FFIEC101_20231016_omb

Supporting Statement for the
Regulatory Capital Reporting for Institutions Subject to the
Advanced Capital Adequacy Framework
(FFIEC 101; OMB No. 7100-0319)
Summary
The Board of Governors of the Federal Reserve System (Board) requests approval from
the Office of Management and Budget (OMB) to extend for three years, without revision, the
Federal Financial Institutions Examination Council (FFIEC) Regulatory Capital Reporting for
Institutions Subject to the Advanced Capital Adequacy Framework (FFIEC 101; OMB No.
7100-0319). The FFIEC 101 collects data regarding the levels and components of risk-based
capital from firms subject to the Board’s advanced approaches capital framework (advanced
approaches framework), as well as data regarding the supplementary leverage ratio (SLR) from
firms subject to that requirement. The FFIEC 101 must be filed quarterly by certain large or
internationally active state member banks (SMBs), bank holding companies (BHCs), savings and
loan holding companies (SLHCs) that are subject to the advanced approaches framework and
other Board-regulated institutions that adopt the framework on a voluntary basis (collectively,
advanced approaches banking organizations); additionally, certain BHCs, SLHCs, SMBs, and
U.S. intermediate holding companies (IHCs) that are not advanced approaches banking
organizations must report only certain information regarding the SLR. The extension to the
FFIEC 101 that is the subject of this request has been approved by the FFIEC. The Federal
Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC)
(together with the Board, the agencies) have also submitted similar requests for OMB review to
request this information from banks under their supervision.
The estimated total annual burden for the FFIEC 101 is 35,288 hours. The form and
instructions are available on the FFIEC’s public website at
https://www.ffiec.gov/ffiec_report_forms.htm.
Background and Justification
A number of federal laws require the Board to establish capital requirements for entities it
supervises.1 The Board’s current risk-based and leverage capital standards are codified in the
Board’s Regulation Q - Capital Adequacy of Bank Holding Companies, Savings and Loan
Holding Companies, and State Member Banks (12 CFR Part 217). The Board’s risk-based capital
standards include an advanced approaches capital framework for large and internationally active
banking organizations. Banking organizations that use this framework report information related
to their risk-based capital requirements using the FFIEC 101.
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Section 171 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires the Board to establish
minimum risk-based and leverage capital requirements on a consolidated basis for the insured depository
institutions, depository institution holding companies, and nonbank financial companies it supervises (12 U.S.C. §
5371(b)(1)-(2)). Further, the International Lending Supervision Act of 1983 (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 agency may deem appropriate and section 38(c) of the Federal Deposit
Insurance Act (12 U.S.C. § 1831o(c)) requires each federal banking agency to adopt a risk-based capital requirement
for insured depository institutions.

With respect to the advanced approaches framework, the Board uses the data reported on
the FFIEC 101 to:
• Assess the components of each advanced approaches banking organization’s risk-based
capital requirements,
• Assess each advanced approaches banking organization’s capital relative to inherent risks
and the Board’s minimum capital requirements,
• Assess the components of each advanced approaches banking organization and top-tier
Category III BHCs, SHCs, and SMBs, and all Category III IHCs of its SLR. The SLR is
the ratio of tier 1 capital to total leverage exposure, as defined in the regulatory capital
rule,
• Monitor the levels and components of the risk-based capital requirements for advanced
approaches banking organizations through peer, outlier, and risk trend analyses,
• Evaluate the quantitative impact and competitive implications of the implementation of
the framework on risk-based capital levels within advanced approaches banking
organizations and on an overall industry basis,
• Ensure that the advanced approaches framework is implemented in the United States in a
safe and sound manner,
• Provide market participants, depositors, the public, supervisors, and other interested
parties with information about advanced approaches banking organizations’ risk-based
capital, and
• Supplement on-site examination processes and decisions pertaining to the allocation of
supervisory resources.
The information collected by the FFIEC 101 is not available from other sources.
Description of Information Collection
The mandatory FFIEC 101 report collects information from all Board-regulated advanced
approaches banking organizations, as well as information regarding the SLR from Category III
institutions. Advanced approaches banking organizations are required to submit detailed data on
the components of their capital and risk-weighted assets in nineteen schedules (A through S).
Category III institutions must complete only Schedule A, SLR Tables 1 and 2.
Advanced Approaches Regulatory Capital and Summary Risk-Weighted Asset
Information. Schedule A collects information about the components of Tier 1 capital, Tier 2
capital, and adjustments to regulatory capital as defined within the rule. Schedule B contains
summary information about risk-weighted assets by risk type, and, in the case of credit risk
exposures, outstanding balances and aggregated information about the drivers and estimates that
underlie the calculation of risk-weighted assets. Tables 1 and 2 of Schedule A collect
information about each advanced approaches banking organization and top-tier Category III
BHCs, SHCs, and SMBs, and all Category III IHC’s SLR, the ratio of tier 1 capital to total
leverage exposure. Table 1 reconciles balance sheet assets reported in published financial
statements and total leverage exposure. Table 2 collects components of on-balance sheet and offbalance sheet exposures, for the calculation of total leverage exposure, tier 1 capital, and the
calculation of the SLR.

