886b, FR Y-7N, FR Y-7NS,
FR Y-8, FR Y-9LP, FR Y-9SP, FR Y-11, and FR Y-11S
The Board has made changes to the FR 2248, FR 2314, FR 2314S, FR 2320, FR 2644,
FR 2886b, FR Y-7N, FR Y-7NS, FR Y-8, FR Y-9LP, FR Y-9SP, FR Y-11, and FR Y-11S
reports to mirror the FR Y-9C and Call report reporting revisions related to ASU 2016-13. The
report forms and instructions were revised to clearly indicate that HTM securities, Securities
purchased under agreements to resell, and Other assets should be reported net of applicable
allowance for credit losses for those institutions that have adopted the standard. Additionally,
the Board indicated on the report form and instructions that institutions that have adopted the
ASU 2016-13 should report “Allowance for credit losses on loans and leases” and “Provisions
for credit losses for all applicable financial assets.”
To further address the broader scope of financial assets for which allowances will be
calculated under ASU 2016-13, the Board revised the FR 2314, FR 2314S, FR 2886b, FR Y-7N,
FR Y-7NS, FR Y-11, and FR Y-11S reports to change the title caption from Changes in
Allowance for Loan and Lease Losses” to “Changes in Allowances for Credit Losses” and added
three columns titled:
 Column A: Loans and leases
 Column B: Held-to-maturity debt securities
 Column C: Available-for-sale debt securities
2. EGRRCPA Adopted FR Y-9C Report Revisions
On September 28, 2018, the Board, pursuant to its delegated authority,17 temporarily
approved certain revisions to the FR Y-9C relating to statutory amendments enacted by
EGRRCPA.18 Pursuant to the requirements of the Board’s delegated authority, the Board is now
extending these revisions for three years through the normal delegated clearance process.19
Section 214 of EGRRCPA, which was enacted on May 24, 2018, modified the Federal
Deposit Insurance Act (FDI Act) to add a new section 51 governing the risk-based capital
requirements for certain acquisition, development, or construction (ADC) loans. EGRRCPA
provides that, effective upon enactment, the federal banking agencies may only require a

17
18
19

5 CFR Pt. 1320, Appx. A(a)(3)(i)(A).
See 83 FR 48990 (September 28, 2018).
See 5 CFR Pt. 1320, Appx. A(a)(3)(i)(B).

21

depository institution to assign a heightened risk weight to an HVCRE exposure if such exposure
is an “HVCRE ADC Loan,” as defined in this new law.
Section 202 of EGRRCPA amended section 29 of the FDI Act to exclude a capped
amount of reciprocal deposits from treatment as brokered deposits for qualifying institutions,
effective upon enactment. The instructions for the FR Y-9C and the Call Report, consistent with
the law prior to the enactment of EGRRCPA, previously treated all reciprocal deposits as
brokered deposits. In amending section 29 of the FDI Act to exclude a capped amount of
reciprocal deposits from treatment as brokered deposits for qualifying institutions, section 202
defines “reciprocal deposits” to mean “deposits received by an agent institution through a deposit
placement network with the same maturity (if any) and in the same aggregate amount as covered
deposits placed by the agent institution in other network member banks.” The terms “agent
institution,” “deposit placement network,” “covered deposit,” and “network member bank,” all
of which are used in the definition of “reciprocal deposit,” also are defined in section 202.
In particular, an “agent institution” is an FDIC-insured depository institution that meets at
least one of the following criteria:
 The institution is well-capitalized and has a composite condition of “outstanding” or
“good” when most recently examined under section 10(d) of the FDI Act (12 U.S.C.
1820(d)),
 The institution has obtained a waiver from the FDIC to accept, renew, or roll over
brokered deposits pursuant to section 29(c) of the FDI Act (12 U.S.C. 1831f(c)), or
 The institution does not receive reciprocal deposits in an amount that is greater than a
“special cap” (discussed below).
Under the “general cap” set forth in section 202, an agent institution may classify
reciprocal deposits up to the lesser of the following amounts as non-brokered reciprocal deposits:
 $5 billion or
 An amount equal to 20 percent of the agent institution’s total liabilities.
Any amount of reciprocal deposits in excess of the “general cap” would be treated as, and
should be reported as, brokered deposits.
A “special cap” applies if an agent institution is either not “well-rated” or not wellcapitalized. In this situation, the institution may classify reciprocal deposits as non-brokered in
an amount up to the lesser of the “general cap” or the average amount of reciprocal deposits held
at quarter-end during the last four quarters the institution was well-capitalized and in
“outstanding” or “good” condition.
To address the change in the treatment of HVCRE loans and certain reciprocal deposits
under EGRRCPA, the agencies made a number of revisions to the September 2018 Call
instructions. In order to avoid the regulatory burden associated with applying different
definitions for HVCRE exposures and reciprocal deposits within a single organization, the Board
temporarily revised the FR Y-9C instructions so that they that are consistent with those changes
to the Call Report. To assist holding companies in preparing the FR Y-9C for that report date,

22

the revised FR Y-9C Supplemental Instructions include information regarding the reporting of
HVCRE exposures and reciprocal deposits.
Specifically, the revisions to the FR Y-9C report provided that (1) respondents are
permitted to report brokered deposits (in Schedule HC-E Memorandum items 1 and 2) in a
manner consistent with the provisions of EGRRCPA,20 but also may choose to continue to report
brokered deposits in a manner consistent with the current instructions to the FR Y-9C and
(2) respondents are permitted to apply a heightened risk weight only to those HVCRE exposures
(in Schedule HC-R, Part II, items 4.b, 5.b and 7) they believe meet the definition of HVCRE
ADC Loan, but also may choose to continue to report and risk weight HVCRE exposures in a
manner consistent with the previous instructions to the FR Y-9C.
3. Other Adopted revisions
Adopted Revisions to the FR Y-9C
On the Notes to the Income Statement - Predecessor Financial Items, the Board added
footnote to line item 6, Realized gains (losses) on held-to-maturity and available-for-sale
securities to instruct holding companies to include realized and unrealized holding gains and
losses in this item in order to implement the accounting change pertaining to equity securities
under Accounting Standards Update (ASU No. 2016-01, “Recognition and Measurement of
Financial Assets and Financial Liabilities”). This change is consistent with the changes to the
Call Report21 and the FR Y-9C22 report that became effective March 31, 2018. This change is
effective March 31, 2019.
Adopted Revisions to the FR 2886b
Effective March 31, 2019, the Board adopted a number of revisions to the FR 2886b
reporting requirements, most of which align with changes implemented on the Call Report. The
changes include:
 Revisions to Schedule RC-R, Regulatory Capital, for banking Edge corporations,
 Revisions to the eligibility criteria for reporting Schedule RC-D, Trading Assets and
Liabilities,
 Revisions to address changes in accounting for equity investments not held for trading,
and
 Revisions to the reporting of equity investments accounted for under the equity method
of accounting.

