FFIEC 009 Country Exposure Report

Draft

FFIEC 009 – Country Exposure Report
Proposed Revisions to the FFIEC 009
for September 30, 2016

The attached draft revised FFIEC 009 cover page and
draft revised General Instructions section
of the Instructions for the Preparation of the Country Exposure Report
reflect the proposed revisions described in the federal banking agencies’
final Paperwork Reduction Act Federal Register notice
published in the Federal Register on July 20, 2016.
The Federal Register notice for these proposed Call Report revisions
is available at http://www.ffiec.gov/forms009_009a.htm.

NOTE: The agencies have not proposed any revisions to the four schedules
of the FFIEC 009 reporting form or to the rest of the
Instructions for the Preparation of the Country Exposure Report.

Draft as of July 20, 2016

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Board of Governors of the Federal Reserve System OMB Number 7100-0035
Federal Deposit Insurance Corporation
OMB Number 3064-0017
Office of the Comptroller of the Currency
OMB Number 1557-0100
Approval expires
Page 1 of 34

Federal Financial Institutions Examination Council

Country Exposure Report—FFIEC 009

Report at the close of business
Month / Day / Year

This report is required to be filed pursuant to authority contained in the
following statutes: 12 U.S.C. §§ 161 and 1817 (national banks), 12 U.S.C. § 1464
(federal savings associations), 12 U.S.C. §§ 248(a), 1844(c), and 3906 (state
member banks and bank holding companies); 12 U.S.C. §§ 1467a(b)(2) and
5412 (savings and loan holding companies); 12 U.S.C. 5365(a)
(intermediate holding companies); and 12 U.S.C. §§ 1817 and 1820
(insured state nonmember commercial and savings banks and insured state
savings associations).

All FFIEC 009 respondents must submit their completed report via the Federal
Reserve System's Reporting Central application within 45 days of the reporting
date for March 31, June 30, and September 30, and within 50 calendar days of the
December 31 reporting date. Any FFIEC 009 respondent who needs guidance on
Reporting Central is encouraged to visit the Federal Reserve System website
http://www.frbservices.org/centralbank/reportingcentral/index.html, for additional
information.
Each report submitted should be signed and certified by an executive officer
of the reporting institution. "Executive Officer" is defined in 12 C.F.R. § 215.2
(e)(1). To fulfill the signature and attestation requirement for the Country
Exposure Report for this report date, attach a signed copy of this page (or a
photocopy or a computer-generated version of this page) to the paper-copy
record of the completed report that the respondent places in its files.

, an authorized officer
Title

Day

City

, that this
Month

Year

report has been examined by me and is true and complete to the best of my
knowledge and belief.

Reporting Institution

Area Code / Phone Number

,
Name

day of
Charter Number (National Banks Only)

Title

I,

of the reporting institution named above, hereby certify on the

Name, title, and phone number of the person to whom inquiries regarding this
report may be directed:

Name

The Board of Governors of the Federal Reserve System, the Office of the
Comptroller of the Currency, and the Federal Deposit Insurance Corporation
are of the view that individual respondent information reported on this form is
exempt from public disclosure under Section (b)(8) of the Freedom of
Information Act (5 U.S.C. § 552 (b)(8)). Accordingly, individual respondent
information reported on this form will be considered confidential and will not be
voluntarily disclosed by the Office of the Comptroller of the Currency, the
Federal Reserve System, or the Federal Deposit Insurance Corporation.

State

Signature

Legal Entity Identifier (LEI) of the Reporting Institution (Report only if the reporting institution
already has an LEI.)

Public reporting burden for this collection of information is estimated to average 131 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. A federal agency may not conduct or sponsor, and
an organization (or a person) is not required to respond to a collection of information, unless it displays a currently valid OMB control number. Comments concerning the accuracy of this burden estimate and suggestions for reducing this burden should be directed to the Office of Information and Regulatory Affairs, Office of Management
and Budget, Paperwork Reduction Project, Washington, DC 20503, and to one of the following: Secretary, Board of Governors of the Federal Reserve System, 20th and C Streets, NW, Washington, DC 20551; Assistant Executive Secretary, Federal Deposit Insurance Corporation, Washington, DC 20429; and Legislative and Regulatory
Analysis Division, Office of the Comptroller of the Currency, Washington, DC 20219.
9/2016

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Instructions for the Preparation of the
Country Exposure Report
(FFIEC 009)
Draft Revised General Instructions
I.

