FRQ_20200323_omb

Supporting Statement for the
Reporting, Recordkeeping, and Disclosure Requirements Associated with Regulation Q
(FR Q; OMB No. 7100-0313)
Changes to Applicability Thresholds for Regulatory Capital and Liquidity Requirements
(Docket No. R-1628) (RIN 7100-AF21)
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 Reporting, Recordkeeping, and Disclosure Requirements Associated with
Regulation Q (FR Q; OMB No. 7100-0313). The Board’s Regulation Q - Capital Adequacy of
Bank Holding Companies, Savings and Loan Holding Companies, and State Member Banks
(12 CFR Part 217) sets forth the capital adequacy requirements for state member banks (SMBs),
BHCs, U.S. intermediate holding companies (IHCs), and covered savings and loan holding
companies (SLHCs) (collectively, Board-regulated institutions).
The Board, Office of the Comptroller of the Currency (OCC), and Federal Deposit
Insurance Corporation (FDIC) (collectively, the agencies) adopted a final rule to revise the
criteria for determining the applicability of regulatory capital and liquidity requirements for large
U.S. banking organizations and IHCs of certain foreign banking organizations. The final rule
established four risk-based categories for determining the applicability of requirements under the
agencies’ regulatory capital rule and liquidity coverage ratio (LCR) rule. Under the final rule,
such requirements increased in stringency based on measures of size, cross-jurisdictional
activity, weighted short-term wholesale funding, nonbank assets, and off-balance sheet exposure.
The final rule applied tailored regulatory capital and liquidity requirements to depository
institution holding companies and U.S. IHCs with $100 billion or more in total consolidated
assets as well as to certain depository institutions. Separately, the Board adopted a final rule that
revised the criteria for determining the applicability of enhanced prudential standards for large
domestic and foreign banking organizations using a risk-based category framework that is
consistent with the framework described in this final rule, and made additional modifications to
the Board’s company-run stress test and supervisory stress test rules. In addition, the Board an d
the FDIC separately adopted a final rule that amends the resolution planning requirements under
section 165(d) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DoddFrank Act) using a risk-based category framework that is consistent with the framework
described in this final rule. The final rule is effective on December 31, 2019.
The final rule requires banking organizations subject to Category III standards to
maintain a minimum supplementary leverage ratio of 3 percent given its size and risk profile. As
a result, these IHCs would no longer be identified as “advanced approaches banking
organizations” for purposes of the advanced approach disclosure respondent count.
The current estimated total annual burden for the FR Q is 79,727 hours, and would
increase to 81,309 hours. The revisions would result in an increase of 1,582 hours. There are no
required reporting forms associated with this information collection.

Background and Justification
Section 1831o(c) of the Federal Deposit Insurance Act requires each federal banking
agency to adopt a risk-based capital requirement, which is based on the prompt corrective action
framework in that section. The International Lending Supervision Act of 1983 (ILSA) (12 U.S.C.
§ 3907(a)(1)) mandates that each federal banking agency require banks to achieve and maintain
adequate capital by establishing minimum levels of capital or by other methods that the
applicable federal banking agency may deem appropriate. In order to implement these and other
statutory requirements, the agencies have issued rules establishing minimum capital
requirements and overall capital adequacy standards for banking organizations. The Board’s
capital rule is located in Regulation Q and applies to SMBs, BHCs, IHCs, and covered SLHCs.
Description of Information Collection
The reporting requirements in Regulation Q are found in sections 217.123, 217.124,
217.132(b)(2)(iii)(A), 217.132(b)(3), 217.132(d)(1), 217.132(d)(1)(iii), and 217.132(d)(2)(iv).
The recordkeeping requirements in Regulation Q are found in sections 217.3(d),
217.35(b)(3)(i)(A), 217.37(c)(4)(i)(E), 217.41(b)(3), 217.41(c)(2)(i), 217.41(c)(2)(ii),
217.121(b), 217.122, 217.132(d)(3)(vi), 217.132(d)(3)(viii), 217.132(d)(3)(ix), 217.132(d)(3)(x),
217.132(d)(3)(xi), 217.141(b)(3), 217.141(c)(1), 217.141(c)(2)(i)-(ii), 217.153, 217.402, and
217.403. The disclosure requirements in Regulation Q are found in sections 217.42(e)(2),
217.62, 217.63, 217.142, 217.172, and 217.173 Tables 2, 3, 4, 5, 9, 12, and 13. No other federal
law mandates these reporting, recordkeeping, and disclosure requirements, and the information is
not available from other sources.
Minimum Capital Ratios
Recordkeeping Requirements
Section 217.3(d) provides for termination and close-out netting across multiple types of
transactions or agreements if the bank obtains a written legal opinion verifying the validity and
enforceability of the agreement under certain circumstances and maintains sufficient written
documentation of this legal review.
Standardized Approach
Recordkeeping Requirements
Section 217.35(b)(3)(i)(A) requires, for a cleared transaction with a qualified central
counterparty (QCCP), that a client Board-regulated institution apply a risk weight of 2 percent,
provided that the collateral posted by the institution to the QCCP is subject to certain
arrangements and the client bank has conducted a sufficient legal review (and maintains
sufficient written documentation of the legal review) to conclude with a well-founded basis that
the arrangements, in the event of a legal challenge, would be found to be legal, valid, binding,
and enforceable under the law of the relevant jurisdictions.