20

Although the EGRRCPA provision relating to reciprocal deposits and the risk-weighting of HVCRE applies only
to depository institutions, the Board revised the FR Y-9C to permit holding companies to report HVCRE in a
manner consistent with their subsidiary depository institutions.
21
See 83 FR 939 (February 7, 2018).
22
See 83 FR 12395 (March 21, 2018).

23

Schedule RC-R, Regulatory Capital (for banking Edge corporations)
Effective January 1, 1993, banking Edge corporations became subject to capital adequacy
guidelines under section 211.12(c) of Regulation K - International Banking Operations (12 CFR
211). According to Regulation K, banking Edge corporations must maintain a minimum total
capital to total risk-weighted assets ratio of at least 10 percent, of which at least 50 percent must
consist of Tier 1 capital. In order to assess compliance with the capital requirements of
Regulation K, banking Edge corporations file FR 2886b Schedule RC-R, which currently
consists of six items:
 Tier 1 capital allowable under the risk-based capital guidelines,
 Tier 2 capital allowable under the risk-based capital guidelines,
 Subordinated debt allowable as Tier 2,
 Total qualifying capital allowable under risk-based capital guidelines,
 Total risk-weighted assets and credit equivalent amounts of off-balance sheet items, and
 Credit equivalent amounts of off-balance-sheet items
In October of 2013, the Board and the OCC published the revised capital rules in the
Federal Register.23 (The FDIC published its own identical rules). The revised capital rules
updated Regulation Q - Capital Adequacy of Bank Holding Companies, Savings and Loan
Holding Companies, and State Member Banks (12 CFR 217). As a result of this update, the
concept of risk-based capital rules in Regulation Q replaced the concept of capital adequacy
guidelines. Since banking Edge Corporations are subject to capital adequacy guidelines under
Regulation K, and the concept of capital adequacy guidelines in Regulation K was replaced by
the concept of risk-based capital rules in Regulation Q, banking Edge corporations were now
subject to risk-based capital rules under Regulation Q.
From August of 2013 to February of 2015, the Board, in conjunction with the OCC and
the FDIC, published initial and final notices in the Federal Register to revise Call Report
Schedule RC-R, Regulatory Capital, to align with the revised capital rules under Regulation Q.24
As a result, Call Report Schedule RC-R, Part I, Regulatory Capital Components and Ratios, and
Part II, Risk-Weighted Assets, were revised as of March 2014 and March 2015, respectively.
The FR 2886b Schedule RC-R was not updated at this time to reflect the revised capital rules.
The Board removed all six existing items on FR 2886b Schedule RC-R, and replaced
them with four items that correspond to the risk-based capital rules under Regulation Q. The
revisions are similar to the revisions made on Call Report Schedule RC-R, albeit concerning
fewer items. The Board believes these four items sufficiently assess risk-based capital adequacy
for banking Edge Corporations, and better align with the risk-based capital rules under
Regulation Q. Specifically, the Board added the following items to FR 2886b Schedule RC-R:
 Tier 1 Capital allowable under Regulation Q,
 Tier 2 Capital allowable under Regulation Q,
 Total Capital allowable under Regulation Q, and
23

See 78 FR 62018 (October 11, 2013).
See 78 FR 48934 (August 12, 2013), 79 FR 2527 (January 14, 2014), 79 FR 35634 (June 23, 2014), and 80 FR
5618 (February 2, 2015).
24

24



Total risk-weighted assets
Schedule RC-D, Trading Assets and Liabilities

The Board changed the reporting threshold for filing Schedule RC-D to Edges with total
trading assets of $10 million or more in any of the four preceding calendar quarters, from the
current threshold of $2 million. The Board no longer needs the information reported in this
schedule from Edges with a lesser amount of trading assets.
Changes in accounting for equity investments not held for trading
In January 2016, the FASB issued ASU No. 2016-01, “Recognition and Measurement of
Financial Assets and Financial Liabilities.” The Board revised the FR 2886b report form and
instructions to account for the changes to U.S. GAAP set forth in ASU 2016-01 hat are
consistent with the changes made to the Call Report.25 These revised reporting requirements are
effective for different sets of respondents as those respondents become subject to the ASU.
Institutions that are public business entities, as defined in U.S. GAAP, are subject to ASU 201601 for fiscal years beginning after December 15, 2017, including interim periods within those
fiscal years. ASU 2016-01 is effective for fiscal years beginning after December 15, 2018, and
interim periods within fiscal years beginning after December 15, 2019. The period over which
institutions will be implementing this ASU ranges from the first quarter of 2019 through the
fourth quarter of 2020. December 31, 2020, will be the first quarter-end FR 2886b report date as
of which all institutions would be required to prepare their FR 2886b in accordance with ASU
2016-01 and the revised reporting requirements.
The changes to the accounting for equity investments under ASU 2016-01 will affect
several existing data items in the FR 2886b. 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 2886b Schedule RC-B
(Securities), item 3, 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 2886b balance sheet
and reported in Schedule RC, item 2.
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 2886b balance sheet in Schedule RC, item 24.
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 2886b balance sheet in Schedule RC, item 23. After the effective date,
changes in the fair value of (i.e., the unrealized gains and losses on) an institution’s equity
25

See 83 FR 939 (January 8, 2018).

