FRY9_20210820_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), any 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.1 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 instructions to the FR Y-9C to implement the temporary revisions
that were approved previously to the definition of “savings deposits” in accordance with
amendments made to the Board’s Regulation D through an interim final rule.2 The Board also
revised the FR Y-9C instructions effective March 31, 2021, to clarify the reporting of savings
deposits for institutions that have suspended the enforcement of the six-transfer limit rule on an
account that meets the definition of a savings deposits.
In addition, the Board revised the FR Y-9C forms and instructions to be consistent with
adopted or proposed changes to U.S. generally accepted accounting principles (GAAP) related to
1) provisions for credit losses on off-balance-sheet credit exposures, 2) expected recoveries of
amounts previously charged off included within the allowances for credit losses, and 3)
nonaccrual treatment of purchased credit-deteriorated assets. The Board also revised the
FR Y-9LP and FR Y-9SP report forms to be consistent with these GAAP changes related to
provisions for credit losses on off-balance-sheet credit exposures. These GAAP-related changes
will be effective March 31, 2021, as of-date. The Board has not yet adopted a proposal regarding

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.
2
See 85 FR 23445 (April 28, 2020). In connection with this interim final rule, the Board temporarily revised the
instructions to the FR Y-9C. See 85 FR 25436 (May 1, 2020).

last-of-layer hedging, as the Financial Accounting Standards Board (FASB) has not yet adopted
a final standard on that topic.
Also, the Board finalized revisions to the FR Y-9C that were previously approved on an
interim basis to collect four new temporary data items related to Paycheck Protection Program
(PPP) loans and the Paycheck Protection Program Liquidity Facility (PPPLF) and two temporary
data items related to section 4013 of the CARES act. These changes became effective June 30,
2020, and the new items will be collected through December 31, 2021.
Finally, the Board finalized revisions to the FR Y-9C instructions that were previously
approved on an interim basis in connection with six interim final rules (IFRs): 1) Eligible
Retained Income (ERI),3 2) Current Expected Credit Losses (CECL),4 (3) Community Bank
Leverage Ratio (CBLR),5 4) Money Market Mutual Fund Liquidity Facility (MMLF),6
5) Paycheck Protection Program (PPP) Loans and Liquidity Facility (PPPLF),6 and Asset
Thresholds.7 Minor clarifications were made to the instructions in response to comments on the
CECL and Asset Thresholds IFRs noted in the “Public Comments” section.
The revisions to the FR Y-9C, FR Y-9LP, and FR Y-9SP are consistent with recently
approved revisions to the Federal Financial Institutions Examination Council (FFIEC)
Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and
FFIEC 051; OMB No. 7100-0036).8 There are no revisions at this time for the FR Y-9ES and
FR Y-9CS.
The new revisions would become effective for reports with a March 31, 2021, as of date.
The temporarily approved revisions were effective March 31, 2020, June 30, 2020, and
December 31, 2020, and are being finalized.
The current estimated total annual burden for the FR Y-9 reports is 115,482 hours, and
would increase to 115,671 hours. The revisions would result in an increase of 189 hours. The
forms and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportforms/review.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 HCs between on-site
inspections. The Board requires HCs to provide standardized financial statements to fulfill the
Board’s statutory obligation to supervise these organizations. The Board uses the collected data
to detect emerging financial problems, review performance and conduct pre-inspection analysis,
monitor and evaluate capital adequacy, evaluate mergers and acquisitions, and analyze a HC’s
3

85 FR 63423 (October 8, 2020).
85 FR 61577 (September 30, 2020).
5
85 FR 64003 (October 9, 2020).
6
85 FR 68243 (October 28, 2020).
7
86 FR 28346 (May 26, 2021).
8
See 85 FR 44361 (July 22, 2020).
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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 for HCs 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.9
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. 10 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 collects
basic balance sheet and income data for the parent company, as well as data on its intangible
assets and intercompany transactions.
The FR Y-9ES is filed annually 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: a Statement of Changes in Net Assets Available for
Benefits, a Statement of Net Assets Available for Benefits, Memoranda, and Notes to the
Financial Statements.
The instructions to each of the FR Y-9C, FR Y-9LP, FR Y-9SP, and FR Y-9ES state that
respondent HCs should retain workpapers and other records used in the preparation of the
reports.
The FR Y-9CS is a voluntary, free-form supplemental report that the Board may utilize to
collect critical additional data from HCs deemed to be needed in an expedited manner. The
FR Y-9CS data collections 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 requested by the
FR Y-9CS would depend on the Board’s data needs in a given situation. For example, changes
made by the Financial Accounting Standards Board may introduce into U.S. generally accepted
accounting principles new data items that are not currently collected by the other FR Y-9 reports.
The Board could use the FR Y-9CS report to collect these data until the items are implemented
into the other FR Y-9 reports.11
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.
10
A top-tier HC may submit a separate FR Y-9LP on behalf of each of its lower-tier HCs.
11
The FR Y-9CS was most recently used by the Board on June 30, 2008. In that collection, data were requested
from banking organizations implementing an Advanced Measurement Approach to calculate operational risk capital
under the Basel II Risk-Based Capital Framework. The report was used to conduct a voluntary Loss Data Collection
Exercise relating to operational risk.
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Respondent Panel
The FR Y-9 panel comprises HCs. Specifically, the FR Y-9C panel consists of top-tier
HCs with total consolidated assets of $3 billion or more; the FR Y-9LP panel consists of each
HC that files the FR Y-9C, as well as each of its subsidiary HCs; the FR Y-9SP panel consists of
HCs with total consolidated assets of less than $3 billion; the FR Y-9ES panel consists of each
ESOP that is also an HC; and the FR Y-9CS panel consists of any HC the Board selects.
Revisions to the FR Y-9
A. Regulation D Revisions
The Board revised the FR Y-9C instructions to implement changes related to the
Regulation D interim final rule issued on April 28, 2020. In response to recent economic
disruptions and volatility in U.S. financial markets caused by the spread of Coronavirus Disease
2019 (COVID-19), the Board adopted the Regulation D interim final rule. The interim final rule
amended the “savings deposit” definition in Regulation D by deleting the six-transfer-limit
provisions in this definition that required depository institutions either to prevent transfers and
withdrawals in excess of the limit or to monitor savings deposits ex post for violations of the
limit. The interim final rule also made conforming changes to other definitions in Regulation D
that refer to “savings deposit” as necessary.
The interim final rule permits, but does not require, depository institutions to immediately
suspend enforcement of the six-transfer limit and to allow their customers to make an unlimited
number of convenient transfers and withdrawals from their savings deposits. The interim final
rule did not amend the Regulation D provisions regarding the reporting of deposits by depository
institutions.
In connection with the interim final rule, the Board published supplemental instructions
to the FR Y-9C, which included temporary revisions to the General Instructions for FR Y-9C
Schedule HC-E, as well as the Glossary entries for “Deposits,” to remove references to the sixtransfer limit. In addition, the supplemental instructions included temporary revisions to the
General Instructions for FR Y-9C Schedule HC-E to state that if a depository institution chooses
to suspend enforcement of the six-transfer limit on a “savings deposit,” the depository institution
may continue to report that account as a “savings deposit” or may instead choose to report that
account as a “transaction account” based on an assessment of certain characteristics of the
account.
However, the Board recognized that the adopted temporary revisions to the instructions
for the FR Y-9C created a reporting option that could result in the collection of ambiguous data
by allowing a depository institution to report a savings deposit as either a “savings deposit” or a
“transaction account” if the institution suspends enforcement of the six-transfer limit. To resolve
this potential issue, the Board revised the General Instructions for FR Y-9C Schedule HC-E to
state that where the reporting institution has suspended the enforcement of the six -transfer limit
rule on an account that otherwise meets the definition of a savings deposit, the institution must

