FRY9_20200103_omb

Supporting Statement for the
Financial Statements for Holding Companies
(FR Y-9; OMB No. 7100-0128)
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 revised the FR Y-9C to make a number of burden-reducing changes, which
are consistent with recent and proposed reporting changes to the Federal Financial Institutions
Examination Council (FFIEC) Consolidated Reports of Condition and Income (FFIEC 031,
FFIEC 041, and FFIEC 051; OMB No. 7100-0036) (Call Report). The changes to the FR Y-9C
reduce reporting burden for HCs with total assets less than $5 billion by adding new reporting
thresholds, revising certain existing reporting thresholds, reducing the reporting frequency for
certain data items and schedules from quarterly to semiannually or annually, and combining
certain data items. These revisions are effective with the December 31, 2019, report date.
Additionally, the instructions to the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES include
recordkeeping provisions for respondent institutions. The Board has revised the FR Y-9
information collection currently to take account of these recordkeeping provisions.
The current estimated total annual burden for the FR Y-9 reports is 119,812 hours and
would increase to 123,841 hours. The revisions would result in a increase of 4,029 hours. The
forms and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/default.aspx.

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) an SLHC
that primarily holds insurance-related assets and does not otherwise submit financial reports with the U.S. Securities
and Exchange Commission pursuant to section 13 or 15(d) of the Securities Exchange Act of 1934.

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. 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.2
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.3 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.
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.

2

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.
3
A top-tier HC may submit a separate FR Y-9LP on behalf of each of its lower-tier HCs.

2

Adopted Revisions to the FR Y-9
FR Y-9C Revisions
The Board has determined it no longer needs certain FR Y-9C data items from financial
institutions with less than $5 billion in total assets. The Board is reducing burden on these
financial institutions by adding new and revised reporting thresholds, reducing the reporting
frequency for certain data items and schedules from quarterly to semiannually or annually, and
combining certain data items. These revisions are consistent with recent and proposed reporting
changes to the Call Report. The revisions are as follows:
New and Revised Reporting Thresholds
The Board added a reporting threshold of $5 billion or more in total assets,4 below which
HCs would not be required to complete the following data items:
 Schedule HI, data item 1(e), Interest income from trading assets,
 Schedule HI, data item 2(c), Interest on trading liabilities and other borrowed money,
 Schedule HI, data item 2(d), Interest on subordinated notes and debentures and on
mandatory convertible securities,
 Schedule HI, data item 5(c), Trading revenue,
 Schedule HI, data item 5(e), Venture capital revenue,
 Schedule HI, data item 5(g), Net securitization income,
 Schedule HI, Memo item 1, Net interest income on a fully taxable equivalent basis,
 Schedule HI, Memo item 2, Net income before applicable income taxes, and discontinued
operations,
 Schedule HI, Memo items 8.a.(1) through 8.b.(2), Discontinued operations and applicable
income tax effect,
 Schedule HI, Memo items 9(a) through 9(e), details pertaining to trading revenue,
 Schedule HI, Memo item 11, Credit losses on derivatives,
 Schedule HI, Memo items 12(a) through 12(c), detail pertaining to Income from the sale
and servicing of mutual funds and annuities (in domestic offices),
 Schedule HI, Memo items 14(a) through 14(b)(1), details pertaining to net gains (losses)
recognized in earnings on assets and liabilities that are reported at fair value under a fair
value option,
 Schedule HI, Memo item 15, Stock-based employee compensation expense (net of tax
effects) calculated for all awards under the fair value method,
 Schedule HI-B, Part I, data item 6, columns A and B, Loans to foreign governments and
official institutions,
 Schedule HI-B, Part I, Memo item 2, columns A and B, Loans secured by real estate to
non-U.S. addressees,
 Schedule HI-B, Part I, Memo item 3, Uncollectible retail credit card fees and finance
charges reversed against income,
 Schedule HI-B, Part II, Memo item 1, Allocated transfer risk reserve,
4

The $5 billion asset threshold is based on total assets as reported for the previous June 30th report date.