25

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
institutions’ implementation of ASU 2016-01 carries over to the agencies’ regulatory capital
rules. Under these rules, institutions that are eligible to and have elected to make the AOCI optout 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. 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, institutions currently
report their holdings of such equity securities without readily determinable fair values as a
category of other assets in FR 2886b Schedule RC, item 8 (item 8 is the total amount of an
institution’s other assets).
At present, AFS equity securities and equity investments without readily determinable
fair values are included in the quarterly averages reported in Schedule RC-K. Institutions report
the quarterly average of its total securities in item 7 of this schedule and this average reflects
AFS equity securities at fair value and equity investments without readily determinable fair
values at historical cost (item 7 is total assets; there is no breakout for securities on Schedule
RC-K on the FR 2886b).
The Board has 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 are currently reported in the FR 2886b, which has been described
above. Accordingly, the revisions to the FR 2886b report form and instructions to address the
equity securities accounting changes are as follows:
Schedule RI
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 RI, Income Statement, and to clearly distinguish these gains and losses from the rest of
an institution’s income (loss) from its continuing operations, Schedule RI, item 8, was revised
effective March 31, 2019, 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, institutions will also report in

26

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 RI, item 8, “Income (loss) before applicable income taxes
and discontinued operations,” has been renumbered as item 8.c, and is equal to the sum of items
8.a and 8.b. From March 31, 2019, through September 30, 2020, the instructions for item 8.b
and the reporting form for Schedule RI include guidance stating that item 8.b is to be completed
only by institutions that have adopted ASU 2016-01. Institutions that have not adopted ASU
2016-01 would leave item 8.b blank when completing Schedule RI. Finally, from March 31,
2019, through September 30, 2020, the instructions for Schedule RI, item 6, “Realized gains
(losses) on securities not held in trading accounts,” and the reporting form for Schedule RI
include guidance stating that, for institutions that have adopted ASU 2016-01, item 6 includes
realized gains (losses) only on AFS debt securities. Effective December 31, 2020, the caption
for item 6 would be revised to “Realized gains (losses) on available-for-sale debt securities.”
Schedule RC
In Schedule RC, Balance Sheet, item 2, “Securities,” has been split into three items:
item 2.a: “Held-to-maturity securities, net of allowance for credit losses,” item 2.b: “Availablefor-sale securities not held for trading,” and 2.c: “Equity securities with readily determinable fair
values not held for trading,” effective March 31, 2019. From March 31, 2019, through
September 30, 2020, the instructions for item 2.c and the reporting form for Schedule RC
include guidance stating that item 2.c is to be completed only by institutions that have adopted
ASU 2016-01. Institutions that have not adopted ASU 2016-01 would leave item 2.c blank.
During this period, the instructions for items 2.a and 2.b explain that institutions that have
adopted ASU 2016-01 should include only debt securities in these items. Effective December
30, 2020, the caption for item 2.a will be revised to “Held-to-maturity debt securities, net of
allowance for credit losses,” and the caption for item 2.b will be revised to “Available-for-sale
debt securities not held for trading.” All institutions would report their holdings of equity
securities with readily determinable fair values not held for trading in item 2.c.
In Schedule RC, item 8, Other Assets, the instructions were revised to add language
stating institutions that have adopted ASU 2016-01 should report “equity investments without
readily determinable fair values” at fair value, effective March 31, 2019. Institutions that have
not adopted ASU 2016-01 will continue to report “equity securities that do not have readily
determinable fair values” at historical cost. The types of equity securities and other equity
investments currently reported in item 8 continue to be reported in this item. However, after the
effective date of ASU 2016-01, the securities the institution reports in item 8 is measured in
accordance with the ASU.
Schedule RC-B
In Schedule RC-B, item 3, “Equity interest in nonrelated organizations,” will be removed
effective December 30, 2020. From March 31, 2019, through September 30, 2020, the
instructions for item 3 and the reporting form for Schedule RC-B include guidance stating that

27

item 3 is to be completed only by institutions that have not adopted ASU 2016-01. Institutions
that have adopted ASU 2016-01 will leave item 3 blank.
Investments accounted for under the equity method of accounting
The instructions for Schedule RC-B, item 3, “Equity interest in nonrelated
organizations,” currently state to include investments that represent 20 percent to 50 percent of
the voting shares of an organization accounted for under the equity method of accounting, and
these investments are reported as either held-to-maturity or available-for-sale. Upon review, it
was determined this treatment is not in compliance with U.S. GAAP, as investments accounted
for under the equity method of accounting should not be classified as either held-to-maturity or
available-for-sale. Guidance on securities accounted for under the equity method is provided in
ASC Subtopic 323-10, Investments – Equity Method and Joint Ventures- Overall. To become
U.S. GAAP compliant and to align with the reporting on the Call Report, the Board revised the
instructions to indicate investments that represent 20 percent to 50 percent of the voting shares of
an organization accounted for under the equity method of accounting should no longer be
included in Schedule RC-B, item 3, but rather included in Schedule RC, item 8, “Other assets.”
In addition, Schedule RC-B, item 3, columns A and B, Amortized Cost and Fair Value of
Held-to-maturity equity interest in nonrelated organizations, respectively, would be discontinued
effective March 31, 2019, as these items are no longer needed by the Board. Columns C and D,
Amortized Cost and Fair value of Available-for-sale securities, would remain on the form and
continue to be collected until December 31, 2020, when all institutions must comply with ASU
2016-01 (see description of revisions due to ASU 2016-01 for more information).
Frequency
The Board has not changed the reporting frequency of the FR 2248 (monthly), FR 2314
and FR 2314S (quarterly and semiannual), FR 2320 (quarterly), FR 2644 (weekly), FR 2886b
(quarterly), FR Y-7N and FR Y-7NS (quarterly), FR Y-8 (quarterly), FR Y-9C and FR Y-9LP
(quarterly), FR Y-9SP (semiannual), and FR Y-11 and FR Y-11S (quarterly and annual). 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 majority of survey respondents submit their FR 2248 data monthly to the Federal
Reserve Banks. Other finance companies in the panel submit their data directly to the Board on
a monthly basis. Respondents submit quarterly data for quarter-end months only. To help ease
the reporting burden on respondents, any semiannual special addendum questions would be sent
to the respondents approximately three weeks in advance of the report as-of date. This advance
notice would allow the respondents to submit the addendum data along with their regular
monthly data. The data are edited and transmitted to the Board for central processing. All data
are due at the Board on the 18th business day after the end of the month. Aggregate data are
published in the Board’s monthly statistical releases Consumer Credit (G.19) and Finance