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Section 217.37(c)(4)(i)(E) requires that a Board-regulated institution have policies and
procedures describing how it determines the period of significant financial stress used to
calculate its own internal estimates for haircuts and be able to provide empirical support for the
period used.
Section 217.41(b)(3) allows for synthetic securitizations a Board-regulated institution’s
recognition, for risk-based capital purposes, of a credit risk mitigant to hedge underlying
exposures if certain conditions are met, including the institution’s having obtained a wellreasoned opinion from legal counsel that confirms the enforceability of the credit risk mitigant in
all relevant jurisdictions.
Section 217.41(c)(2)(i) requires that a Board-regulated institution support a
demonstration of its comprehensive understanding of a securitization exposure by conducting
and documenting an analysis of the risk characteristics of each securitization exposure prior to its
acquisition, taking into account a number of specified considerations.
Section 217.41(c)(2)(ii) requires that, on an on-going basis (no less frequently than
quarterly), a Board-regulated institution must evaluate, review, and update as appropriate the
analysis required under this section for each securitization exposure.
Disclosure Requirements
Section 217.42(e)(2) addresses risk-weighted assets for securitization exposures and
requires that a Board-regulated institution that provides support to a securitization in excess of
the Board-regulated institution’s contractual obligation to provide credit support to the
securitization publicly disclose that is has provided such implicit support to the securitization, as
well as the risk-based capital impact to the Board-regulated institution of providing such implicit
support.
Section 217.62 sets forth disclosure requirements related to a Board-regulated
institution’s capital requirements. Section 217.62(a) specifies a quarterly frequency for the
disclosure of information in the applicable tables set out in section 217.63 and, if a significant
change occurs, such that the most recent reported amounts are no longer reflective of the Boardregulated institution’s capital adequacy and risk profile, it also requires the institution to disclose,
as soon as practicable thereafter, a brief discussion of the change and its likely impact. This
section allows for annual disclosure of qualitative information that typically does not change
each quarter, provided that any significant changes are disclosed in the interim. Section
217.62(b) requires that a Board-regulated institution have a formal disclosure policy approved by
the board of directors that addresses its approach for determining the disclosures it makes. The
policy is required to address the associated internal controls and disclosure controls and
procedures. Section 217.62(c) requires a Board-regulated institution with total consolidated
assets of $50 billion or more that is not an advanced approaches Board-regulated institution, if it
concludes that specific commercial or financial information required to be disclosed under
section 217.62 is exempt from disclosure by the Board under the Freedom of Information Act
(5 U.S.C. § 552), to disclose more general information about the subject matter of the
requirement and the reason the specific items of information have not been disclosed.