3

























Schedule HI-B, Part II, Memo item 2, Separate valuation allowance for uncollectible
retail credit card fees and finance charges,
Schedule HI-B, Part II, Memo item 3, Amount of allowance for loan and lease losses
attributable to retail credit card fees and finance charges,
Schedule HI-B, Part II, Memo item 4, Amount of allowance for post-acquisition credit
losses on purchased credit-impaired loans,
Schedule HI-C, Disaggregated Data on the Allowance for Loan and Lease Losses,
Schedule HC-C, data item 10(a), Leases to individuals for household, family, and other
personal expenditures,
Schedule HC-C, data item 10(b), All other leases,
Schedule HC-C, Memo item 3, Loans secured by real estate to non-U.S. addressees,
Schedule HC-C, Memo item 4, Outstanding credit card fees and finance charges,
Schedule HC-D, Trading Assets and Liabilities5,
Schedule HC-K, data item 4(a), Trading assets,
Schedule HC-L, data items 1(b)(1), Unused consumer credit card lines, and 1(b)(2),
Other unused credit card lines,
Schedule HC-L, data item 1(d), Securities underwriting,
Schedule HC-L, data item 2(a), Amount of financial standby letters of credit conveyed to
others,
Schedule HC-L, data item 3(a), Amount of performance standby letters of credit
conveyed to others,
Schedule HC-L, data items 7(a) through 7(d)(2)(b), pertaining to credit derivatives,
Schedule HC-L, data items 11(a) through 14(b)(2)), pertaining to derivatives positions,
Schedule HC-M, Memo items 6(a)(1)(a)(1) though 6(d), pertaining to assets covered by
loss-sharing agreements with the Federal Deposit Insurance Corporation,
Schedule HC-N, data items 12(a)(1)(a) through 12(f), pertaining to loans and leases
which are covered by loss-sharing agreements with the Federal Deposit Insurance
Corporation,
Schedule HC-N, Memo item 6, Fair value of derivative contract amounts carried as
assets6,
Schedule HC-P, 1-4 Family Residential Mortgage Banking Activities in Domestic
Offices,
Schedule HC-Q, Assets and Liabilities Measured at Fair Value,
Schedule HC-S, Servicing, Securitization, and Asset Sale Activities, and
Schedule HC-V, Variable Interest Entities.

5

Currently, Schedule HC-D must be completed by holding companies with total trading assets of $10 million or
more in any of the four preceding calendar quarters. The Board modified the existing threshold by adding a
reporting threshold of $5 billion or more in total assets.
6
Currently, this memo item must be completed by holding companies with total assets of $1 billion or more, or with
$2 billion or more in par/notional amounts of off-balance-sheet derivative contracts. The Board is increasing the
reporting threshold from $1 billion to $5 billion or more in total assets.

4

Reduced Reporting Frequencies
For HCs with less than $5 billion in total assets, the Board is reducing the reporting
frequency from quarterly to semi-annually (June and December reporting) for the following data
items:
 Schedule HI, Memo item 17, Other-than-temporary impairment losses on held-tomaturity and available-for-sale debt securities recognized in earnings,
 Schedule HI-C, Disaggregated Data on the Allowance for Credit Losses7,
 Schedule HC-C, Memo items 1(a)(1) through 1(f)(3)(c) pertaining to loans restructured in
troubled debt restructurings that are in compliance with their modified terms,
 Schedule HC-N, Memo items 1(a)(1) through 1(f)(3)(c) pertaining to loans restructured
in troubled debt restructurings that are in compliance with their modified terms,
 Schedule HC-R, Part II, data items 1 through 25, columns A through U8, and
 Schedule HC-R, Part II, Memorandum items 1 through 3, all subitems, columns A
through C.9
7