28

Companies (G.20), in the quarterly statistical release Flow of Funds Accounts of the United
States (Z.1).
The FR 2314 and the FR Y-11 are filed quarterly as of the end of March, June,
September, and December, and companies must submit them within sixty days after the as of
date. Meeting the thresholds for filing quarterly is self-determined by the respondent and
ascertained as of the reporting date. The annual FR 2314 and FR Y-11, the FR 2314S, and the
FR Y-11S are filed as of December 31 and are also submitted within sixty days after the as of
date.
The FR 2320 is filed quarterly as of the end of March, June, September, and December.
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. The submission date
to file this report is 45 calendar days after the report date.
The FR 2644 is filed weekly, as of the close of business each Wednesday.
Edge corporations with assets of more than $50 million file the FR 2886b quarterly as of
the last calendar day of March, June, September and December. Edges with assets of
$50 million or less file annually as of December 31st. Edges file the FR 2886b within 30
calendar days of the as-of date. If necessary, a respondent is permitted to take an additional 15
calendar days to submit its completed report without requesting an extension.
Data from the FR 2886b report are included in three Board statistical releases: the
weekly H.6 release, Money Stock Measures, the weekly H.8 release, Assets and Liabilities of
Commercial Banks in the United States, and the quarterly Z.1 release, Financial Accounts of the
United States. These statistical releases are available on the Board’s public website:
www.federalreserve.gov/data.htm. FBOs are required to file the FR Y-7N (quarterly or
annually) and FR Y-7NS reports 60 days after the report date. All FBOs are required to file the
FR Y-7Q within 90 days after the report date. Respondents self-determine, as of the reporting
date, whether they meet the thresholds for filing quarterly.
FBOs are required to file the FR Y-7N (quarterly or annually) and FR Y-7NS reports
60 days after the report date. All FBOs are required to file the FR Y-7Q within 90 days after the
report date. Respondents self-determine, as of the reporting date, whether they meet the
thresholds for filing quarterly.
The FR Y-8 is submitted quarterly as of the last day of March, June, September, and
December. It is submitted within 30 calendar days after the as-of date. A 15-day extension may
be given to respondents that own banks with more than one foreign office. The FR Y-8 data are
confidential.
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

29

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 Y-9ES 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
FR 2248: The FR 2248 is authorized pursuant to section 2A of the Federal Reserve Act
(FRA) (12 U.S.C. 225a), which requires that the Board and the Federal Open Market Committee
(FOMC) maintain long-run growth of the monetary and credit aggregates commensurate with the
economy’s long run potential to increase production, so as to promote effectively the goals of
maximum employment, stable prices, and moderate long-term interest rates. In addition, under
section 12A of the FRA, the FOMC is required to implement regulations relating to the open
market operations conducted by Federal Reserve Banks. Those transactions must be governed
with a view to accommodating commerce and business and with regard to their bearing upon the
general credit situation of the country (12 U.S.C. 263). The Board and the FOMC use the
information obtained from the FR 2248 to help fulfill these obligations. The FR 2248 is
voluntary. The release of information collected on this form includes financial information that
is not normally disclosed by respondents, the release of which would likely cause substantial
harm to the competitive position of the respondent if made publicly available. The data collected
on this form, therefore, would be kept confidential under exemption 4 of Freedom of Information
Act (FOIA), which protects from disclosure trade secrets and commercial or financial
information (5 U.S.C. 552(b)(4)).
FR 2314, FR Y-7N, and FR Y-11 family of reports: The Board has the authority to
require BHCs and any subsidiary thereof, savings and loan holding companies and any
subsidiary thereof, and securities holding companies and any affiliate thereof to file the FR Y-11
and the FR 2314 pursuant to, respectively, section 5(c) of the Bank Holding Company Act of
1956 (BHC Act) (12 U.S.C. 1844(c)), section 10(b) of the Home Owners’ Loan Act (HOLA)
(12 U.S.C. 1467a(b)), and section 618 of the Dodd-Frank Wall Street Reform and Consumer
Protection Act (Dodd-Frank Act) (12 U.S.C. 1850a). The Board has the authority to require
SMBs, agreement corporations, and Edge corporations to file the FR 2314 pursuant to,
respectively, sections 9(6), 25(7), and 25A(17) of the FRA (12 U.S.C. 324, 602, and 625). With
respect to FBOs and their subsidiary IHCs, section 5(c) of the BHC Act, in conjunction with
section 8 of the International Banking Act of 1978 (IBA) (12 U.S.C. 3106), authorizes the board
to require FBOs and any subsidiary thereof to file the FR Y-11 reports, the FR 2314 reports,
FR Y-7N reports, and the FR Y-7Q. These reports are mandatory. Information collected in
these reports generally is not considered confidential. However, because the information is
collected as part of the Board’s supervisory process, certain information may be afforded
confidential treatment pursuant to exemption 8 of FOIA (5 U.S.C. 552(b)(8)). Individual
respondents may request that certain data be afforded confidential treatment pursuant to
exemption 4 of FOIA if the data has not previously been publically disclosed and the release of
the data would likely cause substantial harm to the competitive position of the respondent