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Section 217.63 sets forth disclosure requirements for Board-regulated institutions with
total consolidated assets of $50 billion or more that are not advanced appro aches banks. Section
217.63(a) requires a Board-regulated institution to make the disclosures in Tables 1 through 10.
The institution must make these disclosures publicly available for each of the last three years
(that is, twelve quarters). Section 217.63(b) requires quarterly disclosure of a Board-regulated
institution’s common equity tier 1 capital, additional tier 1 capital, tier 2 capital, tier 1 and total
capital ratios, including the regulatory capital elements and all the regulatory adjustments and
deductions needed to calculate the numerator of such ratios; total risk-weighted assets, including
the different regulatory adjustments and deductions needed to calculate total risk -weighted
assets; regulatory capital ratios during any transition periods, including a description of all the
regulatory capital elements and all regulatory adjustments and deductions needed to calculate the
numerator and denominator of each capital ratio during any transition period; and a
reconciliation of regulatory capital elements as they relate to its balance sheet in any audited
consolidated financial statements.
Tables 1 through 10 in section 217.63 set forth qualitative and quantitative disclosure
requirements for scope of application, capital structure, capital adequacy, capital conservation
buffer, credit risk, counterparty credit risk-related exposures, credit risk mitigation,
securitizations, equities not subject to Subpart F (Risk-Weighted Assets - Market Risk) of the
rule, and interest rate risk for non-trading activities.
Advanced Approach
Reporting Requirements
Section 217.123 requires an advanced approaches Board-regulated institution to notify
the Board of changes to advance systems and requires submission of a plan for returning to
compliance with qualification requirements.
Section 217.124 requires an advanced approaches Board-regulated institution to notify
the Board when it makes a material change to its advanced systems and to develop an
implementation plan after any mergers.
Section 217.132(b)(2)(iii)(A) addresses counterparty credit risk of repo-style transactions,
eligible margin loans, and over-the-counter derivative contracts and allows an institution, with
the prior written approval of the Board, to calculate haircuts (H s and Hfx) using its own internal
estimates of the volatilities of market prices and foreign exchange rates. To receive Board
approval to use its own internal estimates, an institution must satisfy the minimum quantitative
standards outlined in this section, including maintaining policies and procedures that describe
how it determines the period of significant financial stress used to calculate the Board-regulated
institution’s own internal estimates for haircuts under this section and must be able to provide
empirical support for the period used. The Board-regulated institution must obtain the prior
approval of the Board for, and notify the Board if the Board-regulated institution makes any
material changes to, these policies and procedures.

4

Section 217.132(b)(3) provides that, with the prior written approval of the Board, an
advanced approaches Board-regulated institution may estimate exposure at default (EAD) for a
netting set using a value-at-risk (VaR) model that meets certain requirements.
Section 217.132(d)(1) allows the use of the internal models methodology to determine
EAD for counterparty credit risk for derivative contracts with prior written approval by the
Board.
Section 217.132(d)(1)(iii) allows the use of the internal models methodology for
derivative contracts, eligible margin loans, and repo-style transactions subject to a qualifying
cross-product netting agreement with prior written approval.
Section 217.132(d)(2)(iv) provides that for risk-weighted assets using the internal models
methodology (IMM), an advanced approaches Board-regulated institution uses an internal model
to estimate the expected exposure (EE) for a netting set and then calculates EAD based on that
EE. An advanced approaches Board-regulated institution must calculate two EEs and two EADs
(one stressed and one unstressed) for each netting as outlined in this section.
Recordkeeping Requirements
Sections 217.121 and 122 requires that each advanced approaches Board-regulated
institution to adopt a written implementation plan that addresses how it will comply with the
advanced capital adequacy framework’s qualification requirements, including incorporation of a
comprehensive and sound planning and governance process to oversee the implementation
efforts. The institution must also develop processes for assessing capital adequacy in relation to
an organization’s risk profile. It must establish and maintain internal risk rating and segmentation
systems for wholesale and retail risk exposures, including comprehensive risk parameter
quantification processes and processes for annual reviews and analyses of reference data to
determine their relevance. It must document its process for identifying, measuring, monitoring,
controlling, and internally reporting operational risk; verify the accurate and timely reporting of
risk-based capital requirements; and monitor, validate, and refine its advanced systems.
Section 217.132(d)(3)(vi) requires that an advanced approaches Board-regulated
institution, in order to obtain agency approval to calculate the distributions of exposures upon
which the EAD calculation is based, must demonstrate to the satisfaction of the agency that it has
been using for at least one year an internal model that broadly meets the minimum standards,
with which the institution must maintain compliance. The institution must have procedures to
identify, monitor, and control wrong-way risk throughout the life of an exposure. The procedures
must include stress testing and scenario analysis.
Section 217.132(d)(3)(viii) requires that when estimating model parameters based on a
stress period, an advanced approaches Board-regulated institution must use at least three years of
historical data that include a period of stress to the credit default spreads of the institution ’s
counterparties. The institution must review the data set and update the data as necessary,
particularly for any material changes in its counterparties. The institution must demonstrate at
least quarterly, and maintain documentation of such demonstration, that the stress period