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report such deposits as a “savings deposit” (and as a “nontransaction account”) or a “transaction
account” based on an assessment of the following characteristics:
1) If the reporting institution does not retain the reservation of right to require at least seven
days’ written notice before an intended withdrawal, the account must be reported as a
demand deposit (and as a “transaction account”).
2) If the reporting institution retains the reservation of right to require at least seven days’
written notice before an intended withdrawal and the depositor is eligible to hold a
Negotiable Order of Withdrawal (NOW) account, the account must be reported as an
Automatic Transfer Service (ATS) account, NOW account, or a telephone and
preauthorized transfer account (and as a “transaction account”).
3) If the reporting institution retains the reservation of right to require at least seven days’
written notice before an intended withdrawal and the depositor is ineligible to hold a
NOW account, the account must be reported as a savings deposit (and as a
“nontransaction account”).
The revised FR Y-9C instructions are consistent with corresponding revisions, related to
the Regulation D amendments, to the Call Reports and the Report of Assets and Liabilities of
U.S. Branches and Agencies of Foreign Banks (FFIEC 002; OMB No. 7100-0032).
B. Revisions Related to U.S. GAAP
The Board revised the FR Y-9C, FR Y-9LP and FR Y-9SP forms and instructions to
make a number of changes related to U.S. GAAP effective for reports with a March 31, 2021, as
of date.
Provisions for Credit Losses on Off-Balance-Sheet Credit Exposures
On June 16, 2016, the Financial Accounting Standards Board (FASB) issued Accounting
Standards Update (ASU) No. 2016-13, Topic 326, Financial Instruments – Credit Losses (ASU
2016-13). Within Topic 326, paragraph 326-20-30-11 states: “An entity shall report in net
income (as a credit loss expense) the amount necessary to adjust the liability for credit losses for
management’s current estimate of expected credit losses on off-balance-sheet credit exposures.”
Off-balance-sheet credit exposures include unfunded loan commitments, financial standby letters
of credit, and financial guarantees not accounted for as insurance, and other similar instruments
except for those within the scope of Accounting Standards Codification (ASC) Topic 815 on
derivatives and hedging.
Throughout Topic 326, the FASB refers to provisions for credit losses as “credit loss
expense.” For example, paragraph 326-20-30-1 states: “An entity shall report in net income (as a
credit loss expense) the amount necessary to adjust the allowance for credit losses (ACL) for
management’s current estimate of expected credit losses on financial assets(s).” Thus, Topic 326
does not prohibit recording the adjustment to the liability for expected credit losses on offbalance-sheet credit exposures within the provisions for credit losses reported in the income
statement.

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The FR Y-9C income statement instructions currently direct HCs that have adopted Topic
326 to report provisions for expected credit losses on off-balance-sheet credit exposures in
Schedule HI, item 7.d, “Other noninterest expense,” and prohibit its inclusion in Schedule HI,
item 4, “Provision for loan and lease losses.”12 Therefore, to align regulatory reporting to the
guidance within Topic 326, the Board revised the FR Y-9C instructions to direct HCs that have
adopted Topic 326 to report provisions for expected credit losses on off-balance-sheet credit
exposures as part of the total amount of HCs’ provisions for credit losses in Schedule HI,
item 4.13 These instructional changes apply only to HCs that have adopted Topic 326.
The inclusion of provisions for expected credit losses on off-balance-sheet credit
exposures in the provisions for credit losses presented in item 4 of the FR Y-9C income
statement will cause a loss of transparency within the overall reported amount of provisions for
credit losses between provisions attributable to on- and off-balance-sheet credit exposures. To
enhance transparency and differentiate these provisions, the Board added Memorandum item 7,
“Provisions for credit losses on off-balance-sheet credit exposures,” to Schedule HI-B, Part II,
Changes in Allowances for Credit Losses, which would identify the portion of the overall
amount of the provisions for credit losses reported in Schedule HI, item 4, attributable to the
provisions for expected credit losses on off-balance-sheet credit exposures. Adding the new
memorandum item to Schedule HI-B, Part II, would enable the Board to monitor the underlying
components of the total amount of a HC’s provisions for credit losses (i.e., the separate
provisions for expected credit losses attributable to loans and leases held for investment, held -tomaturity debt securities, available-for-sale (AFS) debt securities, other financial assets measured
at amortized cost, and off-balance-sheet credit exposures) and how these components change
over time in relation to the amounts of the various categories of financial assets and off-balancesheet credit exposures within the scope of ASC Topic 326.
In addition, footnote 5 on Schedule HI-B, Part II, item 5, “Provisions for credit losses,”
was updated to reflect that “For institutions that have adopted ASU 2016-13, the sum of item 5,
Column A through Column C, plus Schedule HI-B, Part II, Memorandum items 5 and 7 below,
must equal Schedule HI, item 4.”
Lastly, footnote 2 on Schedule SI of the FR Y-9SP report form for item 7, “Other
expenses” and footnote 1 on Schedule PI of the FR Y-9LP, report form for item 2.c, “Provision
for loan and lease losses” were updated to direct HCs that have adopted ASU 2016-13 to report
provisions for expected credit losses on off-balance-sheet credit exposures as part of their total
amount of provisions for credit losses.
Expected Recoveries of Amounts Previously Charged Off Included within the Allowances
for Credit Losses
As noted above, the FASB issued ASU 2016-13 on June 16, 2016, and it has been
amended by subsequent FASB ASUs. Within Topic 326, paragraph 326-20-30-1 states, “The
A footnote to Schedule HI, item 4, on the FR Y-9C forms currently states, “Institutions that have adopted ASU
2016-13 should report in item 4 the provisions for credit losses on all financial assets that fall within the scope of the
standard.”
13
The existing footnote to Schedule HI, item 4, also would be revised in the same manner.
12