30

(5 U.S.C. 552(b)(4)). Additionally, individual respondents may request that personally
identifiable information be afforded confidential treatment pursuant to exemption 6 of FOIA if
the release of the information would constitute a clearly unwarranted invasion of personal
privacy (5 U.S.C. 552(b)(6)). The applicability of these FOIA exemptions would be determined
on a case-by-case basis.
FR 2320: The FR 2320 is authorized pursuant to section 10(b) of HOLA (12 U.S.C.
1467a(b)). The FR 2320 is mandatory. The information collected on the FR 2320 is generally
not accorded confidential treatment with the exception of responses to line items 24, 25, and 26.
Responses to these line items are kept confidential under exemptions (b)(4) of FOIA, which
exempts from disclosure “trade secrets and commercial or financial information obtained from a
person and privileged or confidential” (5 U.S.C. 552(b)(4)), and (b)(8) of FOIA, which exempts
from disclosure information related to examination, operating, or condition reports prepared by,
on behalf of, or for the use of an agency responsible for the regulation or supervision of financial
institutions (5 U.S.C. 552(b)(8)). If confidential treatment is requested by a respondent for other
items in the FR 2320, the Board will review the request to determine if confidential treatment is
appropriate.
FR 2644: The FR 2644 is authorized pursuant to section 2A of the FRA (12 U.S.C.
225a), which requires that the Board and the FOMC maintain long-run growth of the monetary
and credit aggregates commensurate with the economy’s long run potential to increase
production, so as to promote effectively the goals of maximum employment, stable prices, and
moderate long-term interest rates. To accomplish these goals, section 11(a)(2) of the FRA
authorizes the Board to require depository institutions to provide whatever “reports of its
liabilities and assets as the Board may determine to be necessary or desirable to enable the Board
to discharge its responsibility to monitor and control monetary and credit aggregates” (12 U.S.C.
248(a)(2)). Branches and agencies of foreign banks are subject to the reporting requirements of
section 11(a)(2) of the FRA pursuant to section 7(c)(2) of the IBA (12 U.S.C. 3105(c)(2)). The
obligation to respond is voluntary. The release of information collected on this form includes
financial information that is not normally disclosed by respondents, the release of which would
likely cause substantial harm to the competitive position of the respondent if made publicly
available. The data collected on this form, therefore, would be kept confidential under
exemption 4 of FOIA, which protects from disclosure trade secrets and commercial or financial
information (5 U.S.C. 552(b)(4)).
FR 2886b: The Board has the authority to require Edge and agreement corporations to
submit the FR 2886b pursuant to sections 25 and 25A of the FRA (12 U.S.C. 602 and 625). The
FR 2886b is mandatory. For Edge and agreement corporations engaged in banking, current
Schedules RC-M (with the exception of item 3) and RC-V are held confidential pursuant to
section (b)(4) of FOIA (5 U.S.C. 552(b)(4)). For Edge and agreement corporations not engaged
in banking, only information collected on Schedule RC-M (with the exception of item 3) are
given confidential treatment pursuant to section (b)(4) of FOIA (5 U.S.C. 552(b)(4)).
FR Y-8: The FR Y-8 is authorized pursuant to section 5(c) of the BHC Act (12 U.S.C.
1844(c)), section 10(b)(2) of HOLA (12 U.S.C. 1467a(b)(2)), and section 23A of the FRA
(12 U.S.C. 371c). The FR Y-8 report is mandatory for any holding company that has engaged in

31

one or more covered transactions with an affiliate during the reporting period. The release of
data collected on this form includes financial information that is not normally disclosed by
respondents, the release of which would likely cause substantial harm to the competitive position
of the respondent if made publicly available. The data collected on this form, therefore, would
be kept confidential under exemption 4 of FOIA, which protects from disclosure trade secrets
and commercial or financial information (5 U.S.C. 552(b)(4)).
The FR Y-9 family of reports is authorized by section 5 of the BHC Act (12 U.S.C.
1844(c)(1)(A)) for BHCs, section 10 of HOLA (12 U.S.C. 1467(a)(b)(2)) for SLHCs, section
165 of the Dodd-Frank Act (12 U.S.C. 5365) for IHCs, and section 618 of the Dodd-Frank Act
(12 U.S.C. 1850a(c)(1)(A)) for supervised securities holding companies. These reports are
mandatory.
With respect to FR Y-9C, Schedule HI’s item 7(g) “FDIC deposit insurance
assessments,” Schedule HC-P’s item 7(a) “Representation and warranty reserves for 1-4 family
residential mortgage loans sold to U.S. government agencies and government sponsored
agencies,” and Schedule HC-P’s item 7(b) “Representation and warranty reserves for 1-4 family
residential mortgage loans sold to other parties” are considered confidential. Such treatment is
appropriate because the data is not publicly available and the public release of this data is likely
to impair the Board’s ability to collect necessary information in the future and could cause
substantial harm to the competitive position of the respondent. Thus, this information may be
kept confidential under exemptions (b)(4) of FOIA, which exempts from disclosure “trade
secrets and commercial or financial information obtained from a person and privileged or
confidential” (5 U.S.C. 552(b)(4)), and (b)(8) of FOIA, which exempts from disclosure
information related to examination, operating, or condition reports prepared by, on behalf of, or
for the use of an agency responsible for the regulation or supervision of financial institutions
(5 U.S.C. 552(b)(8)). If confidential treatment is requested by a respondent for other items in the
FR Y-9C, the Board will review the request to determine if confidential treatment is appropriate.
With respect to FR Y-9LP, FR Y-9SP, FR Y-ES, and FR Y-9CS, the information
collected would generally not be accorded confidential treatment. If confidential treatment is
requested by a respondent, the Board will review the request to determine if confidential
treatment is appropriate.
Consultation Outside the Agency
There has been no consultation outside of the agency.
Public Comments
On December 12, 2018, the Board published an initial notice in the Federal Register
(83 FR 63870) requesting public comment for 60 days on the extension, with revision, of the
FR 2248, FR 2314, FR 2314S, FR 2320, FR 2644, FR 2886b, FR Y-7N, FR Y-7NS, FR Y-7Q,
FR Y-8, FR Y-9C, FR Y-9LP, FR Y-9SP, FR Y-9ES, FR Y-9CS, FR Y-11, and FR Y-11S. The
comment period for this notice expired on February 11, 2019. The Board did not receive any

32

comments. On March 28, 2019, the Board published a final notice in the Federal Register (84
FR 11783).
Estimates of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2248 is 750
hours and will not change due to negligible burden associated with the changes. These reporting
requirements represent less than 1 percent of Board’s total paperwork burden.