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 for estimating allowances for credit
losses. In response to ASU 2016-13, the Board added Schedule, HI-C Part II, Disaggregated Data on Allowances for
Credit Losses,” to capture disaggregated data on allowances for credit losses and held to maturity securities from
HCs that have adopted ASU 2016-13, effective, March 31, 2019. See 83 FR 63870 (December 12, 2018). The Board
is adding a semiannual reporting frequency for Schedule HI-C, Part II for HCs with less than $5 billion in total
assets. For HCs with less than $5 billion in total assets that have not adopted ASU 2016-13, the Board will collect
the recorded investment instead of the amortized cost and collect the allowance balance on loans and leases held for
investment, on Schedule HI-C Part II data items 1-6, on a semiannual basis. HCs with less than $5 billion in total
assets that have adopted ASU 2016-13, should report the amortized cost and allowance balance for credit losses on
held to maturity securities on Schedule HI-C, Part II data items 1-6 and the allowance balance on held-to-maturity
securities on data items 7-11, semi-annually. The changes become effective September 2019 and are reportable
starting in December 2019. The Board believes that semi-annual information on the composition of the allowance
for credit losses in relation to the amortized cost for each loan category, and disaggregated information on HTM
securities allowances, is sufficient to support the Board’s analysis of the allowance and credit risk management. The
data on allowance allocations by loan category, when reviewed in conjunction with the past due and nonaccrual data
reported by loan category in Schedule HC-N, which will continue to be reported on a quarterly basis, assist the staff
in assessing a HC’s credit risk exposures and evaluating the appropriateness of the overall level of its Allowance for
Loan and Lease Losses and its allocations by loan category. If changes in the quarterly past due and nonaccrual data
by loan category at individual HCs in quarters when the disaggregated allowance data would not be reported in the
FR Y-9C raise questions about the composition of the allowance, supervisory follow-up can be undertaken on a
case-by-case basis.
8
In these data items, HCs currently report detailed information about the risk-weighting of various types of assets
and other exposures under the Federal Reserve’s regulatory capital rules. HCs still would need to calculate riskweighted assets, maintain appropriate documentation for this calculation, and report data items 26 through 31 of Part
II, if applicable, on a quarterly basis. The Federal Reserve does not believe it is necessary for HCs to continue to
provide the details of their risk-weighting allocations and calculations in Schedule HC-R, Part II, on a quarterly
basis as the Federal Reserve can adequately review regulatory capital calculations for the first and third calendar
quarters as part of on-site examinations or through other types of periodic monitoring, as necessary.
9
HCs currently report detailed information in these data items about derivative exposures that are elements of the
risk-weighting process for these exposures. The Board does not believe it is necessary for a HC with less than $5
billion in total assets to continue to report these amounts on a quarterly basis. Generally, HCs with less than $5
billion in total assets do not have a significant amount of derivatives contracts, and the Board can review
information about HCs’ risk-weighting calculations for derivative exposures for the first and third calendar quarters,
as necessary, as part of on-site examinations or through other periodic monitoring.

5

In addition, for HCs with less than $5 billion in total assets, the Board is reducing the
reporting frequency from quarterly to annually on a calendar year-to-date basis in the December
report only for the following data items:
 Schedule HI, Memo items 6(a) through 6(j), Other noninterest income,
 Schedule HI, Memo items 7(a) though 7(p), Other noninterest expense, and
 Schedule HI, Memo item 16, Noncash income from negative amortization on closed-end
loans secured by 1–4 family residential properties.
Combined Data Items
For HCs with less than $5 billion in total assets, the Board is combining certain data
items, all reportable on a quarterly basis, as follows:
 Combine information currently reported in Schedule HI data items 5(d)(1) through
5(d)(5), pertaining to various fees and commissions on securities brokerage investments,
investment banking and insurance, into new data items 5(d)(6) and 5(d)(7),
 Combine information currently reported in Schedule HI-B Part I, data items 4(a) and
4(b), columns A and B, pertaining to commercial and industrial loans, into new data item
4(c), columns A and B,
 Combine information currently reported in Schedule HI-B Part I, data items 8(a) and
8(b), columns A and B, pertaining to lease finance receivables, into new data item 8(c),
columns A and B,
 Combine information currently reported in Schedule HC-B, data items 4(a)(1) through
4(a)(3), columns A through D, pertaining to residential pass-through securities, into new
data item 4(a)(4), columns A through D,
 Combine information currently reported in Schedule HC-C, data items 4(a) and 4(b),
column A, pertaining to commercial and industrial loans, into new data item 4(c),
column A,
 Combine information currently reported in Schedule HC-C, data items 9(b)(1) and
9(b)(2), column A and B, pertaining to loans for purchasing or carrying securities and all
other loans, into new data item 9(b)(3), columns A and B,
 Combine information currently reported in Schedule HC-C, data items 10(a) and 10(b),
column A, pertaining to lease financing receivables (net of unearned income), into new
data item 10(c), column A,
 Combine information currently reported in Schedule HC-C, Memo items 1(e)(1) and
1(e)(2), pertaining to commercial and industrial loans, into new memo item (1)(e)(3),
 Combine information currently reported in Schedule HC-C, Memo items 12(a) though
12(d), pertaining to loans (not subject to the requirements of FASB ASC 310-30 (former
AICPA Statement of Position 03-3)) and leases held for investment that are acquired in
business combinations with acquisition dates in the current calendar year, into new memo
item 12(e),
 Combine information currently reported in Schedule HC-N, data items 8(a) and 8(b),
columns A, B and C, pertaining to leases financing receivables, into new data item 8(c),
columns A, B and C, and
10

10

HCs with less than $5 billion in total assets would report only the newly combined data items. HCs with $5 billion
or more in total assets would continue to report only the currently existing data items.