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ACL is a valuation account that is deducted from, or added to, the amortized cost basis of the
financial asset(s) to present the net amount expected to be collected on the financial asset.
Expected recoveries of amounts previously written off and expected to be written off shall be
included in the valuation account and shall not exceed the aggregate of amounts previously
written off and expected to be written off by an entity.” The terms “written off” as used in Topic
326 and “charged off” as used in FR Y-9C instructions are used interchangeably in this
discussion.
Under GAAP, before an institution’s adoption of Topic 326, expected recoveries of
amounts previously written off would not be included in the measurement of the allowance for
loan and lease losses; recoveries would be recorded only when received. Under Topic 326,
including expected recoveries of amounts previously written off within allowances for credit
losses reduces the overall amount of these allowances. Amounts related to an individual asset are
written off or charged off when deemed uncollectible. However, under ASC Topic 326,
institutions can, in some circumstances, reduce the amount of the ACL that would otherwise be
calculated for a pool of assets with similar risk characteristics that includ es charged-off assets on
the same day the charge-offs were taken by the estimated amount of expected recoveries of
amounts written off on these assets. Reducing the ACL by amounts of expected recoveries prior
to collection effectively “reverses” a charge-off. Therefore, to provide transparency for expected
recoveries of amounts with inherently higher risk that, before an HC’s adoption of ASC Topic
326, were not allowed to be recorded until they were received, the Board added new
Memorandum item 8 to Schedule HI-B, Part II, Changes in Allowances for Credit Losses, to
capture the “Estimated amount of expected recoveries of amounts previously written off included
within the ACL on loans and leases held for investment (included in item 7, column A, ‘Balance
end of current period,’ above).” This new item will be applicable to HCs only after they have
adopted Topic 326.
Not including the proposed memorandum item for expected recoveries of amounts
previously written off within the ACL on loans and leases would cause a loss of transparency
within the reported amount of this allowance between the portions of the allowance attributable
to (1) expected credit losses on the amortized cost basis of loans and leases held for investment
net of expected recoveries of amounts expected to be charged off in the future and (2) expected
recoveries of loan and lease amounts previously charged off. The new Memorandum item 8
enhances transparency and differentiates these amounts within the period-end balance of the
ACL on loans and leases by separately identifying the estimated amount within this allowance
attributable to expected recoveries of amounts previously written off. This new memorandum
item will enable Board data users, including its examiners, and the public to better understand
key components underlying HCs’ ACL on loans and leases (i.e., amounts for expected credit
losses on the amortized cost basis of loans and leases held for investment and amounts for
expected recoveries of amounts previously written off on such loans and leases) and how these
components change over time. This information will assist Board data users in monitoring
amounts with inherently higher credit risk and changes therein that contribute to reductions in the
overall amount of the ACL on loans and leases. This new memorandum item will apply to loans
and leases held for investment because this is the FR Y-9C category of financial assets that is
expected to have the greatest amount of estimated expected recoveries of amounts previously
written off.
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Nonaccrual Treatment of Purchased Credit-Deteriorated Assets
ASU 2016-13 introduced the concept of purchased credit-deteriorated (PCD) assets. PCD
assets are acquired financial assets that, at acquisition, have experienced more-than-insignificant
deterioration in credit quality since origination. When recording the acquisition of PCD assets,
the amount of expected credit losses as of the acquisition date is recorded as an allowance and
added to the purchase price of the assets rather than recording these acquisition date expected
credit losses through provisions for credit losses. The sum of the purchase price and the initial
ACL establishes the amortized cost basis of the PCD assets at acquisition. Any difference
between the unpaid principal balance of the PCD assets and the amortized cost basis of the assets
as of the acquisition date is a noncredit discount or premium. The initial ACL and any noncredit
discount or premium determined on a collective basis at the acquisition date are allocated to the
individual PCD assets.
After acquisition, any noncredit discount or premium is accreted or amortized into
interest income, as appropriate, over the remaining lives of the PCD assets on a level-yield basis.
However, if a PCD asset is placed in nonaccrual status, institutions must cease accreting the
noncredit discount or amortizing the noncredit premium into interest income consistent with the
guidance in ASC paragraph 310-20-35-17.
The current instructions for FR Y-9C Schedule HC-N, Past Due and Nonaccrual Loans,
Leases, and Other Assets, provide an exception to the general rule for placing financial assets in
nonaccrual status set forth in the FR Y-9C Glossary entry for “Nonaccrual status” for purchased
credit-impaired (PCI) assets. Topic 326 replaces the concept of PCI assets in previous GAAP
with the concept of PCD assets. 14 Although there is some similarity between the concepts of PCI
and PCD assets, these two concepts are not identical. Nevertheless, ASU 2016-13 provides that,
upon adoption of Topic 326, all PCI assets will be deemed to be, and accounted for prospectively
as, PCD assets. However, the Schedule HC-N instructions indicate that the nonaccrual exception
for PCI assets was not extended to PCD assets by stating that “For purchased credit-deteriorated
loans, debt securities, and other financial assets that fall within the scope of ASU 2016 -13,
nonaccrual status should be determined and subsequent nonaccrual treatment, if appropriate,
should be applied in the same manner as for other financial assets held by an institution.”
As described in the FR Y-9C Supplemental Instructions for March 2020, if an HC has
adopted ASU 2016-13 and has a PCD asset, including a PCD asset that was previously a PCI
asset or part of a pool of PCI assets, that would otherwise be required to be placed in nonaccrual
status (see the Glossary entry for “Nonaccrual status”), the HC may elect to continue accruing
interest income and not report the PCD asset as being in nonaccrual status if the following
criteria are met:
(1) the HC reasonably estimates the timing and amounts of cash flows expected to be
collected, and

14

According to ASC paragraph 310-30-15-2, PCI assets, in general, are loans and debt securities with evidence of
deterioration of credit quality since origination acquired by completion of a transfer for which it is probable, at
acquisition, that the investor will be unable to collect all contractually required payments receivable.

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(2) the HC did not acquire the asset primarily for the rewards of ownership of the underlying
collateral, such as use of collateral in operations of the institution or imp roving the
collateral for resale.
Additionally, these FR Y-9C Supplemental Instructions state that when a PCD asset that
meets the criteria above is not placed in nonaccrual status, the asset should be subject to other
alternative methods of evaluation to ensure that the HC’s net income is not materially overstated.
Further, an HC is not permitted to accrete the credit-related discount embedded in the purchase
price of a PCD asset that is attributable to the acquirer’s assessment of expected credit losses as
of the date of acquisition (i.e., the contractual cash flows the acquirer did not expect to collect at
acquisition). Interest income should no longer be recognized on a PCD asset to the extent that the
net investment in the asset would increase to an amount greater than the payoff amount. If an HC
is required or has elected to carry a PCD asset in nonaccrual status, the asset must be reported as
a nonaccrual asset at its amortized cost basis in FR Y-9C Schedule HC-N, column C.15 For PCD
assets for which the HC has made a policy election to maintain a previously existing pool of PCI
assets as a unit of account for accounting purposes upon adoption of ASU 2016 -13, the
determination of nonaccrual or accrual status should be made at the pool level, not at the
individual asset level.
For a PCD asset that is not reported in nonaccrual status, the delinquency status of the
PCD asset should be determined in accordance with its contractual repayment terms for purposes
of reporting the amortized cost basis of the asset as past due in Schedule HC-N, column A or B,
as appropriate. If the PCD asset that is not reported in nonaccrual status consists of a pool of
loans that were previously PCI assets that is being maintained as a unit of account after the
adoption of ASU 2016-13, delinquency status should be determined individually for each loan in
the pool in accordance with the individual loan’s contractual repayment terms.
The Board revised the FR Y-9C instructions to revise the nonaccrual treatment for PCD
assets to provide HCs the option to not report PCD assets in nonaccrual status if they meet the
criteria described above. The instructions also incorporate the other reporting guidance for PCD
assets in the FR Y-9C Supplemental Instructions for March 2020 described above.
C. Revisions Related to PPP/PPPLF New Data Items
The Board revised the FR Y-9C forms and instructions to collect new data items related
to PPP and PPPLF interim final rule issued by the agencies. Section 1102 of the CARES Act
allows for banking organizations to make loans under a program of the Small Business
Administration (SBA) in connection with COVID-19 disruptions to small businesses (referred to
as PPP loans or PPP covered loans). While the loans are funded by the banking organizations,
they receive a guarantee from the SBA. The Federal Reserve subsequently established a liquidity
facility to permit banking organizations to obtain non-recourse loans, for which PPP loans are
pledged to the facility, to provide additional liquidity.
On April 13, 2020, the Board and the other federal banking agencies published an interim
final rule with an immediate effective date, which permits banking organizations to exclude from
15

Similarly, in the FFIEC 002, any PCD loans in nonaccrual status would be reported in Schedule N, column C.