FR 2248

Estimated
number of
respondents26

Annual
frequency

Estimated
average time
per response

Estimated
annual burden
hours

Monthly

150

8

20 minutes

400

Quarterly

150

4

30 minutes

300

Addendum

150

2

10 minutes

50
750

Total

The estimated total annual cost to the public for this information collection is $42,038
and will not change as a result of the adopted revisions.27

26

Of these respondents, 21 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.
27
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/.

33

As shown in the table below, the estimated total annual burden for the FR 2314 family of
reports is 13,467 hours and will increase to 14,664 hours. The average estimated hours per
response for the FR 2314 filers will increase from 6.6 hours to 7.2 hours, an increase of 0.6
hours. These reporting requirements represent less than 1 percent of the Board’s total paperwork
burden.
Estimated
Estimated
Annual
number of
average hours
frequency
respondents28
per response

FR 2314 and FR 2314S
Current
FR 2314 (quarterly)
FR 2314 (annual)
FR 2314S

439
239
300

4
1
1

6.6
6.6
1.0

11,590
1,577
300
13,467

Total

Proposed
FR 2314 (quarterly)
FR 2314 (annual)
FR 2314S

Estimated
annual burden
hours

439
239

4
1

7.2
7.2

12,643
1,721

300

1

1.0

300

Total

14,664

Change

1,197

The estimated total annual cost to the public for this information collection is $754,825
and would increase to $821,917 for the revised FR 2314.29

28

Of these respondents, 388 FR 2314 filers 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-sizestandards.
29
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/.

34

As shown in the table below, the estimated total annual burden for the FR 2320 is 130
hours and will not change due to negligible burden associated with the changes. These reporting
requirements represent less than 1 percent of the Board’s total paperwork burden.
Estimated
number of
respondents30
FR 2320

13

Estimated
Annual
average hours
frequency
per response
4

2.5

Estimated
annual burden
hours
130

The estimated total annual cost to the public of this information collection is $7,287 and
will not change as a result of the adopted revisions.31

30

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.
31

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/.

35

As shown in the table below, the estimated total annual burden for the FR 2644 is
106,925 hours and will not change due to negligible burden associated with the changes. These
reporting requirements represent less than 1 percent of the Board’s total paperwork burden.

FR 2644

Estimated
number of
respondents32
875

Annual
frequency
52

Estimated
average hours
per response
2.35

Estimated
annual burden
hours
106,925

The estimated total annual cost to the public for this information collection is $5,993,146
and will not change as a result of the adopted revisions.33

32

Of the actual respondents, 310 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.
33
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/.

36

As shown in the table below, the estimated total annual burden for the FR 2886b is 1,433
hours and will increase to 1,652 hours. The average estimated hours per response for the (1)
quarterly banking FR 2886b filers will increase from 15.15 hours to 15.77 hours, an increase of
0.62 hours; (2) annual banking FR 2886b filers will increase from 15.15 hours to 15.87 hours, an
increase of 0.72 hours; (3) quarterly investment FR 2886b filers will increase from 9.6 hours to
11.81 hours, an increase of 2.21 hours; and (4) annual investment FR 2886b filers will increase
from 9.6 hours to 10.82 hours, an increase of 1.22 hours. The estimated reporting burden is
lower for investment Edges, which file only 4 supporting schedules, than for banking Edges,
which file all 11 supporting schedules. These reporting requirements represent less than 1
percent of the Board’s total paperwork burden.
Estimated
Annual
number of
frequency
respondents34

FR 2886b
Current
Banking
Edge and agreement
corporations (quarterly)
Edge and agreement
corporations (annual)
Investment
Edge and agreement
corporations (quarterly)
Edge and agreement
corporations (annual)

Estimated
average hours
per response

Estimated
average hours
per response

9

4

15.15

545

1

1

15.15

15

21

4

9.6

806

7

1

9.6

67
1,433

9

4

15.77

568

1

1

15.87

16

21

4

11.81

992

7

1

10.82

Total

76
1,652

Change

219

Total
Proposed
Banking
Edge and agreement
corporations (quarterly)
Edge and agreement
corporations (annual)
Investment
Edge and agreement
corporations (quarterly)
Edge and agreement
corporations (annual)

34

Of these respondents, 19 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.
Respondent count is as of December 31, 2017.

37

The estimated total annual cost to the public for this information collection is $80,320
and would increase to $92,595 for the revised FR 2886b.35

35

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/.

38

As shown in the table below, the estimated total annual burden for the FR Y-7N,
FR Y-7NS, and FR Y-7Q is 2,707 hours and will increase to 2,834 hours. The average estimated
hours per response for the FR Y-7N filers will increase from 6.8 hours to 7.6 hours, an increase
of 0.8 hours. The average estimated hours per response for the FR Y-7NS and FR Y-7Q filers
will remain unchanged. These reporting requirements represent less than 1 percent of the
Board’s total paperwork burden.
Estimated
number of
respondents36
Current
FR Y-7N (Quarterly)
FR Y-7N (Annual)
FR Y-7NS
FR Y-7Q (Quarterly)
FR Y-7Q (Annual)

Estimated
Annual
average hours
frequency
per response

35
19
22
130
29

4
1
1
4
1

6.8
6.8
1
3
1.5

952
129
22
1,560
44
2,707

35
19
22
130
29

4
1
1
4
1

7.6
7.6
1
3
1.5

1,064
144
22
1,560
44

Total
Proposed
FR Y-7N (Quarterly)
FR Y-7N (Annual)
FR Y-7NS
FR Y-7Q (Quarterly)
FR Y-7Q (Annual)

Estimated
annual burden
hours

Total

2,834

Change

127

The estimated total annual cost to the public for this information collection is $151,727
and would increase to $158,846 for the revised FR Y-7N, FR Y-7NS, and FR Y-7Q.37

36

Of these respondents, 1 FR Y-7N (quarterly), 5 FR Y-7N (annual), 22 FR Y-7NS, and 0 FR Y-7Q respondents
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. The respondent counts (approximate)
are as of December 31, 2017.
37
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/.