General Instructions

A. Introduction and Purpose
The FFIEC 009 provides information on the distribution, by country, of claims on, and liabilities to,
foreign residents held by United States banks, savings associations, bank holding companies, savings and
loan holding companies, and intermediate holding companies. The data collected are used to determine
the presence of credit and related risks, including transfer and country risk. These data are also aggregated
and released to the public. Aggregate data are provided to the Bank for International Settlements (BIS),
as part of an international cooperative effort to compile and publish global data on claims on foreign
residents. The aggregated data, along with applicable individual data reported on the FFIEC 009a, are
available electronically through the E.16 Statistical Release (located at: http://www.ffiec.gov/E16.htm).
B. Summary Description of this Report
The FFIEC 009 consists of four schedules (with one, Schedule C, containing two parts). Schedule C, Part
I, collects information on the claims on an “immediate-counterparty” basis, i.e., on the basis of the country
of residence of the borrower (except claims resulting from the fair value of derivative contracts). Part I also
includes the redistribution of immediate-counterparty claims to an “ultimate-risk” basis, i.e., on the basis
of the country of residence of the guarantor or collateral provided (i.e., the “ultimate obligor”). In
Columns 1 through 12 of Part I, data are collected on an immediate-counterparty basis. In Columns 13
through 22 of Part I, the inward and outward redistribution of claims from an immediate-counterparty
basis to an ultimate-risk basis is shown. These redistributions arise from arrangements such as formal
guarantees, the provision of collateral, and the purchase of credit protection as defined in Sections II.F
and II.H.
Schedule C, Part II, collects information on the reporter’s claims on an ultimate-risk basis and
memorandum items providing additional details related to those claims. Claims on an ultimate-risk basis
are shown in Columns 1 through 11 of Schedule C, Part II. Schedule C, Part II, also contains
memorandum items relating to claims reported on an ultimate-risk basis. Column 12 shows the amounts
reported in Columns 1 through 10 of Schedule C, Part II, that are held-to-maturity and available-for-sale
securities. Columns 13 through 16 collect information on collateral mitigants that do not meet the criteria
for the purposes of risk transfers of claims as defined in this report. Column 17 shows the amount of
claims, on an ultimate-risk basis (reported in Columns 1 through 10 of Part II), that are held for trading.
Column 18 provides any offsetting positions held for the trading book, where an effective offset exists
(see Section II.G for a discussion of effective netting and offsetting).
Schedule L collects information on foreign-office liabilities. Columns 1 and 2 show, by country and
currency, foreign-office liabilities for which no payment is guaranteed at locations outside the country of
the office, reported by the country of the foreign office. Column 3 shows all liabilities booked at foreign
offices by the country of the creditor. Column 4 shows the net positions of the foreign office with related
offices in other countries. These net positions are not reported elsewhere on this report, due to the
consolidation rules.
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Schedule O collects information on off-balance-sheet exposures from commitments, guarantees, and
credit derivatives. Column 1 collects any unused or undrawn commitments, on an ultimate-risk basis, by
country of the ultimate obligor of the commitment. In Column 2, the amount of all legally binding
guarantees provided, except credit derivatives written, are reported by country of the counterparty to
whom the guarantee is being provided. Columns 3 through 6 provide a breakdown of the notional amount
of credit derivatives positions purchased and sold (by country of the reference entity), on a gross-gross and
gross-net basis (see Section II.H for definitions of these terms). Credit derivatives purchased that
result in a risk transfer on Schedule C, Parts I and II, are excluded from this schedule. Column 7
shows the claims, on an ultimate-risk basis (reported in Columns 1 through 10 of Schedule C, Part II, and
Columns 1 and 2 of Schedule O), that are trade finance related.
Schedule D collects information on the fair value of derivative contracts of the reporter by country of
counterparty (including the United States). A sector distribution and the total are collected in Columns 1
through 5. In Column 6, claims on bank branches that are not formally and legally guaranteed by the head
office are reported in the country rows corresponding to the country in which the branch is located (instead
of the country of the head office). These claims represent risk that could potentially remain in the
countries in which the branches are located.
C. Administrative Issues
1. Authority
This report is required to be filed by national banks, federal savings associations, state member banks,
bank holding companies, savings and loan holding companies, intermediate holding companies, insured
state nonmember commercial and savings banks, and insured state savings associations pursuant to
authority contained in the following statutes:
Board of Governors of the Federal Reserve System – Section 11a of the Federal Reserve
Act (12 U.S.C. 248a), Section 5c of the Bank Holding Company Act (12 U.S.C. 1844c),
Section 907 of the International Lending Supervision Act of 1983 (12 U.S.C. 3906), and
Section 165(a) of the Dodd-Frank Act (12 U.S.C. 5365(a));
Office of the Comptroller of the Currency – the National Bank Act, as amended (12
U.S.C. 161) and Home Owners Loan Act (12 U.S.C. 1464); and
Federal Deposit Insurance Corporation – Sections 7 and 10 of the Federal Deposit
Insurance Act (12 U.S.C. 1817 and 1820).
2. Confidentiality
The individual FFIEC 009 reports are given confidential treatment under 5 U.S.C. 552(b)(4) and (b)(8).
However, aggregated data that do not reveal the activities of individual banks do not receive confidential
treatment and are made public. Portions of the aggregated data are also reported to the Bank for
International Settlements as part of an international cooperative effort to compile and publish worldwide
data on cross-border claims.