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regulatory capital requirements PPP loans pledged to the PPPLF.16 The interim final rule
modifies the agencies’ capital rule to allow banking organizations to neutralize the effects on
their risk-based and leverage capital ratios of making PPP loans that are pledged to the PPPLF.
Specifically, a banking organization may exclude from its total leverage exposure, average total
consolidated assets, standardized total risk-weighted assets, and advanced approaches total riskweighted assets, as applicable, any exposure from a PPP loan pledged to the PPPLF. The interim
final rule also codified the statutory zero percent risk weight for PPP loans; however, the PPP
loans already received a zero percent risk weight under the agencies’ existing capital rules as an
exposure directly and unconditionally guaranteed by an agency of the U.S. government. The
Board has temporarily revised the FR Y-9C instructions to reflect the changes made in this
interim final rule.
The Board needs to collect information on the number and outstanding balance of PPP
loans, as well as the outstanding balance and quarterly average of PPP loans pledged to the
liquidity facility, for their use in supervising holding companies. Therefore, the Board
temporarily approved the addition of four new data items to collect this information, with the
collection of these items is expected to be through December 31, 2021.
Starting with the June 30, 2020, reporting period, a holding company was required to
report the total number of PPP loans outstanding, the outstanding balance of PPP loans, the
outstanding balance of PPP loans pledged to the Federal Reserve’s liquidity facility, and the
quarterly average amount of PPP loans pledged to the Federal Reserve’s liquidity facility and
excluded from average total assets in the calculation of the leverage ratio. These items were
added to Schedule HC-M, as items 25.a, 25.b, 25.c, and 25.d.
Also starting with the June 30, 2020, reporting period, the quarterly average amount of
PPP loans pledged to the liquidity facility and reported in 25.d were reported as a deduction in
Schedule HC-R, part I, item 29, “LESS: Other deductions from (additions to) assets for leverage
ratio purposes,” and thus excluded from Schedule HC-R, Part I, item 30, “Total assets for the
leverage ratio.”
Since PPP loans, regardless of whether they are pledged to the liquidity facility, receive a
zero percent risk weight, they are effectively not included in the standardized total risk -weighted
assets. Similarly, advanced approaches holding companies do not reflect PPP loans in “Total
risk-weighted assets” reported on Schedule HC-R, Part I, item 46.a.
HCs subject to the supplementary leverage ratio requirement report their adjusted
“Supplementary leverage ratio” in Schedule HC-R, Part I, items 53.
D. Revisions Related to Section 4013 of the CARES Act
As provided for under the CARES Act, a financial institution may account for an eligible
loan modification either under Section 4013 or in accordance with Financial Accounting
Standards Board (FASB) Accounting Standards Codification (ASC) Subtopic 310-40,
Receivables—Troubled Debt Restructurings by Creditors. If a loan modification is not eligible
16

85 FR 20387 (April 13, 2020).

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under Section 4013, or if the institution elects not to account for the loan modification under
Section 4013, the financial institution should evaluate whether the modified loan is a troubled
debt restructuring (TDR) under ASC Subtopic 310-40.
To be an eligible loan under Section 4013 (Section 4013 loan), a loan modification must
be (1) related to COVID-19, (2) executed on a loan that was not more than 30 days past due as of
December 31, 2019, and (3) executed between March 1, 2020, and the earlier of (A) 60 days
after the date of termination of the National Emergency or (B) December 31, 2020.
Holding companies accounting for eligible loans under Section 4013 are not required to
apply ASC Subtopic 310-40 to the Section 4013 loans for the term of the loan modification.
Holding companies do not have to report Section 4013 loans as TDRs in regulatory reports.
Consistent with Section 4013, the Board added two new data items for Section 4013
loans to the FR Y-9C, which were collected quarterly beginning with the June 30, 2020, report
date. These new items, Memorandum item 16.a, “Number of Section 4013 loans outstanding,”
and Memorandum item 16.b, “Outstanding balance of Section 4013 loans,” were added to
Schedule HC-C, Part I, Loans and Leases. These items enable the Board to monitor individual
HCs’ use of the temporary relief provided by Section 4013 as well as the volume of loans
modified in accordance with Section 4013.
The Board collects institution-level Section 4013 loan information on a confidential
basis. The Board encouraged financial institutions to work with their borrowers during the
National Emergency related to COVID-19, including use of the relief under Section 4013. 17
However, the Board considers that public disclosure of supervisory information on Section 4013
loans could have a detrimental impact on holding companies offering modifications under this
provision to borrowers that need relief due to COVID-19.
E. Eligible Retained Income
Under the capital rule, an HC must maintain a minimum amount of regulatory capital. In
addition, an HC must maintain a buffer of regulatory capital above its minimum capital
requirements to avoid restrictions on capital distributions.
On March 20, 2020, the Board, Office of the Comptroller of the Currency (OCC), and
Federal Deposit Insurance Corporation (FDIC) (collectively the agencies) adopted an IFR (ERI
IFR)18 that revises the definition of eligible retained income in the agencies’ capital rule. This
change allowed HCs to more freely use their capital buffers, and should help promote lending
and other financial intermediation activities by HCs and avoid compounding disruptions due to
COVID-19.

See “Interagency Statement on Loan Modifications and Reporting for Financial Institutions Working with
Customers Affected by the Coronavirus (Revised)” (April 7, 2020), available at https://www.occ.gov/newsissuances/news-releases/2020/nr-ia-2020-50a.pdf.
18
85 FR 15909 (March 20, 2020).
17

11

Previously, an HC’s eligible retained income was net income for the four preceding
calendar quarters, net of any distributions and associated tax effects not already reflected in net
income. Under the ERI IFR, an HC eligible retained income is defined as the greater of (1) an
HC’s net income for the four preceding calendar quarters, net of any distributions and associated
tax effects not already reflected in net income and (2) the average of an HC’s net income o ver
the four preceding calendar quarters.
In order to reflect the definition of eligible retained income, as amended by the ERI IFR,
the Board temporarily revised the calculation on the FR Y-9C report, Schedule HC-R, Part I,
Item 51, “Eligible retained income.”19 For Schedule HC-R, Part I, item 51, “four preceding
calendar quarters” refers to the calendar quarter ending on the last day of the reporting period
and the three preceding calendar quarters. The average of an HC’s net income over the four
preceding calendar quarters refers to average of three-month net income for the calendar quarter
ending on the last of the reporting quarter and three-month net income for the three preceding
calendar quarters.
F. 5-Year 2020 CECL Transition Provision
The instructions for certain items in Call Report Schedule RC-R, Parts I and II have been
revised effective as of the March 31, 2020, report date to incorporate revisions reflected in the
interim final rule, Regulatory Capital Rule: Revised Transition for the Current Expected Credit
Losses Methodology for Allowances, published in the Federal Register on March 31, 2020
(CECL interim final rule). 20 This interim final rule provides institutions that were required to
adopt the current expected credit losses methodology (CECL) for accounting purposes during the
2020 calendar year with the option to delay for two years the estimated impact of CECL on
regulatory capital, followed by a three-year transition period to phase out the aggregate amount
of the capital benefit provided during the initial two-year delay (i.e., a five-year transition, in
total).
The CECL interim final rule does not replace the current CECL transition option in the
agencies’ capital rule, which was adopted in 2019 and allows banking organizations to phase in
over a three-year period the day-one effects on regulatory capital that may result from the
adoption of CECL (2019 CECL rule). 21 This transition option remains available to institutions
that adopt CECL. Thus, institutions required to adopt CECL in 2020, including those that began
reporting in accordance with CECL in their first quarter 2020 regulatory reports, have the option
to elect the three-year transition option contained in the 2019 CECL rule or the five-year CECL
transition option contained in the CECL interim final rule, beginning with the FR Y-9C for the
March 31, 2020, report date or such later report date in 2020 as of which institutions first report
in accordance with CECL.

19

The ERI IFR also applies to the U.S. intermediate holding companies of foreign banking organizations required to
be established or designated under 12 CFR 252.153.
20
85 FR 17723 (March 31, 2020). The agencies published a correcting amendment in the Federal Register 85 FR
29839 (May 19, 2020).
21
84 FR 4222 (February 14, 2019).