5

coincides with increased credit default swap or other credit spreads of the institution’s
counterparties. The institution must have procedures to evaluate the effectiveness of its stress
calibration that include a process for using benchmark portfolios that are vulnerable to the same
risk factors as the institution’s portfolio. The agency may require the institution to modify its
stress calibration to better reflect actual historic losses of the portfolio.
Section 217.132(d)(3)(ix) requires that an advanced approaches Board-regulated
institution subject its internal model to an initial validation and annual model review process.
The model review should consider whether the inputs and risk factors, as well as the model
outputs, are appropriate. As part of the model review process, the institution must have a
backtesting program for its model that includes a process by which unacceptable model
performance will be determined and remedied.
Section 217.132(d)(3)(x) requires that an advanced approaches Board-regulated
institution must have policies for the measurement, management, and control of collateral and
margin amounts.
Section 217.132(d)(3)(xi) requires that an advanced approaches Board-regulated
institution have a comprehensive stress testing program that captures all credit exposures to
counterparties, and incorporates stress testing of principal market risk factors and
creditworthiness of counterparties.
Section 217.141 addresses operational criteria for recognizing the transfer of risk. Section
217.141(b)(3) requires a well-reasoned legal opinion confirming the enforceability of the credit
risk mitigant in all relevant jurisdictions. Section 217.141(c)(1) and 217.141(c)(2)(i) require an
advanced approaches institution to demonstrate its comprehensive understanding of a
securitization exposure for each securitization exposure by conducting an analysis of the risk
characteristics of a securitization exposure prior to acquiring the exposure and do cument such
analysis within three business days after acquiring the exposure. Section 217.141(c)(2)(ii)
requires that, on an ongoing basis (no less frequently than quarterly), a bank must evaluate,
review, and update as appropriate the analysis required under this section for each securitization
exposure.
Section 217.153 provides that an advanced approaches Board-regulated institution must
receive prior written approval from the Board before it can use the internal models approach.
Disclosure Requirements
Section 217.142, which outlines the capital treatment for securitization exposures,
requires that an advanced approaches Board-regulated institution provides support to a
securitization in excess of the Board-regulated institution’s contractual obligation to provide
credit support to the securitization disclose publicly that it has provided such implicit support to
the securitization, as well as the regulatory capital impact to the institution of providing such
implicit support.

6

Section 217.172 specifies that each advanced approaches Board-regulated institution
must publicly disclose its total and tier 1 risk-based capital ratios and their components.
Section 217.173 requires an advanced approaches Board-regulated institution to make the
qualitative and quantitative disclosures described in Tables 1 through 12. The institution must
make these disclosures publicly available for each of the last three years (that is, twelve quarters)
or such shorter period beginning on January 1, 2014. Table 2 to section 217.173 addresses
disclosures related to capital structure; Table 3 to section 217.173 addresses disclosures related
to capital adequacy; Table 4 to section 217.173 addresses disclosures related to capital
conservation and countercyclical capital buffers; Table 5 to section 217.173 addresses general
disclosures related to credit risk; Table 9 to section 217.173 addresses disclosures related to
securitizations; Table 12 to section 217.173 addresses disclosures related to interest rate risk for
non-trading activities; and Table 13 to section 217.173 addresses disclosures related to
supplementary leverage ratios.
Risk-based Capital Surcharge for GSIBs
Recordkeeping Requirements
Pursuant to Subpart H of Regulation Q, a BHC is a global systemically important BHC
(GSIB) if its method 1 score equals or exceeds 130 basis points. A BHC must calculate its
method 1 and method 2 scores pursuant to Subpart H on an annual basis by December 31 of each
year.
Section 217.402 requires an advanced approaches BHC to annually calculate and retain
its method 1 score, which is the sum of its systemic indicator scores for the twelve systemic
indicators set forth in Table 1 to section 217.404. The systemic indicator score in basis points for
a given systemic indicator is equal to the ratio of the amount of that systemic indicator, as
reported on the BHC’s most recent Banking Organization Systemic Risk Report (FR Y-15; OMB
No. 7100-0352); to the aggregate global indicator amount for that systemic indicator published
by the Board in the fourth quarter of that year; multiplied by 10,000; and multiplied by the
indicator weight corresponding to the systemic indicator as set forth in Table 1 to section
217.404.
Section 217.403 requires a BHC to annually calculate and retain its GSIB surcharge,
which is the greater of its method 1 and method 2 surcharges. The method 2 surcharge is based
on the BHC’s method 2 score, which is equal to the sum of the global systemically important
BHC’s systemic indicator scores for the nine systemic indicators set forth in Table 1 of the final
rule and the global systemically important BHC’s short-term wholesale funding score. The
systemic indicator score is equal to the amount of the systemic indicator, as reported on the
global systemically important BHC’s most recent FR Y-15, multiplied by the coefficient
corresponding to the systemic indicator set forth in Table 1 to section 217.405.