39

As shown in the table below, the estimated total annual burden for the FR Y-8 is 29,110
hours and will not change due to negligible burden associated with the changes. These reporting
requirements represent less than 1 percent of the Board’s total paperwork burden.

FR Y-8

Estimated
number of
respondents38

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

933

4

7.8

29,110

The estimated total annual cost to the public for this information collection is $1,631,616
and will not change as a result of the adopted revisions.39

38

Of the respondents, 502 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. For
purposes of this burden table, the number of respondents represents the number of FR Y-8 reporting forms filed.
39
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/.

40

As shown in the table below, the estimated total annual burden for the FR Y-9 family of
reports is 110,898 hours and will increase to 110,959 hours. The average estimated hours per
response for non-advanced approaches FR Y-9C filers will increase from 46.29 hours to 46.34
hours, an increase of 0.05 hours. The average estimated hours per response for advanced
approaches FR Y-9C filers will increase from 47.54 hours to 47.59 an increase of 0.05 hours.
The average estimated hours per response for the FR Y-9LP, FR Y-9SP, FR Y-9ES, and
FR Y-9CS filers will remain unchanged. These reporting requirements represent less than 1
percent of the Board’s total paperwork burden.
Estimated
number of
respondents40

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

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

292
18
338
4,238
82
236

4
4
4
2
1
4

46.29
47.54
5.27
5.40
0.50
0.50

54,067
3,423
7,125
45,770
41
472
110,898

292
18
338
4,238
82
236

4
4
4
2
1
4

46.34
47.59
5.27
5.40
0.50
0.50

Total

54,125
3,426
7,125
45,770
41
472
110,959

Change

61

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 estimated total annual cost to the public for this information collection is $6,215,833
and would increase to $6,219,252 for the revised FR Y-9.41

40

Of these respondents, 3,750 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.
Respondent count is as of December 31, 2017, for the FR Y-9C, FR Y-9LP, and the FR Y-9SP. The FR Y-9ES
count is an estimate based on current NIC structure and the FR Y-9CS count is based on the last use of the report.
41
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/.

41

As shown in the table below, the estimated total annual burden for the FR Y-11 family of
reports is 13,662 hours and will increase to 15,237 hours. The average estimated hours per
response for FR Y-11 filers will increase from 6.8 hours to 7.6 hours, an increase of 0.8 hours.
The average estimated hours per response for the FR Y-11S filers will remain unchanged. These
reporting requirements represent less than 1 percent of the Board’s total paperwork burden.

FR Y-11 and FR Y-11S
Current
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S

Estimated
number of
respondents42

Annual
frequency

Estimated
average hours
per response

Estimated
annual burden
hours

445
189
273

4
1
1

6.8
6.8
1.0

12,104
1,285
273
13,662

445
189
273

4
1
1

7.6
7.6
1.0

Total

13,528
1,436
273
15,237

Change

1,575

Total
Proposed
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S

The estimated total annual cost to the public for this information collection is $765,755
and would increase to $854,034 for the revised FR Y-11.43
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 the FR 2248 is $92,106 per year.
The estimated cost the Federal Reserve System for the FR 2314 reports is $83,200 per year. The
estimated cost the Federal Reserve System for the FR 2320 is $21,100 per year. The estimated
cost to the Federal Reserve Syste for the FR 2644 is $2,417,200 per year. The estimated cost to
the Federal Reserve System for the FR 2886b is $204,300 per year. The estimated cost to the
42

Of the respondents, 615 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.
43
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/.

42

Federal Reserve System for the FR Y-7N reports is $126,900 per year. The estimated cost for
the FR Y-8 is $145,200 per year. The estimated cost to the Federal Reserve System for the
FR Y-9 reports is $2,335,200 per year. The estimated cost to the Federal Reserve System for the
FR Y-11 reports is $110,600 per year.

43

Appendix A – Effective Dates for CECL by Entity Type
Effective Dates for ASU 2016-13
Regulatory
U.S. GAAP Effective Date

Report Effective
Date*

PBEs That
Fiscal years beginning after 12/15/2019, including interim
03/31/2020

Are SEC
periods within those fiscal years
Filers
Other PBEs
Fiscal years beginning after 12/15/2020, including interim

03/31/2021

(Non-SEC
periods within those fiscal years
Filers)
Fiscal years beginning after 12/15/2020, and interim

12/31/202145

Non-PBEs
periods for fiscal years beginning after 12/15/202144

First calendar
Early application permitted for fiscal years beginning after quarter-end after
Early
12/15/2018, including interim periods within those fiscal

effective date of

years

early application of

Application

the ASU

*For institutions with calendar fiscal year-ends and reports with quarterly report dates.
For institutions that are PBEs and also are SEC filers, as both terms are defined in U.S.
GAAP, the new credit losses standard is effective for fiscal years beginning after December 15,
2019, including interim periods within those fiscal years. Thus, for an SEC filer that has a
44
45