12

The agencies have revised the FR Y-9C Schedule HC-R instructions for the following
items in Part I of the schedule to enable institutions that elect the five-year CECL transition
option to report their regulatory capital data in accordance with the CECL interim final rule:
• Item 2, “Retained earnings,”
• Item 15.a and 15.b on the FR Y-9C, for certain deferred tax assets arising from temporary
differences that exceed an institution’s applicable common equity tier 1 capital deduction
threshold,
• Item 27, “Average total consolidated assets,”
• Item 42.a on the FR Y-9C, for the amount of adjusted allowances for credit losses
includable in tier 2 capital,
• Item 42.b on the FR Y-9C, “Eligible credit reserves includable in tier 2 capital,” and
• Item 55.a on the FR Y-9C, “Total leverage exposure.”
The instructions for Schedule HC-R, Part II, item 8, “All other assets,” also have been
revised to account for the five-year CECL transition option.
In addition, beginning with the June 30, 2020, FR Y-9C, Schedule HC-R, Part I, item 2.a,
“Does your institution have a CECL transition election in effect as of the quarter-end report
date? (enter “1” for Yes; enter “0” for No.),” will be revised to allow institutions that have
adopted CECL to choose from among three entries rather than the current two entries. An
institution that has adopted CECL will choose from the following CECL transition election
entries: “0” for adopted CECL with no transition election; “1” for a 3-year CECL transition
election; and “2” for a 5-year 2020 CECL transition election. An institution that has not adopted
CECL will continue to leave item 2.a blank.
G. Community Bank Leverage Ratio
Section 4012 of the CARES Act required the appropriate Federal banking agencies to
reduce the community bank leverage ratio (CBLR) to 8 percent for a temporary period ending on
the earlier of the termination date of the national emergency concerning the coronavirus disease
COVID-19 outbreak declared by the President on March 13, 2020, under the National
Emergencies Act22 (National Emergency) or December 31, 2020, which the agencies did through
an interim final rule. 23 To provide further clarity around the possible end date of the statutory
relief and provide a qualifying community banking organization that is planning to elect to use
the community bank leverage ratio framework sufficient time to meet the leverage ratio
requirement, the agencies also issued an interim final rule extending relief for the 8 percent
community bank leverage ratio through 2020, providing relief through an 8.5 percent community
bank leverage ratio in 2021, and resuming the existing 9 percent community bank leverage ratio
in 2022.24 Neither interim final rule changed the methodology for calculating the CBLR, merely
the qualifying ratio for an institution to report as a CBLR institution.
There are no substantive reporting revisions associated with the revised CBLR
framework. However, it is possible that some additional holding companies that are now eligible
22

50 U.S.C. § 1601 et seq.
85 FR 22924 (April 23, 2020).
24
85 FR 22930 (April 23, 2020).
23

13

CBLR institutions under the lower qualifying ratio may choose to use the less burdensome
reporting for regulatory capital on Schedule HC-R. Therefore, the Board temporarily revised the
FR Y-9C instructions to accurately reflect aspects of the statutory interim final rule and the
transition interim final rule.
H. Money Market Mutual Fund Liquidity Facility (MMLF)
The Federal Reserve established the MMLF on March 18, 2020, to broaden its program
of support for the flow of credit to households and businesses. Under the program, the Federal
Reserve Bank of Boston will make loans available to eligible financial institutions secured by
high-quality assets purchased by the financial institution from money market mutual funds. On
March 23, 2020, the agencies published an interim final rule (MMLF IFR), 25 which permits
banking organizations 26 to exclude exposures related to the MMLF from regulatory capital
requirements.
The MMLF IFR modifies the Board’s capital rule to allow HCs to neutralize the effects
of purchasing assets through the MMLF on their risk-based and leverage capital ratios. This
treatment extends to the community bank leverage ratio (CBLR). Specifically, an HC may
exclude from its total leverage exposure, average total consolidated assets, standardized total
risk-weighted assets, and advanced approaches total risk-weighted assets, as applicable, any
exposure acquired pursuant to a non-recourse loan from the MMLF. The interim final rule only
applies to activities with the MMLF. The facility is scheduled to terminate on March 31, 2021,
unless the facility is extended by the Board.
Consistent with U.S. GAAP, the Board would expect holding companies to report assets
purchased from money market mutual funds under the MMLF on their balance sheets. To be
eligible collateral for pledging to the FRBB, assets must be purchased from an eligible money
market mutual fund at either the seller’s amortized cost or fair value. Thereafter, banking
organizations would subsequently measure the assets at amortized cost or fair value depending
on the asset category in which the assets are reported on their balance sheets. The non -recourse
nature of the transaction through the MMLF would impact the valuation of the liability to the
Federal Reserve Bank of Boston. After reflecting any appropriate discounts on the assets
purchased and the associated liabilities, organizations are not expected to report any material net
gains or losses (if any) at the time of purchase. Any discounts generally would be accreted over
time into income and expense.
I. Asset Thresholds
To mitigate temporary transition costs on banking organizations related to the
coronavirus disease 2019 (COVID event), the agencies issued an interim final rule 27 to permit
national banks, savings associations, state banks, BHCs, SLHCs, and U.S. branches and agencies
25

85 FR 16232 (March 23, 2020).
For purposes of the MMLF, “banking organizations” consist of all U.S. depository institutions, U.S. bank holding
companies (parent companies incorporated in the United States or their U.S. broker-dealer subsidiaries), and U.S.
branches and agencies of foreign banks, but does not include savings and loan holding companies.
27
85 FR 77345 (December 2, 2020).
26

14

of foreign banking organizations with under $10 billion in total assets as of December 31, 2019,
(community banking organizations) to use asset data as of December 31, 2019, in order to
determine the applicability of various regulatory asset thresholds during the remainder of 2020
and calendar year 2021. Consistent with the interim final rule, the Board has temporarily revised
the FR Y-9C and FR Y-9LP instructions to allow an HC to use asset data as of December 31,
2019, in order to determine reporting requirements for reports for the December 31, 2020,
through December 31, 2021, as of dates.
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 FFIEC website: https://www.ffiec.gov/NPW.
Legal Status
The reporting and recordkeeping requirements associated with the FR Y-9 series of
reports are authorized for BHCs pursuant to section 5 of the Bank Holding Company Act of 1956
(BHC Act) (12 U.S.C. § 1844); for SLHCs pursuant to sections 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); for
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. §§ 5311(a)(1) and 5365);28 and for
securities holding companies pursuant to section 618 of the Dodd-Frank Act (12 U.S.C. §
1850a(c)(1)(A)). Except for the FR Y-9CS report, which is expected to be collected on a
voluntary basis, the obligation to submit the remaining reports in the FR Y-9 series of reports
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.
28

15

and to comply with the recordkeeping requirements set forth in the respective instructions to
each of the other reports, is mandatory.
With respect to the FR Y-9C report, Schedule HI’s Memorandum 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, the information also would 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, Schedule HC’s memorandum item 2.b and the
FR Y-9SP report, Schedule SC’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.
Additionally, items on the FR Y-9C, Schedule HC-C for loans modified under Section
4013, data items Memorandum items 16.a, “Number of Section 4013 loans outstanding”; and
Memorandum items 16.b, “Outstanding balance of Section 4013 loans” are considered
confidential. While the Board generally makes institution-level FR Y-9C report data publicly
available, the Board is collecting Section 4013 loan information as part of condition reports for
the impacted HCs and the Board considers disclosure of these items at the HC level would not be
in the public interest. 29 Such information is permitted to be collected on a confidential basis,
consistent with 5 U.S.C. § 552(b)(8). Exemption 8 of FOIA specifically exempts from disclosure
information “contained in or 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.” In addition, holding companies may be reluctant to offer modifications under
Section 4013 if information on these modifications made by each holding company is publicly
available, as analysts, investors, and other users of public FR Y-9C report information may
penalize an institution for using the relief provided by the CARES Act. The Board may disclose
Section 4013 loan data on an aggregated basis, consistent with confidentiality or as otherwise
required by law.
Aside from the data items described above, the remaining data items collected on the
FR Y-9C report and the FR Y-9SP report are generally not accorded confidential treatment. The
29

See 12 U.S.C. § 1464(v)(2).

