FRY9_20191220_omb

Supporting Statement for the
Financial Statements for Holding Companies
(FR Y-9; OMB No. 7100-0128)
Prudential Standards for Large Bank Holding Companies,
Savings and Loan Holding Companies, and Foreign Banking Organizations
(Docket No. R-1658; RIN 7100-AF45)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Financial Statements for Holding Companies (FR Y-9; OMB No. 7100-0128). This
information collection comprises the following five reports:
 Consolidated Financial Statements for Holding Companies (FR Y-9C),
 Parent Company Only Financial Statements for Large Holding Companies (FR Y-9LP),
 Parent Company Only Financial Statements for Small Holding Companies (FR Y-9SP),
 Financial Statements for Employee Stock Ownership Plan Holding Companies
(FR Y-9ES), and
 Supplement to the Consolidated Financial Statements for Holding Companies
(FR Y-9CS).
The Board requires bank holding companies (BHCs), most savings and loan holding
companies (SLHCs),1 securities holding companies, and U.S. intermediate holding companies
(IHCs) (collectively, HCs) to provide standardized financial statements through one or more of
the FR Y-9 reports. The information collected on the FR Y-9 reports is necessary for the Board
to identify emerging financial risks and monitor the safety and soundness of HC operations.
The Board adopted a final rule that establishes risk-based categories for determining
prudential standards for large U.S. banking organizations and foreign banking organizations,
consistent with section 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act
(Dodd-Frank), as amended by the Economic Growth, Regulatory Relief, and Consumer
Protection Act (EGRRCPA), and with the Home Owners’ Loan Act (HOLA). The final rule
amends certain prudential standards, including standards relating to liquidity, risk management,
stress testing, and single-counterparty credit limits, to reflect the risk profile of banking
organizations under each category; applies prudential standards to certain large SLHCs using the
same categories; makes corresponding changes to reporting forms; and makes additional
modifications to the Board’s company-run stress test and supervisory stress test rules, consistent
with section 401 of EGRRCPA. The final rule is effective December 31, 2019.
The Board amended the FR Y-9C to clarify requirements for HCs subject to Category III
capital standards. The final rule amended those instructions to further clarify that the
1

An SLHC must file one or more of the FR Y-9 family of reports unless it is (1) a grandfathered unitary SLHC with
primarily commercial assets and thrifts that make up less than 5 percent of its consolidated assets or (2) a SLHC that
primarily holds insurance-related assets and does not otherwise submit financial reports with the U.S. Securities and
Exchange Commission (SEC) pursuant to section 13 or 15(d) of the Securities Exchange Act of 1934.

supplementary leverage ratio and countercyclical buffer also apply to Category III BHCs,
Category III SLHCs, and Category III U.S. IHCs. The FR Y-9LP is revised to require covered
SLHCs with total consolidated assets of $100 billion or more to report total nonbank assets on
Schedule PC-B, in order to determine whether the firm would be subject to Category III
standards. The first as-of date for the amended FR Y-9C and FR Y-9LP is the next report after
the effective date of the final rule. There are no changes to the FR Y-9SP, FR Y-9ES, or
FR Y-9CS.
The current estimated total annual burden for the FR Y-9 reports is 119,816 hours and
would decrease to 119,812 hours. The revisions would result in a decrease of 4 hours. The forms
and instructions are available on the Board’s public website at
http://www.federalreserve.gov/apps/reportforms/default.aspx.
Background and Justification
The FR Y-9 reports are the Board’s primary source of financial data on HCs. Federal
Reserve System examiners rely on the FR Y-9 reports to supervise financial institutions between
on-site inspections. The Board uses the collected data to detect emerging financial problems,
conduct pre-inspection analysis, monitor and evaluate capital adequacy, evaluate mergers and
acquisitions, and analyze an HC’s overall financial condition to monitor the safety and soundness
of its operations. The information collected by the FR Y-9 reports is not available from other
sources.
Description of Information Collection
The FR Y-9C consists of standardized financial statements similar to the Call Reports
filed by commercial banks.2 The FR Y-9C collects consolidated data from HCs and is filed
quarterly by top-tier HCs with total consolidated assets of $3 billion or more.3
The FR Y-9LP, which collects parent company only financial data, must be submitted by
each HC that files the FR Y-9C, as well as by each of its subsidiary HCs.4 The report consists of
standardized financial statements.
The FR Y-9SP is a parent company only financial statement filed semiannually by HCs
with total consolidated assets of less than $3 billion. In a banking organization with total
consolidated assets of less than $3 billion that has tiered HCs, each HC in the organization must
submit, or have the top-tier HC submit on its behalf, a separate FR Y-9SP. 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.
2