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Schedule B collects general exposure information from advanced approaches banking
organizations. Respondents must report:
• Wholesale exposures, including separate reporting for the following types of exposures:
Corporate; Bank; Sovereign; Income producing real estate; High volatility commercial
real estate; Eligible margin loans, repo-style transactions, and OTC derivatives with cross
product netting; and Eligible margin loans, repo-style transactions, and OTC derivatives
without cross product netting,
• Retail Exposures, including separate reporting for the following types of exposures:
Residential mortgage closed-end first liens, Residential mortgage closed-end junior liens,
Residential mortgage revolving exposures, Qualifying revolving exposures, and Other
retail exposures,
• Securitization exposures,
• Cleared transactions, including separate reporting for the following types of exposures:
Derivative contracts and netting sets to derivatives, Repo-style transactions, and Default
fund contributions,
• Equity exposures, and
• Other assets; including separate reporting for the following types of exposures: Unsettled
transactions, Assets not included in a defined exposure category, Non-material portfolios
of exposures, Credit valuation adjustments, Assets subject to the general risk-based
capital requirements, Excess eligible credit reserves not included in Tier 2 capital,
Advanced market risk equivalent assets; and Operational risk.
Some of the aggregate data items submitted in Schedule B are derived from information
contained in the more detailed confidential supporting schedules described below. The data
contained in Schedule B describe the main summary-level components of respondents’ riskweighted assets.
Wholesale Exposures. Schedules C through J request data on respondents’ wholesale
exposures. Each schedule represents a sub-portfolio of the wholesale exposure category as listed
on Schedule B. For each reported sub-portfolio, the schedule groups exposures into sub-portfolio
segments using supervisor-defined probability of default (PD) ranges. The reported cells within
these schedules then describe the main risk parameters and characteristics of each sub-portfolio
segment.
Retail Exposures. Schedules K through O request data on respondents’ retail exposure
category. Each schedule represents a sub-portfolio of the retail exposure category as listed on
Schedule B. PD ranges are used to sub-divide each sub-portfolio into segments.2 The reported
cells within these schedules then describe the main risk parameters and characteristics of each
sub-portfolio segment. The retail schedules also incorporate risk characteristics that are believed
to be commonly used drivers within respondents’ risk management and measurement processes,
including the distribution of each sub-portfolio segment by loan-to-value ranges (applies only to
real estate exposures), weighted average credit bureau score, and weighted average account age.3
2

Unlike the wholesale credit exposure reporting schedules, the PD ranges for retail exposures differ from subportfolio to sub-portfolio.
3
For qualifying revolving exposures and other (non-mortgage) retail exposures, the exposure at default of accounts
under two years old is reported instead of weighted average age for each sub-portfolio exposure segment.

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Securitization Exposures. Schedule P requests data on respondents’ securitization and
resecuritization exposures that are subject to either the supervisory formula approach, the
simplified supervisory formula approach, a 1250 percent risk weight, or deduction. A respondent
completes Schedule P by providing information on exposure amount, risk-weighted asset
amount, and deduction amount for each securitization and resecuritization based on the treatment
the exposure is subject to under the rule.
Cleared Transactions. Schedule Q requests data on respondents’ cleared transaction
exposures. The schedule divides cleared transactions into subcategories relating to the Clearing
member client bank and to the Clearing member bank. For the Clearing member client bank
category, a respondent completes Schedule Q by providing exposure amount and risk weighted
asset amount information on derivative contracts or netting sets of derivative contracts and repostyle transactions. Schedule Q requests that respondents provide exposure amount from default
fund contributions and risk-weighted asset amounts for exposures within the Clearing member
bank category, which include derivative contracts or netting sets of derivative contracts, repostyle transactions, and default fund contributions to non-qualified and qualified central
counterparties.
Equities. Schedule R requests information about respondents’ equity exposures by type of
exposure and by approach to measuring required capital. Schedule R also requests information
on equity exposures subject to specific risk weights and equity exposures to investment funds. A
respondent completes the appropriate section of the schedule based on whether it uses a simple
risk-weight approach, a full internal models approach, or a partially modeled approach to
measuring required capital for equity exposures.
Operational Risk. Schedule S requests data on respondents’ operational risk exposure.
Data items submitted in this schedule include various details about historical operational losses,
on a stand-alone and group-wide basis, for the current reporting period and those historical
operational losses used to model operational risk capital. The schedule also requests data related
to scenarios, distribution assumptions, and loss caps used to model operational risk capital.
Respondent Panel
The FFIEC 101 panel comprises SMBs, BHCs, SLHCs, and other Board-regulated
institutions that are subject to the advanced approaches framework pursuant to subpart E of the
Board’s Regulation Q (12 CFR Part 217, Subpart E), as well as, with regard to Schedule A, SLR
Tables 1 and 2, top-tier Category III SMBs, BHCs, SLHCs, and all Category III IHCs.
Frequency and Time Schedule
The FFIEC 101 is collected quarterly as of the end of the last calendar day of March,
June, September, and December. Respondents must begin reporting on the FFIEC 101,
Schedule A, except for a few specific line items, beginning with the calendar quarter
immediately following the quarter in which the respondent becomes an advanced approaches or
Category III banking institution (Schedule A, SLR Tables 1 and 2 only for Category III banking
institutions), or elects to use the advanced approaches rule (an opt-in institution), and must begin