16

data items collected on FR Y-9LP, FR Y-9ES, and FR Y-9CS30 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 ap propriate, and will
inform the respondent if the request for confidential treatment has been granted or 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
information is considered confidential pursuant to exemption 8 of the FOIA (5 U.S.C. §
552(b)(8)). In addition, the financial institution’s work papers 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 coordinated and consulted with the FDIC and OCC in regard to the revisions
to the FR Y-9 reports.
Public Comments
On March 20, 2020, the Board published the ERI IFR in the Federal Register (85 FR
15909) requesting public comment for 60 days on the extension, with revision, of the FR Y-9
reports. The comment period expired on May 19, 2020. The Board did not receive any comments
on this proposal, and the revisions were implemented as proposed.
On March 23, 2020, the Board published the MMLF IFR in the Federal Register (85 FR
16232) and on April 9, 2020, the Board published a notice in the Federal Register (85 FR 19944)
requesting public comment for 60 days on the extension, with revision, of the FR Y-9 reports.
The comment period expired on June 8, 2020. The Board did not receive any comments on this
proposal, and the revisions were implemented as proposed.
On March 31, 2020, the Board published the CECL IFR in the Federal Register (85 FR
17723) requesting public comment for 60 days on the extension, with revision, of the FR Y-9
reports. The comment period expired June 1, 2020. The Board did not receive any comments on
the proposal, but the Board clarified the instructions to the reports to accurately reflect the CECL
transition provision as modified by the final rule. In addition to the specific changes mentioned
in the interim final rule, the final rule expands eligibility for the new transition to banking
organizations that voluntarily early adopt CECL in the 2020 calendar year. The final rule also
included minor adjustments to clarify calculation of the transition provision. Specifically, the
30

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 FOIA (5 U.S.C. § 552(b)(4) and (8)).

17

FR Y-9C instructions were clarified to note that an electing banking organization that opted to
apply the transition in the first quarter in which it was eligible is not required to apply the
transition in any quarter in which it would not reflect a positive modified CECL transitional
amount (that could result in negative retained earnings). Also, the FR Y-9C instructions were
clarified to note that the day-one transitional amounts (CECL transitional amount, AACL
transitional amount, and DTA transitional amount) may be calculated as a positive or negative
number.
On April 13, 2020, the Board published the PPPLF IFR in the Federal Register (85 FR
20387) requesting public comment for 60 days on the extension, with revision, of the FR Y-9
reports. The comment period expired on May 13, 2020. The Board did not receive any comments
on this proposal, and the revisions were implemented as proposed.
On April 23, 2020, the Board published the CBLR IFR in the Federal Register (85 FR
22930) requesting public comment for 60 days on the extension, with revision, of the FR Y-9
reports. The comment period expired on June 22, 2020. The Board did not receive comments on
this proposal, and the revisions were implemented as proposed.
On July 7, 2020, the Board published a notice in the Federal Register (85 FR 40646)
requesting public comment for 60 days on the extension, with revision, of the FR Y-9 reports.
The comment period expired on September 8, 2020. The Board did not receive any comments on
this proposal, and the revisions will be implemented as proposed, with the new data items being
collected through December 31, 2021.
On October 8, 2020, the Board published a notice in the Federal Register (85 FR 63553)
requesting public comment for 60 days on the extension, with revision, of the FR Y-9 reports.
The comment period expired on December 7, 2020. The Board received a comment from a
banker’s association on this proposal. The Board also considered comments received on a
comparable Call Report proposal, and adopted changes on the FR Y-9C to maintain consistency
with the Call Report.31
Comments Received on Provision for Credit Losses on Off-balance Sheet Credit
Exposures
The commenter on the October 2020 notice noted the potential impact on other reports
beyond the FR Y-9C of the GAAP change related to provision for credit losses on off-balance
sheet credit exposures. These other reports include the FR Y-7N (OMB No. 7100-0125),
FR Y-11 (OMB No. 7100-0244), FR 2314 (OMB No. 7100-0073), FR 2886b (OMB No.
7100-0086), and FR 2644 (OMB No. 7100-0075). The Board will consider conforming changes
to the forms and instructions for the FR 2886b, FR Y-7N, FR Y-11, and FR 2314 in the future.
Any such changes would be proposed by the Board through a separate Federal Register notice
pursuant to the Paperwork Reduction Act (PRA). The Board does not intend to make conforming
changes to the FR 2644 since this report is only comprised of balance sheet items and this
GAAP-related change only impacts income statement items.
31

85 FR 44361 (July 22, 2020).

18

Comments Received on Final Regulation D Reporting Revisions
The Board did not receive comments on the proposal to finalize, on an interim basis,
revisions to the FR Y-9C instructions regarding the definition of “savings deposits” associated
with the amendments to the Board’s Regulation D. The changes were effective as of June 30,
2020.
The commenter on the October 2020 notice raised several concerns with the proposed
changes related to the definition of “savings deposits” and the assessment criteria to remove
certain optional reporting, and requested a clarification on the definition of “retail sweep
arrangements.” The commenter recommended that the revisions be consistent across reports.
Specifically, the commenter recommended that savings deposits be classified consistently as
transaction or nontransaction accounts across reports. The commenter stated that the differences
in the treatment of savings deposits would require firms to report savings deposits as
nontransaction accounts on the Call Reports, FR Y-9C, and FR 2886b, while the same deposits
would be classified as a transaction account on the Report of Transaction Accounts, Other
Deposits and Vault Cash (FR 2900; OMB No. 7100-0087). The commenter recommended that
the Board provide clear and consistent definitions of “savings deposits,” “transaction accounts,”
and “nontransaction accounts.” In response to the commenter’s recommendation, the Board will
continue to maintain the requirement to report “savings deposits” as a component of
nontransaction accounts on the FR Y-9C and FR 2886b in order to maintain consistency with the
Call Report. The Board will also maintain the definition of “transaction accounts” and
“nontransaction accounts” as currently stated in the FR Y-9C and FR 2886b instructions, which
is consistent with the Call Report instructions. It is important to note the Call Report and
FR Y-9C are principal sources of financial data used for supervision and regulation of the
banking industry whereas the primary purpose of the FR 2900 report is to collect data for the
construction of the monetary aggregates.
Secondly, regarding the proposed changes to the assessment criteria for “savings
deposits,” the commenter recommended that a depositor’s eligibility to hold a NOW account
should not be included in the criteria assessment to determine the reporting treatment for savings
deposits for which the numeric limits on transfers and withdrawals have been removed. The
commenter noted that “if a firm does not offer NOW accounts, they would be required to repo rt
savings deposits as NOW accounts, ATS accounts, or telephone and preauthorized transfer
accounts (and as transaction accounts) based on a depositor’s eligibility to hold such account”
and “for firms that do not offer NOW accounts, the data necessary to determine a depositor’s
eligibility for NOW accounts would not be readily available.”
In addition, the commenter noted that this reporting treatment would be inconsistent with
the Regulation D definition of savings deposits, as NOW account eligibility is not a component
of the definition. The commenter believed that gathering the data necessary to distinguish these
depositors from other savings account holders solely for regulatory reporting purposes would
create business and systems challenges. The Board agrees with the commenter that the
depositor’s eligibility to hold a NOW account should not be included in the assessment criteria
for classification as a “savings deposit,” as such reporting would not be consistent with the
Regulation D definition of savings deposits. Therefore, the Board will remove the depositor’s
19