The Consolidated Reports of Condition and Income (Call Reports) (OMB No. 7100-0036) consist of the
Consolidated Reports of Condition and Income for a Bank with Domestic Offices Only and Total Assets Less than
$5 Billion (FFIEC 051), as well as the Consolidated Reports of Condition and Income for a Bank with Domestic
Offices Only (FFIEC 041), and the Consolidated Reports of Condition and Income for a Bank with Domestic and
Foreign Offices (FFIEC 031).
3
Under certain circumstances described in the FR Y-9C’s General Instructions, HCs with assets under $3 billion
may be required to file the FR Y-9C.
4
A top-tier HC may submit a separate FR Y-9LP on behalf of each of its lower-tier HCs.

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The FR Y-9ES is filed annual by each employee stock ownership plan (ESOP) that is
also an HC. The report collects financial data on the ESOP’s benefit plan activities. The
FR Y-9ES 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 free-form supplemental report that the Board may utilize to collect
critical additional data deemed to be needed in an expedited manner from HCs. The data are used
to assess and monitor emerging issues related to HCs, and the report is intended to supplement
the other FR Y-9 reports. The data items included on the FR Y-9CS may change as needed.
Adopted Revisions to the FR Y-9
The Board adopted a final rule that establishes risk-based categories for determining
prudential standards for large U.S. banking organizations and foreign banking organizations,
consistent with section 165 of the Dodd-Frank, as amended by the EGRRCPA, and with the
HOLA. The final rule amends certain prudential standards, including standards relating to
liquidity, risk management, stress testing, and single-counterparty credit limits, to reflect the risk
profile of banking organizations under each category; applies prudential standards to certain
large SLHCs using the same categories; makes corresponding changes to reporting forms; and
makes additional modifications to the Board’s company-run stress test and supervisory stress test
rules, consistent with section 401 of EGRRCPA. The final rule is effective December 31, 2019.
The Board amended the FR Y-9C to clarify requirements for HCs subject to Category III
capital standards. The final rule amended those instructions to further clarify that the
supplementary leverage ratio and countercyclical buffer also apply to Category III BHCs,
Category III SLHCs, and Category III U.S. IHCs. The FR Y-9LP is revised to require covered
SLHCs with total consolidated assets of $100 billion or more to report total nonbank assets on
Schedule PC-B, in order to determine whether the firm would be subject to Category III
standards. The first as-of date for the amended FR Y-9C and FR Y-9LP is the next report after
the effective date of the final rule. There are no changes to the FR Y-9SP, FR Y-9ES, or
FR Y-9CS.
Time Schedule for Information Collection
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 date. The FR Y-9SP is filed semiannually as of the last calendar day of June
and December, and the filing deadline 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 of the following
year, unless an extension to file by October 15 is granted. Respondents will be notified of the
filing deadline for the FR Y-9CS if it is utilized by the Board.