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D. Who Must Report
Reportable Entities
The Country Exposure Report (FFIEC 009) is required to be filed quarterly by banks, savings
associations, bank holding companies, savings and loan holding companies, and intermediate holding
companies meeting the criteria listed below:
Schedules C, L, and O must be completed by:
(1) Every U.S. chartered insured bank or savings association in the 50 States of the United States, the
District of Columbia, Puerto Rico, and U.S. territories and possessions, that has, on a fully consolidated
basis, total outstanding claims on residents of foreign countries exceeding $30 million in the aggregate,
and has at least one of the following:
•
•
•
•

•

A branch in a foreign country;
A consolidated subsidiary in a foreign country;
An Edge or Agreement subsidiary;
A branch in Puerto Rico or in any U.S. territory or possession (except that a bank or savings
association with its head office in Puerto Rico or any U.S. territory or possession need not report if it
meets only this criterion); or
An International Banking Facility (IBF).

All references to “bank(s)” are inclusive of “savings association(s),” unless otherwise noted.
(2) Every Edge and/or Agreement corporation that has total outstanding claims on residents of foreign
countries exceeding $30 million, unless it is majority owned by a bank or savings association that is
required to file a report.
(3) Every institution that meets the Schedule D reporting requirements (see below).
(4) Every U.S. bank holding company that is required to file the FR Y-6 report (Bank Holding Company
Annual Report) and has a subsidiary bank that is required to file this report.
(5) Every savings and loan holding company that meets the criteria for banks in (1) above.1
(6) Every intermediate holding company that meets the criteria for banks in (1) above.
All references to “bank holding company(s)” are inclusive of “savings and loan holding company(s)” and
“intermediate holding company(s),” unless otherwise noted.

1

Savings and loan holding companies (SLHCs) do not include any trust (other than a pension, profitsharing, stockholders’ voting, or business trust) which controls a savings association if such trust by its
terms must terminate within 25 years or not later than 21 years and 10 months after the death of
individuals living on the effective date of the trust, and (a) was in existence and in control of a savings
association on June 26, 1967, or, (b) is a testamentary trust.

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However, to reduce reporting burden:
(1) If a bank holding company has only one subsidiary bank that meets the reporting requirements and
that subsidiary bank accounts for 90 percent or more of the consolidated holding company’s total claims
on foreigners, either the holding company or the bank (but not both) should prepare a report. However, if
the only subsidiary bank that is required to report accounts for less than 90 percent of the consolidated
holding company’s claims, only the holding company should prepare a (consolidated) report.
(2) If a bank holding company has two or more subsidiary banks that meet the reporting requirements and
these subsidiary banks, together, account for 90 percent or more of the consolidated holding company’s
total claims on foreigners, the holding company need not file a separate report.
Column 3 of Schedule L—Total Liabilities Booked at Foreign Offices (by country of creditor)—is
required to be reported only by those reporters that have one or more branches or subsidiaries located
outside the fifty states of the United States, the District of Columbia, or a U.S. military facility (regardless
of where located) that meet the following criteria:
•

Branches filing the Foreign Branch Report of Condition (FFIEC 030) that report total assets of
$500 million or more (denominated in all currencies) on Line Item 11 on a report date,

•

Subsidiaries filing the quarterly Financial Statements of Foreign Subsidiaries of U.S. Banking
Organizations (FR 2314) that have a banking charter and engage in banking business, and that
report $2 billion or more in total assets in Schedule BS, item 10, and $10 million or more in
total deposits in Schedule BS-M, item 6.