eligibility to hold a NOW account from the assessment criteria. The Board and other federal
banking agencies have implemented comparable revisions to the Call Report.
Additionally, the commenter recommended that the effective date of the proposed
revisions to the FR Y-9C definition of “savings deposits” be delayed from December 31, 2020,
until June 30, 2021, to better align with the proposed effective dates of the FR 2900 32 and the
Report of Foreign (Non-U.S.) Currency Deposits (FR 2915; OMB No. 7100-0087). The
commenter noted that aligning the timing of the revisions would give firms additional time to
implement any further changes made by the Board and other agencies in light of the comments
received. In response to the commenter’s recommendation, the Board has deferred the effective
date of the proposed revisions that requires a depository institution to report each account as a
“savings deposit” or a “transaction account” based on the institution’s assessment of account
characteristics and removes the optionality in reporting savings deposits as either a “savings
deposit” or a “transaction account” if the institution suspended the enforcement of the six transfer limit until March 31, 2021. Choosing March 31, 2021 as the proposed effective date will
align the FR Y-9C Regulation D revisions with the Call Report and will provide institutions
additional time to implement any necessary changes. The timing of the FR Y-9C changes was
chosen to match the Call Report to allow for consistent quarterly reporting.
Lastly, the commenter requested clarification on how institutions should report the
components of retail sweep arrangements on the FR Y-9C report. Specifically, the commenter
asked whether institutions should continue to report the nontransaction components of, or
savings deposits in, retail sweep arrangements as nontransaction accounts. If not, the commenter
asked whether institutions should strictly follow the proposed assessment criteria for the
treatment of accounts where the transfer limit has been removed. In response to the comment, the
Board has modified the description of retail sweep arrangements in the FR Y-9C instructions to
remove references to transaction and nontransaction components. Further, the instructions will
indicate that institutions should not follow the proposed assessment criteria for the treatment of
accounts for which the transfer limit has been removed.
Instead, the instructions will note that institutions that offer valid retail sweep programs
must report each component of the retail sweep arrangement based on the customer account
agreement established by the depository institution. The instructions will also note that two key
criteria must be met for a valid retail sweep program. These criteria are (1) a depository
institution must establish by agreement with its customer two distinct, legally separate accounts
and (2) the swept funds must actually be moved between the customer’s accounts on th e
depository institution’s official books and records as of the close of business on the day(s) on
which the depository institution intends to report the funds as being in separate accounts. These
modifications are consistent with modifications to the Call Report instructions made in response
to a similar comment.33

32
33

See 85 FR 54577 (November 2, 2020).
85 FR 74784 (December 23, 2020).

20

Modifications to proposed Memorandum item 8 of Schedule HI-B, Part II, “Changes in
Allowances for Credit Losses”
As discussed above, the Board added a new Memorandum item 8 to Schedule HI-B, Part
II, to collect the estimated amount of expected recoveries of amounts previously written off
included within the allowance for credit losses on loans and leases held for investment. The
Board did not receive any comments on this aspect of the proposal, and will adopt this revision.
However, the Board has decided to collect this new Memorandum item only from holding
companies with $5 billion or more in total consolidated assets. The Board decided to limit this
collection to such holding companies in order to minimize burden, consistent with a number of
other FR Y-9C items that are not required from holding companies with less than $5 billion in
total assets.
Proposed revisions related to last-of-layer hedging
In the October 2020 notice, the Board proposed to make certain revisions to the FR Y-9C
related to the last-of-layer method of hedge accounting standards. This proposal would have
implemented in the FR Y-9C revisions related to a project added to the FASB agenda to expand
last-of-layer hedging to multiple layers, thereby providing more flexibility to entities when
applying hedge accounting to a closed portfolio of prepayable assets. The Board proposed for
these revisions to become effective following the adoption and implementation of a final
standard on this matter by FASB.
Because FASB has not yet adopted a final standard regarding last-of-layer hedging, the
Board has not adopted the proposed FR Y-9C revisions associated with this topic at this time.
The Board will consider whether to finalize the proposed revisions related to last-of-layer
hedging when FASB adopts a final standard.
Additional Instructional Matters
The agencies addressed several additional instructional matters in the final Call Report
notice.34 The Board made comparable clarifying changes to the FR Y-9 reports for consistency
purposes as discussed in detail below.
1. Uncollectible Accrued Interest Receivable under ASC Topic 326
In April 2019, the Financial Accounting Standards Board (FASB) issued ASU No. 201904, “Codification Improvements to Topic 326, Financial Instruments—Credit Losses, Topic 815,
Derivatives and Hedging, and Topic 825, Financial Instruments,” which amended ASC Topic
326 to allow an institution to make certain accounting policy elections for accrued interest
receivable balances, including a separate policy election, at the class of financing receivable or
major security-type level, to charge off any uncollectible accrued interest receivable by reversing
interest income, recognizing credit loss expense (i.e., provision expense), or a combination of
both. The Glossary entry for “Accrued Interest Receivable” in the FR Y-9C report instructions
currently references the following accounting policy elections in ASU 2019-04:
34

85 FR 74784 (November 23, 2020)

21

•
•

Holding companies may elect to separately present accrued interest receivable from the
associated financial asset, and the accrued interest receivable is presented net of an
allowance for credit losses (ACL), if any, and
Holding companies that charge off uncollectible accrued interest receivable in a timely
manner, i.e., in accordance with the Glossary entry for “Nonaccrual Status,” may elect, at
the class of financing receivable or the major security-type level, not to measure an ACL
for accrued interest receivable.

Although this Glossary entry does not currently provide for the ASU’s separate
accounting policy election for the charge-off of uncollectible accrued interest receivable at the
class of financing receivable or major security-type level, this election is specifically addressed
in the Interagency Policy Statement on Allowances for Credit Losses issued in May 2020. 35
Accordingly, as provided in the FR Y-9C Supplemental Instructions for the September 30, 2020,
report date,36 a holding company that has adopted ASC Topic 326 may make the charge-off
election for accrued interest receivable balances in ASU 2019-04 separately from the other
elections for these balances in the ASU for FR Y-9C reporting purposes. A holding company
may also charge off uncollectible accrued interest receivable against an ACL for FR Y-9C
reporting purposes.
The Board plans to update the FR Y-9C Glossary entry for “Accrued Interest Receivable”
to align the instructions in this entry with the elections permitted under U.S. GAAP for
institutions that have adopted ASC 326, which also would achieve consistency with the
discussion of accrued interest receivable in the Interagency Policy Statement on Allowances for
Credit Losses.
2. Shared Fees and Commissions from Securities-Related and Insurance Activities
Holding companies with $5 billion or more in total assets report income from certain
securities-related and insurance activities in FR Y-9C report Schedule HI, Income Statement,
items 5.d.(1) through (7), while holding companies with less than $5 billion in total assets report
only items 5.d.(6) and 5.d.(7). When an institution partners with, or otherwise joins with, a third
party to conduct these securities-related or insurance activities, and any fees and commissions
generated by these activities are shared with the third party, the Schedule HI instructions do not
currently address the reporting treatment for these sharing arrangements. Consequently, holding
companies may have reported the gross fees and commissions from these activities in the
appropriate subitem of Schedule HI, item 5, “Other noninterest income,” and the third party’s
share of the fees and commissions separately as expenses in Schedule HI, item 7.d, “Other
noninterest expense.” Alternatively, holding companies may have reported only their net share of
the fees or commissions in the appropriate subitem of Schedule HI, item 5.
The Board believes that reporting shared fees and commissions on a net basis is
preferable to gross reporting and is analogous to how income from certain other incomegenerating activities is reported on the FR Y-9C income statement, including securitization
35