See footnote 46
See footnote 47

44

calendar year fiscal year, the standard is effective January 1, 2020, and institutions must first
apply the new credit losses standard in its FR 2314, FR 2320, FR 2886b, FR Y-7N, FR Y-8,
FR Y-9C, FR Y-9LP and FR Y-11 report for the quarter ended March 31, 2020. For the
FR 2248, FR 2644, and the FR Y-9SP reporters must first apply the new credit losses standard
January 31, 2020, January 1, 2020, and June 30, 2020, respectively.
For a PBE that is not an SEC filer, the credit losses standard is effective for fiscal years
beginning after December 15, 2020, including interim periods within those fiscal years. Thus,
for a PBE that is not an SEC filer and has a calendar year fiscal year, the standard is effective
January 1, 2021, and the institution must first apply the new credit losses standard in its FR 2314,
FR 2320, FR 2886b, FR Y-7N, FR Y-8, FR Y-9C, FR Y-9LP, and FR Y-11 for the quarter ended
March 31, 2021. For the FR 2248, FR 2644, and the FR Y-9SP reporters must first apply the
new credit losses standard, January 31, 2021, January 6, 2021, and June 30, 2021, respectively.
For an institution that is not a PBE, the credit losses standard is effective for fiscal years
beginning after December 15, 2020, and for interim period financial statements for fiscal years
beginning after December 15, 2021.46 Thus, an institution with a calendar year fiscal year that is
not a PBE must first apply the new credit losses standard in its FR 2248, FR 2314, FR 2320,
FR 2886b, FR Y-7N, FR Y-8, FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-11 for December 31,
2021, if the institution is required to file such form.47 The FR 2644 reporters must first apply the
new credit losses standard January 5, 2022. However, where applicable, institutions would
include the CECL provision for expected credit losses for the entire year ended December 31,
2021, in the income statement in its report for year-end 2021. The institution would also
recognize in its year-end 2021 report a cumulative-effect adjustment to the beginning balance of
retained earnings as of January 1, 2021, resulting from the adoption of the new standard as of the
beginning of the 2021 fiscal year.
For regulatory reporting purposes, early application of the new credit losses standard will
be permitted for all institutions for fiscal years beginning after December 15, 2018, including
interim periods within those fiscal years.

46

On August 8, 2018, FASB issued a proposed ASU that would amend the transition and effective date provisions
in ASU 2016-13 for entities that are not PBEs (non-PBEs) so that the credit losses standard would be effective for
non-PBEs for fiscal years beginning after December 15, 2021, including interim periods within those fiscal years.
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If the FASB issues a final Accounting Standards Update amending the transition and effective date provisions in
ASU 2016-13 as described in footnote 46, a non-PBE with a calendar year fiscal year would first apply the new
credit losses standard in its reports for March 31, 2022, if an institution is required to file these report forms.

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Appendix B – U.S. GAAP Changes as a result of CECL
Introduction of a new credit loss methodology
The new accounting standard developed by the FASB has been designed to replace the
existing incurred loss methodology in U.S. GAAP. Under CECL, the allowance for credit losses
is an estimate of the expected credit losses on financial assets measured at amortized cost, which
is measured using relevant information about past events, including historical credit loss
experience on financial assets with similar risk characteristics, current conditions, and reasonable
and supportable forecasts that affect the collectability of the remaining cash flows over the
contractual term of the financial assets. In concept, an allowance will be created upon the
origination or acquisition of a financial asset measured at amortized cost. At subsequent
reporting dates, the allowance will be reassessed for a level that is appropriate as determined in
accordance with CECL. The allowance for credit losses under CECL is a valuation account,
measured as the difference between the financial assets’ amortized cost basis and the amount
expected to be collected on the financial assets, i.e., lifetime expected credit losses.
Reduction in the number of credit impairment models
Impairment measurement under existing U.S. GAAP has often been considered complex
because it encompasses five credit impairment models for different financial assets.48 In
contrast, CECL introduces a single measurement objective to be applied to all financial assets
carried at amortized cost, including HFI loans and HTM debt securities. That said, CECL does
not specify a single method for measuring expected credit losses; rather, it allows any reasonable
approach, as long as the estimate of expected credit losses achieves the objective of the FASB’s
new accounting standard. Under the existing incurred loss methodology, institutions use various
methods, including historical loss rate methods, roll-rate methods, and discounted cash flow
methods, to estimate credit losses. CECL allows the continued use of these methods; however,
certain changes to these methods will need to be made in order to estimate lifetime expected
credit losses.
Purchased credit-deteriorated (PCD) financial assets
CECL introduces the concept of PCD financial assets, which replaces purchased creditimpaired (PCI) assets under existing U.S. GAAP. The differences in the PCD criteria compared
to the existing PCI criteria will result in more purchased loans HFI, HTM debt securities, and
available-for-sale (AFS) debt securities being accounted for as PCD financial assets. In contrast
to the existing accounting for PCI assets, the new standard requires the estimate of expected
credit losses embedded in the purchase price of PCD assets to be estimated and separately
recognized as an allowance as of the date of acquisition. This is accomplished by grossing up
board the purchase price by the amount of expected credit losses at acquisition, rather than being
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Current U.S. GAAP includes five different credit impairment models for instruments within the scope of CECL:
ASC Subtopic 310-10, Receivables-Overall; ASC Subtopic 450-20, Contingencies-Loss Contingencies; ASC
Subtopic 310-30, Receivables-Loans and Debt Securities Acquired with Deteriorated Credit Quality; ASC Subtopic
320-10, Investments-Debt and Equity Securities - Overall; and ASC Subtopic 325-40, Investments-Other-Beneficial
Interests in Securitized Financial Assets.

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reported as a credit loss expense. As a result, as of acquisition date, the amortized cost basis of a
PCD financial asset is equal to the principal balance of the asset less the non-credit discount,
rather than equal to the purchase price as is currently recorded for PCI loans.
AFS debt securities
The new accounting standard also modifies the existing accounting practices for
impairment on AFS debt securities. Under this new standard, institutions will recognize a credit
loss on an AFS debt security through an allowance for credit losses, rather than a direct writedown as is required by current U.S. GAAP. The recognized credit loss is limited to the amount
by which the amortized cost of the security exceeds fair value. A write-down of an AFS debt
security’s amortized cost basis to fair value, with any incremental impairment reported in
earnings, would be required only if the fair value of an AFS debt security is less than its
amortized cost basis and either (1) the institution intends to sell the debt security, or (2) it is more
likely than not that the institution will be required to sell the security before recovery of its
amortized cost basis.
Although the measurement of credit loss allowances is changing under CECL, the
FASB’s new accounting standard does not address when a financial asset should be placed in
nonaccrual status. Therefore, institutions should continue to apply the agencies’ nonaccrual
policies that are currently in place. In addition, the FASB retained the existing write-off
guidance in U.S. GAAP, which requires an institution to write off a financial asset in the period
the asset is deemed uncollectible.

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