6



Combine information currently reported in Schedule HC-N, Memo items 1(e)(1) and
1(e)(2), columns A, B and C, pertaining to commercial and industrial loans, into new
memo item 1(e)(3), columns A, B and C.
Recordkeeping Requirements

The instructions to the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES state that
respondents must maintain in their files a manually signed and attested printed copy of the data
submitted on the form, and should retain workpapers and other records used in the preparation of
those reports. The Board is revising the FR Y-9 information collection to account for these
recordkeeping provisions, which are not currently accounted for.
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.
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 and recordkeeping 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 Wall Street and Consumer Protection Act
(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);11 and on securities holding companies pursuant to section 618 of the Dodd-Frank Act
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)),
11

7

(12 U.S.C. § 1850a(c)(1)(A)). The obligation to submit the FR Y-9 series of reports, and the
recordkeeping requirements set forth in the respective instructions to each report, are mandatory.
With respect to the FR Y-9C report, Schedule HI’s data item 7(g) “FDIC deposit
insurance assessments,” Schedule HC-P’s data 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 data 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
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-9CS12 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.
To the extent the instructions to the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES
reports each respectively direct the financial institution to retain the workpapers and related
materials used in preparation of each report, such material would only be obtained by the Board
as part of the examination or supervision of the financial institution. Accordingly, such
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.
12
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)).

8

information is considered confidential pursuant to exemption 8 of the FOIA (5 U.S.C. §
552(b)(8)). In addition, the workpapers and related materials may also be protected by
exemption 4 of the FOIA, to the extent such financial information is treated as confidential by
the respondent (5 U.S.C. § 552(b)(4)).
Consultation Outside the Agency
The Board consulted with the Federal Deposit Insurance Corporation and Office of the
Comptroller of the Currency in regard to these revisions.
Public Comments
On September 26, 2019, the Board published an initial notice in the Federal Register
(84 FR 50840) requesting public comment for 60 days on the extension, with revision, of the
FR Y-9 reports. The comment period for this notice expired on November 25, 2019. The Board
did not receive any comments. The revisions will be implemented as proposed. On December 26,
2019, the Board published a final notice in the Federal Register (84 FR 70971).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-9 family of
reports is 119,812 hours and would increase to 123,841 hours with the adopted revisions. The
estimated average hours per response for non-advanced approaches FR Y-9C filers with less than
$5 billion in total assets would decrease from 46.34 hours to 40.48 hours, a decrease of 5.86
hours. The estimated average hours per response for non-advanced approaches FR Y-9C filers
with $5 billion or more in total assets and advanced approaches FR Y-9C filers would not change
with this proposal. The estimated average hours per response for the FR Y-9LP, FR Y-9SP,
FR Y-9ES, and FR Y-9CS filers would also remain unchanged. The result of these burden
reduction measures reduces the total burden by 3,633 hours. The result of the addition of the
previously uncleared recordkeeping requirement is an increase of 7,662 hours, producing the net
total increase of 4,029 hours. These reporting requirements represent approximately 1.2 percent
of the Board’s total paperwork burden.

9

Estimated
number of
respondents13

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
Current Total
Proposed
Reporting
FR Y-9C (non AA HCs) with
less than $5 billion in total
assets
FR Y-9C (non AA HCs) with
$5 billion or more in total assets
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Recordkeeping
FR Y-9C (non AA HCs) with
less than $5 billion in total
assets
FR Y-9C (non AA HCs) with
$5 billion or more in total assets
FR Y-9C (AA HCs)
FR Y-9LP
FR Y-9SP
FR Y-9ES
FR Y-9CS
Proposed Total

Estimated
Annual
average hours
frequency
per response

Estimated
annual burden
hours

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

155

4

40.48

25,098

189
19
434
3,960
83
236

4
4
4
2
1
4

46.34
47.59
5.27
5.40
0.50
0.50

35,033
3,617
9,149
42,768
42
472

155

4

1.00

620

189
19
434
3,960
83
236

4
4
4
2
1
4

1.00
1.00
1.00
0.50
0.50
0.50

756
76
1,736
3,960
42
472
123,841
4,029

Change

13

Of these respondents, 4 FR Y-9C (non AA HCs) with less than $5 billion in total assets filers; 177 FR Y-9LP
filers; 3,153 FR Y-9SP filers; and 83 FR Y-9ES filers 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.

10

The current estimated total annual cost to the public for these collections of information
is $6,901,171 and would increase to $7,133,242 with the adopted revisions.14
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.

14

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/.

11