85 FR 32991 (June 1, 2020).
https://www.federalreserve.gov/reportforms/supplemental/Final%20FR%20Y9C%20September%202020%20Supplemental%20Instructions.pdf.
36

22

income and servicing fee income, which are currently reported net of specified expenses and
costs.
This net approach better represents an institution’s income from a securities-related or
insurance activity engaged in jointly with a third party than when the third party’s share of the
fees and commissions is separately reported as a noninterest expense in another income
statement data item. As a result, the Board has clarified the existing Schedule HI instructions to
ensure consistent reporting on a net basis of fees and commissions from securities-related and
insurance activities that are shared with third parties. Furthermore, to avoid including repetitive
language in the instructions for the multiple noninterest income items for income from securitiesrelated and insurance activities in Schedule HI, a new non-reportable item 5.d captioned “Income
from securities-related and insurance activities” has been added before the existing 5.d subitems
on the FR Y-9C report. The reporting treatment for arrangements involving the sharing of fees
and commissions with third parties arising from an institution’s securities brokerage, investment
banking, investment advisory, securities underwriting, insurance and annuity sales, insurance
underwriting, or any other securities-related and insurance activities is explained once in the new
item 5.d instructions.
3. Pledged Equity Securities
In January 2016, the FASB issued ASU 2016-01, “Recognition and Measurement of
Financial Assets and Financial Liabilities.” As one of its main provisions, the ASU requires
investments in equity securities, except those accounted f or under the equity method and those
that result in consolidation, to be measured at fair value, with changes in fair value recognized in
net income. Thus, the ASU eliminates the existing concept of available-for-sale (AFS) equity
securities, which are measured at fair value with changes in fair value generally recognized in
other comprehensive income. As of December 31, 2020, all holding companies will have been
required to adopt ASU 2016-01 and, as a consequence, must report equity securities with readily
determinable fair values not held for trading in Schedule HC, Balance Sheet, item 2.c, “Equity
securities with readily determinable fair values not held for trading,” instead of Schedule HC-B,
Securities, item 7, “Investments in mutual funds and other equity securities with readily
determinable fair values.” Accordingly, Schedule HC-B, item 7, will be removed effective
December 31, 2020.
Holding companies report held-to-maturity and AFS securities in Schedule HC-B, items
1 through 7, and have long reported in Schedule HC-B, Memorandum item 1, “Pledged
securities” the amount of such securities that are pledged to secure deposits and for other
purposes. Considering that all institutions that previously reported their AFS equity securities in
Schedule HC-B, item 7, now report these securities in Schedule HC, item 2.c, the Board is
updating the instructions for Schedule HC-B, Memorandum item 1, and Schedule HC, item 2.c,
to indicate that holding companies should include in Memorandum item 1 the fair value of
pledged equity securities with readily determinable fair values not held for trading that are now
reported in Schedule HC, item 2.c. The wording of existing footnote 1 to Memorandum item 1 of
Schedule HC-B on the FR Y-9C forms will be similarly updated. These instructional
clarifications would ensure that pledged equity securities formerly reportable as AFS equity
securities would continue to be reported in Memorandum item 1 notwithstanding the change in
23

accounting for equity securities under U.S. GAAP. Information on pledged securities is an
important element of the agencies’ analysis of an institution’s liquidity risk. The existing
footnote 1 to Memorandum item 1, Schedule HC-B on the FR Y-9C forms and the instructions
for PC-B Memorandum line item 10, “Pledged securities”, of the FR Y-9LP and related footnote
1 reference of this line item on the FR Y-9LP forms will be similarly updated.
The FR Y-9C instructional clarifications to the Glossary entry for “Accrued Interest
Receivable” and Schedule HC-B for pledged equity securities will take effect December 31,
2020, while the instructional clarifications to Schedule HI for shared fees and commissions from
securities-related and insurance activities will take effect March 31, 2021.
On December 2, 2020, the Board published the Asset Thresholds IFR in the Federal
Register (85 FR 77345) requesting public comment for 60 days on the extension, with revision,
of the FR Y-9 reports. The comment period expired February 1, 2021. The Board did not receive
any comments on the proposal, but the Board clarified the FR Y-9C instructions to reflect that a
holding company should continue to use its total as reported in FR Y-9C Schedule HC, item 12,
as of the current quarter-end report date when reporting other qualifying criteria for the CBLR
framework (that is, the sum of trading assets and trading liabilities as a percentage of total assets
in Schedule HC-R, item 33, column B, and total off-balance sheet exposures as a percentage of
total assets in Schedule HC-R, Part I, item 34.d, column B). The Board and the other agencies
have received comments on the IFR. In order to implement reporting changes related to the IFR
prior to the expiration of the temporarily approved revisions, the Board has adopted this proposal
under the PRA pending review of comments on the IFR. If the Board modifies the IFR through
the adoption of a final rule regarding temporary asset threshold relief, the Board would adopt
appropriate additional revisions to the FR Y-9C and FR Y-9LP reports through a separate PRA
process.
On September 30, 2020, the Board published the CECL final rule in the Federal Register
(85 FR 61577). On October 8, 2020, the Board published the ERI final rule in the Federal
Register (85 FR 63423). On October 9, 2020, the Board published the CBLR final rule in the
Federal Register (85 FR 64003). On October 28, 2020, the Board published the MMLF and
PPPLF final rule in the Federal Register (85 FR 68243). On January 4, 2021, the Board
published a final notice in the Federal Register (86 FR 92). On May 26, 2021, the Board
published a final notice in the Federal Register (86 FR 28346).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-9 reports is
115,482 hours, and would increase to 115,671 hours with the revisions. The GAAP and
Regulation D revisions would result in an increase of 189 hours. The revisions associated with
the new items for PPPLF and Section 2013 of the CARES Act would not affect burden as these
adjustments to burden were made in July 2020 with the emergency clearance and are reflected in
the current burden. These reporting and recordkeeping requirements represent 1.5 percent of the
Board’s total paperwork burden.

24

FR Y-9
Current
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
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
FR Y-9LP
FR Y-9SP

Estimated
number of
respondents37

Annual
frequency

Estimated
Estimated
average hours annual burden
per response
hours

124

4

35.59

17,653

218
9
416
3,739
78
236

4
4
4
2
1
4

44.79
49.80
5.27
5.40
0.50
0.50

39,057
1,793
8,769
40,381
39
472

351
416
3,739
78
236

4
4
2
1
4

1.00
1.00
0.50
0.50
0.50

1,404
1,664
3,739
39
472
115,482

124

4

35.72

17,717

218
9
416
3,739
78
236

4
4
4
2
1
4

44.92
50.14
5.27
5.40
0.50
0.50

39,170
1,805
8,769
40,381
39
472

351
416
3,739

4
4
2

1.00
1.00
0.50

1,404
1,664
3,739

37

Of these respondents, 4 FR Y-9C (non AA HCs) with less than $5 billion in total assets filers; 31 FR Y-9LP filers;
2,869 FR Y-9SP filers; and 58 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. The respondent count for the FR Y-9C, FR Y-9LP, and FR Y-9SP are as of June 30, 2020. The
respondent count for the FR Y-9ES is as of December 31, 2019.

25

FR Y-9ES
FR Y-9CS

78
236

1
4

0.50
0.50

Proposed Total

39
472
115,671

Change

189

The estimated total annual cost to the public for the FR Y-9 reports is $6,830,760, and
would increase to $6,841,940 with the revisions. 38
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FR Y-9 reports is $2,050,800.

38

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 $20, 45% Financial Managers at
$73, 15% Lawyers at $72, and 10% Chief Executives at $95). 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 2020, published March 31, 2021, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

26