The total assets test defined above applies to the total of the foreign branch’s or subsidiary’s international
and local assets, regardless of the currency in which the assets are payable. If any foreign office of a
reporter exceeds the reporting threshold, then column should 3 be completed for the reporter’s entire
organization and not just for the offices exceeding the threshold.
A Schedule D must be completed by every institution whose FFIEC 031 or FR Y-9C (or for Edge and/or
Agreement corporations the FR 2886b) as of December 31 of the previous year shows:
(1) Total gross notional values of derivative contracts (the sum of items 7.a.(1) through 7.a.(4),
Columns A and B, and items 12.a through 12.e, Columns A through D, on Schedule RC-L of the
FFIEC 031 or the sum of items 7.a.(1) through 7.a.(4), Columns A and B, and items 11.a through
11.e, Columns A through D, on Schedule HC-L of the FR Y-9C) in excess of $10 billion.
or
(2) Total gross fair values of derivative contracts (the sum of items 7.b.(1) and 7.b.(2), Columns A
and B and items 15.a and 15.b, Columns A through D, on Schedule RC-L of the FFIEC 031 or the
sum of items 7.b.(1) and 7.b.(2), Columns A and B, and items 14.a and 14.b, Columns A through D,
on Schedule HC-L of the FR Y-9C) in an amount greater than 5 percent of their total assets.
In addition, the bank regulatory authorities may specifically require a report (or any specific schedule
therein) to be filed by other banking organizations that the authorities deem to have significant country
exposures.

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Consolidation Rules
The information should be reported on a fully consolidated basis. For reports from banks, the scope of
coverage and the consolidation of information should be in accordance with the procedures and tests of
significance set forth in the instructions for preparation of the FFIEC 031. For reports from bank holding
companies, the information should be consolidated in accordance with the principles set forth in the
instructions for the preparation of the FR Y-9C. For Edge and/or Agreement corporations, the information
should be consolidated in accordance with the principles set forth in the instructions for the preparation of
the FR 2886b.
As a best practice, the data reported on the FFIEC 009 can be reconciled to the FR Y-9C (or Call Report).
However, there are no requirements to perform such a reconciliation.
E. Accounting Issues
All amounts should be reported in U.S. dollars regardless of the currencies in which the balances are
denominated. The translations should be made on the same basis used to prepare its (or its subsidiary
bank’s) FFIEC 031 and the FR Y-9C.
Claims, liabilities, and unused commitments should be reported using the same accounting basis as used
on the FFIEC 031 and FR Y-9C, unless stated otherwise in these instructions.
Edge and/or Agreement corporations should reference the instructions for the preparation of the
FFIEC 031 for further information on reporting definitions and generally accepted accounting principles.
Round all amounts reported on this form to the nearest million dollars. Negative amounts are only
permissible in Column 4 of Schedule L.
1. Differences between FFIEC 009 Reporting and U.S. GAAP
The differences in accounting treatment between the FFIEC 009 and U.S. GAAP are as follows:2
Reporting Item
U.S. GAAP
FFIEC 009
Netting of Derivative Offsetting of positive and negative fair values Offsetting of positive and negative fair
are permitted when a “right of setoff” exists
values is permitted, consistent with
Contracts
under ASC Subtopic 210-20, Balance SheetU.S. GAAP. However, only net positive
Offsetting (formerly FASB Interpretation
fair values are reported on the FFIEC 009.
No. 39, Offsetting of Amounts Related to Certain
Contracts).
Netting of Trading
Assets

Although there is no official FASB
pronouncement, it is industry practice to net
trading assets against trading liabilities in the
same security (i.e., with the same CUSIP or
ISIN).

2

CUSIP netting is allowed for the FFIEC
009 report. In addition, short positions in
the same issuer and asset class of the
trading asset may be reported as an
offsetting position on Schedule C, Part II,
Column 18.

In the previous version of this report it was required that available-for-sale securities be reported at
amortized cost instead of fair value. This treatment is no longer required.
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F. Submission of Reports
The FFIEC 009 report is to be prepared quarterly, as of the last calendar day of March, June, September,
and December. For each quarter the reporting requirements are met (according to Section I.D), all
reporters must use the Federal Reserve System’s Reporting Central system to submit their completed
report to the Federal Reserve Bank of New York (FRBNY). The submission deadline is 45 calendar days
after the March 31, June 30, and September 30 as of date. The submission deadline is 50 calendar days
after the December 31 as of date.
If the submission deadline falls on a weekend or holiday, the report must be received on the first business
day after the Saturday, Sunday, or holiday.
The Federal Reserve System Website http://www.frbservices.org/centralbank/index.html provides
additional information on Reporting Central. The Website also includes a link that reporters may use to
contact FRBNY for technical assistance.
Each reporter should keep a copy of each report. This copy should be signed and certified by an
Executive Officer (as defined in 12 CFR 215.2(e)(1)) of the bank or bank holding company.
G. Legal Entity Identifier (LEI)
The LEI is a 20-digit alpha-numeric code that uniquely identifies entities that engage in financial
transactions. A reporter must provide its LEI on the cover page of this report only if it already has an
LEI. The LEI must be a currently issued, maintained, and valid LEI, not an LEI that has lapsed. If a
reporter does not have an LEI, it is not required to obtain one for purposes of reporting it on this report.

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