7

Respondent Panel
The FR Q panel comprises state member banks (SMBs), BHCs, U.S. IHCs, and covered
savings and loan holding companies (SLHCs).
Revisions to the FR Q
The agencies adopted a final rule to revise the criteria for determining the applicability of
regulatory capital and liquidity requirements for large U.S. banking organizations and the U.S.
IHCs of certain foreign banking organizations. The final rule established four risk -based
categories for determining the applicability of requirements under the agencies’ regulatory
capital rule and LCR rule. Under the final rule, such requirements increased in stringency based
on measures of size, cross-jurisdictional activity, weighted short-term wholesale funding,
nonbank assets, and off-balance sheet exposure. The final rule applied tailored regulatory capital
and liquidity requirements to depository institution holding companies and U.S. IHCs with $100
billion or more in total consolidated assets as well as to certain depository institutions.
Separately, the Board adopted a final rule that revised the criteria for determining the
applicability of enhanced prudential standards for large domestic and foreign banking
organizations using a risk-based category framework that is consistent with the framework
described in this final rule, and made additional modifications to the Board’s company-run stress
test and supervisory stress test rules. In addition, the Board and the FDIC separately adopted a
final rule that amends the resolution planning requirements under section 165(d) of the DoddFrank Act using a risk-based category framework that is consistent with the framework described
in this final rule. The final rule is effective on December 31, 2019.
The final rule requires banking organizations subject to Category III standards to
maintain a minimum supplementary leverage ratio of 3 percent given its size and risk profile. As
a result, these IHCs would no longer be identified as “advanced approaches banking
organizations” for purposes of the advanced approach disclosure respondent count.
Time Schedule for Information Collection
This information collection contains reporting, recordkeeping, and disclosure
requirements, as mentioned above. The reporting, recordkeeping, and disclosure requirements
are required annually and quarterly.
Public Availability of Data
There is no data related to the reporting and recordkeeping requirements available to the
public.
Legal Status
Section 38(o) of the Federal Deposit Insurance Act (12 U.S.C. § 1831o(c)), section 908
of the ILSA (12 U.S.C. § 3907(a)(1)), section 9(6) of the Federal Reserve Act (12 U.S.C. § 324),
and section 5(c) of the Bank Holding Company Act of 1956 (12 U.S.C. § 1844(c)) authorize the

8

Board to require the information collection. The obligation to respond to this information
collection is mandatory.
If a respondent considers the information to be trade secrets and/or privileged such
information could be withheld from the public under the authority of the Freedom of Information
Act (5 U.S.C. § 552(b)(4)). Additionally, to the extent that such information may be contained in
an examination report such information maybe also be withheld from the public (5 U.S.C. § 552
(b)(8)).
Consultation Outside the Agency
The Board worked with the OCC and FDIC to amend the regulation that is requiring this
revision.
Public Comments
On December 21, 2018, the agencies published a notice of proposed rulemaking for U.S.
banking organizations in the Federal Register (83 FR 66024) for public comment. The comment
period for this notice expired on January 22, 2019. On May 24, 2019, the agencies published a
notice of proposed rulemaking for foreign banking organizations in the Federal Register (84 FR
24296) for public comment. The comment period for this notice expired on June 21, 2019. The
agencies did not receive any public comments on the PRA analysis. On November 1, 2019, the
agencies published a final rule in the Federal Register (84 FR 59230). The final rule is effective
on December 31, 2019.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Q is 79,727
hours, and would increase to 81,309 with the revisions. These reporting, recordkeeping, and
disclosure requirements represent less than 1 percent of the Board’s total paperwork burden.

FR Q
Current
Initial Setup
Standardized Approach
Recordkeeping
Sections 217.35(b)(3)(i)(A),
217.37(c)(4)(i)(E),
217.41(b)(3), and
217.41(c)(2)(i)
Disclosure

Estimated
number of
respondents1

1

Annual
frequency

1

1

Estimated
average hours
per response

122

Estimated
annual burden
hours

122

Of these respondents, 628 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.