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Public Availability of Data
Data from the FR Y-9 reports that are not granted confidential treatment are publicly
available on the Federal Financial Institutions Examination Council website:
https://www.ffiec.gov/NPW.
Legal Status
The Board has the authority to impose the reporting requirements associated with the
FR Y-9 family of reports on BHCs pursuant to section 5 of the Bank Holding Company Act of
1956 (BHC Act) (12 U.S.C. § 1844); on SLHCs pursuant to section 10(b)(2) and (3) of the Home
Owners’ Loan Act (12 U.S.C. § 1467a(b)(2) and (3)), as amended by sections 369(8) and
604(h)(2) of the Dodd-Frank Act; on U.S. IHCs pursuant to section 5 of the BHC Act (12 U.S.C
§ 1844), as well as pursuant to sections 102(a)(1) and 165 of the Dodd-Frank Act (12 U.S.C. §§
511(a)(1) and 5365)5; and on securities holding companies pursuant to section 618 of the DoddFrank Act (12 U.S.C. § 1850a(c)(1)(A)). The obligation to submit the FR Y-9 series of reports,
are mandatory.
With respect to the FR Y-9C report, 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 commercial and
financial information. Such treatment is appropriate under exemption 4 of the Freedom of
Information Act (FOIA) (5 U.S.C. § 552(b)(4)), because these data items reflect commercial and
financial information that is both customarily and actually treated as private by the submitter,
and which the Board has previously assured submitters will be treated as confidential. It also
appears that disclosing these data items may reveal confidential examination and supervisory
information, and in such instances, this information would also be withheld pursuant to
exemption 8 of the FOIA (5 U.S.C. § 552(b)(8)), which protects information related to the
supervision or examination of a regulated financial institution.
In addition, for both the FR Y-9C report and the FR Y-9SP report, Schedule HC’s
memorandum item 2.b., the name and email address of the external auditing firm’s engagement
partner, is considered confidential commercial information and protected by exemption 4 of the
FOIA (5 U.S.C. § 552(b)(4)), if the identity of the engagement partner is treated as private
Section 165(b)(2) of Title I of the Dodd-Frank Act (12 U.S.C. § 5365(b)(2)), refers to “foreign-based bank holding
company.” Section 102(a)(1) of the Dodd-Frank Act (12 U.S.C. § 5311(a)(1)), defines “bank holding company” for
purposes of Title I of the Dodd-Frank Act to include foreign banking organizations that are treated as bank holding
companies under section 8(a) of the International Banking Act of 1978 (12 U.S.C. § 3106(a)). The Board has
required, pursuant to section 165(b)(1)(B)(iv) of the Dodd-Frank Act (12 U.S.C. § 5365(b)(1)(B)(iv)), certain
foreign banking organizations subject to section 165 of the Dodd-Frank Act to form U.S. intermediate holding
companies. Accordingly, the parent foreign-based organization of a U.S. IHC is treated as a BHC for purposes of the
BHC Act and section 165 of the Dodd-Frank Act. Because section 5(c) of the BHC Act authorizes the Board to
require reports from subsidiaries of BHCs, section 5(c) provides additional authority to require U.S. IHCs to report
the information contained in the FR Y-9 series of reports.
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information by HCs. The Board has assured respondents that this information will be treated as
confidential since the collection of this data item was proposed in 2004.
Aside from the data items described above, the remaining data items on the FR Y-9C
report and the FR Y-9SP report are generally not accorded confidential treatment. The data items
collected on FR Y-9LP, FR Y-9ES, and FR Y-9CS6 reports, are also generally not accorded
confidential treatment. As provided in the Board’s Rules Regarding Availability of Information
(12 CFR part 261), however, a respondent may request confidential treatment for any data items
the respondent believes should be withheld pursuant to a FOIA exemption. The Board will
review any such request to determine if confidential treatment is appropriate, and will inform the
respondent if the request for confidential treatment has been denied.
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On November 29, 2018, the Board published a notice of proposed rulemaking for U.S.
banking organizations in the Federal Register (83 FR 61408) for public comment. The comment
period for this notice expired on January 22, 2019. On May 15, 2019, the Board published a
notice of proposed rulemaking for foreign banking organizations in the Federal Register
(84 FR 21988) for public comment. The comment period for this notice expired on June 21,
2019. The Board did not receive any specific comments related to the Paperwork Reduction Act
(PRA) analysis. On November 1, 2019, the Board published a final rule in the Federal Register
(84 FR 59032). The final rule is effective on December 31, 2019.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-9 family of
reports is 119,816 hours, and would decrease to 119,812 hours with the adopted revisions. The
Board estimates that revisions to the FR Y-9C would increase the non AA HCs respondent count
by 1 and decrease the AA HCs respondent count by 1. The Board estimates that revisions to the
FR Y-9 would decrease the estimated annual burden by 4 hours. These reporting requirements
represent approximately 1.1 percent of the Board’s total paperwork burden.

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The FR Y-9CS is a supplemental report that may be utilized by the Board to collect additional information that is
needed in an expedited manner from HCs. The information collected on this supplemental report is subject to
change as needed. Generally, the FR Y-9CS report is treated as public. However, where appropriate, data items on
the FR Y-9CS report may be withheld under exemptions 4 and/or 8 of the Freedom of Information Act (5 U.S.C. §
552(b)(4) and (8)).

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Estimated
number of
respondents7

FR Y-9

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

Current
FR Y-9C (non AA HCs)
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Current Total

343
20
434
3,960
83
236

4
4
4
2
1
4

46.34
47.59
5.27
5.40
0.50
0.50

63,578
3,807
9,149
42,768
42
472
119,816

Proposed
FR Y-9C (non AA HCs)
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Proposed Total

344
19
434
3,960
83
236

4
4
4
2
1
4

46.34
47.59
5.27
5.40
0.50
0.50

63,764
3,617
9,149
42,768
42
472
119,812

Change

( 4)

The current estimated total annual cost to the public for these collections of information
is $6,901,402 and would decrease to $6,901,171 with the adopted revisions.8
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 Y-9 reports is $2,050,800
per year.

7

Of these respondents, 3,417 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $600 million in total assets), https://www.sba.gov/document/support--table-size-standards.
8
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 $19, 45% Financial Managers at
$71, 15% Lawyers at $69, and 10% Chief Executives at $96). 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 2018, published March 29, 2019, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Occupational Classification System, https://www.bls.gov/soc/.

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