9

Sections 217.42(e)(2), 217.62,
and 217.63
Advanced Approach
Reporting
Sections 217.132(b)(2)(iii)(A)
and 217.132(d)(2)(iv)
Recordkeeping
Sections 217.132(d)(3)(vi),
217.132(d)(3)(viii),
217.132(d)(3)(ix),
217.132(d)(3)(x),
217.132(d)(3)(xi),
217.141(b)(3), 217.141(c)(1),
217.141(c)(2)(i)-(ii), and
217.153
Disclosure
Section 217.173 Tables 2, 3, 4,
5, 9, and 12
Current Initial Setup Total
Ongoing
Minimum Capital Ratios
Recordkeeping
Section 217.3(d)
Standardized Approach
Recordkeeping
Sections 217.35(b)(3)(i)(A),
217.37(c)(4)(i)(E), and
217.41(c)(2)(ii)
Disclosure
Sections 217.42(e)(2), 217.62,
and 217.63
Advanced Approach
Reporting
Sections 217.123, 217.124,
217.132(b)(2)(iii)(A),
217.132(b)(3), 217.132(d)(1),
217.132(d)(1)(iii), and
217.132(d)(2)(iv)
Recordkeeping
Sections 217.121(b), 217.122,
217.132(d)(3)(ix), and
217.132(d)(3)(xi)

1

1

226.25

226

1

1

160

160

1

1

300

300

1

1

328

328
1,136

1,431

1

16

22,896

1,431

1

20

28,620

25

4

131.25

13,125

17

1

111.77

1,900

17

1

429

7,293

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Sections 217.132(d)(3)(viii)
and 217.141(c)(2)(i)-(ii)
Disclosure
Sections 217.142 and 217.172
Section 217.173 Tables 2, 3, 4,
5, 9, and 12
Section 217.173 Table 13
Risk-based Capital Surcharge
for GSIBs
Recordkeeping
Sections 217.402 and 217.403
Current Ongoing Total

17

4

17

1

17
25

4
4

21

1

20
5.78
41
5

0.5

Current Total
Proposed
Initial Setup
Standardized Approach
Recordkeeping
Sections 217.35(b)(3)(i)(A),
217.37(c)(4)(i)(E),
217.41(b)(3), and
217.41(c)(2)(i)
Disclosure
Sections 217.42(e)(2), 217.62,
and 217.63
Advanced Approach
Reporting
Sections 217.132(b)(2)(iii)(A)
and 217.132(d)(2)(iv)
Recordkeeping
Sections 217.132(d)(3)(vi),
217.132(d)(3)(viii),
217.132(d)(3)(ix),
217.132(d)(3)(x),
217.132(d)(3)(xi),
217.141(b)(3), 217.141(c)(1),
217.141(c)(2)(i)-(ii), and
217.153
Disclosure
Section 217.173 Tables 2, 3, 4,
5, 9, and 12
Proposed Initial Setup Total

1,360
98
2,788
500

11
78,591
79,727

1

1

122

122

1

1

226.25

226

1

1

160

160

1

1

300

300

1

1

328

328
1,136

11

Ongoing
Minimum Capital Ratios
Recordkeeping
Section 217.3(d)
Standardized Approach
Recordkeeping
Sections 217.35(b)(3)(i)(A),
217.37(c)(4)(i)(E), and
217.41(c)(2)(ii)
Disclosure
Sections 217.42(e)(2), 217.62,
and 217.63
Advanced Approach
Reporting
Sections 217.123, 217.124,
217.132(b)(2)(iii)(A),
217.132(b)(3), 217.132(d)(1),
217.132(d)(1)(iii), and
217.132(d)(2)(iv)
Recordkeeping
Sections 217.121(b), 217.122,
217.132(d)(3)(ix), and
217.132(d)(3)(xi)
Sections 217.132(d)(3)(viii)
and 217.141(c)(2)(i)-(ii)
Disclosure
Sections 217.142 and 217.172
Section 217.173 Tables 2, 3, 4,
5, 9, and 12
Section 217.173 Table 13
Risk-based Capital Surcharge
for GSIBs
Recordkeeping
Sections 217.402 and 217.403
Proposed Ongoing Total

1,431

1

16

22,896

1,431

1

20

28,620

25

4

131.25

13,125

19

1

111.77

2,124

19

1

429

8,151

19

4

20

1,520

19

1

19
25

4
4

21

1

5.78
41
5

0.5

110
3,116
500

11
80,173

Proposed Total

81,309

Change

1,582

12

The current estimated total annual cost to the public for the FR Q is $4,592,275, and
would increase to $4,683,398 with the revisions. 2
Sensitive Questions
This collection of information contains 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 is negligible.

2

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 Standard Occupational Classification System, https://www.bls.gov/soc/.

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