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reporting data on the remaining schedules (except for Category III banking institutions) of the
FFIEC 101 at the end of the first quarter in which they have begun their parallel run period.
The report due dates are 60 days following the end of a quarter while a respondent is in
its parallel run period. After completing its parallel run period, the report due dates are the same
as the report due dates currently required of respondents when filing their respective Call Report
or FR Y-9C4. SMBs must submit the FFIEC 101 to the appropriate Federal Reserve Bank within
thirty calendar days following the as of date; a five-day extension may be given to banks with
more than one foreign office. BHCs, SLHCs, and IHCs must submit the FFIEC 101 to the
appropriate Federal Reserve Bank within forty calendar days after the March 31, June 30, and
September 30 as of dates unless that day falls on a weekend or holiday (received on the first
business day after the Saturday, Sunday, or holiday) and within forty-five calendars days after
the December 31 as of date.
In general, a reporting entity should maintain in its files a signed and attested record of its
completed FFIEC 101 report, including any amended reports, and the related work papers and
supporting documentation for five years after the report date, unless there are applicable state
requirements that mandate a longer retention time.
Public Availability of Data
For report dates before a reporting institution has completed its parallel run period,
Schedule A will be available to the public, except for items 78 (total eligible credit reserves
calculated under the advanced approaches rules), 79 (amount of eligible credit reserves
includable in tier 2 capital), 86 (expected credit loss that exceeds eligible credit reserves);
87 (advanced approaches risk-weighted assets), 88 (common equity tier 1 capital ratio calculated
using the advanced approaches), 89 (additional tier 1 capital ratio calculated using the advanced
approaches), and 90 (total capital ratio using the advanced approaches). Information reported in
all other schedules of the FFIEC 101 are confidential. For report dates after a reporting
institution has completed its parallel run period, all items reported in Schedules A and B (except
for Schedule B, items 31.a and 31.b, column D) and items 1 and 2 of Schedule S are available to
the public. All other items reported in the FFIEC 101 are confidential. Note that for both before
and after an institution has completed its parallel run period, all items reported on Schedule A,
SLR Tables 1 and 2, are available to the public.
Individual respondent data, excluding confidential information, are available on the
National Information Center public website.
Legal Status
The Board is authorized to collect the information on the FFIEC 101 report from SMBs
pursuant to section 9(6) of the Federal Reserve Act (12 U.S.C. § 324), from BHCs pursuant to
section 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. § 1844(c)), from
SLHCs pursuant to section 10 of the Home Owners’ Loan Act (12 U.S.C. § 1467a(b)(2)), and
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Consolidated Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB No.
7100-0036) and the Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No. 7100-0128).

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from IHCs pursuant to section 5(c) of the BHC Act (12 U.S.C. § 1844(c)(1)(A)), as well as
pursuant to sections 102(a)(1) and 165 of the Dodd-Frank Wall Street and Consumer Protection
Act (Dodd-Frank Act) (12 U.S.C. §§ 5311(a)(1) and 5365.)5 and sections 8(a) and 13(a) of the
International Banking Act of 1978 (12 U.S.C. §§ 3106 and 3108(a)). The quarterly FFIEC 101
report is mandatory for reporting institutions.
For report dates before a reporting institution has completed its parallel run period,
Schedule A, except for items 78, 79, and 86-90, is released to the public. All of the information
reported in the other schedules of the FFIEC 101 will be confidential. For report dates after
reporting institution has completed its parallel run period, all items reported in Schedules A and
B (except for Schedule B, items 31.a and 31.b, column D) and items 1 and 2 of Schedule S will
be available to the public. All other items reported in the FFIEC 101 will be confidential. All
items reported on Schedule A, SLR Tables 1 and 2, are available to the public.
A reporting institution may request confidential treatment for some or all of the portions
of the FFIEC 101 report that will be made available to the public if the institution is of the
opinion that disclosure of specific commercial or financial information in the report would likely
result in substantial harm to its competitive position, or that disclosure of the submitted
information would result in an unwarranted invasion of personal privacy. If a reporting
institution requests confidential treatment, the Board will determine whether the information is
entitled to confidential treatment on a case-by-case basis. To the extent a reporting institution
submits confidential commercial or financial information in connection with the FFIEC 101,
which is both customarily and actually treated as private by the reporting institution, the
reporting institution may request confidential treatment pursuant to exemption 4 of the FOIA
(5 U.S.C. § 552(b)(4)).
Finally, the Board uses data from the FFIEC 101 to supplement on-site examination
processes. Therefore, this information can be kept confidential under FOIA exemption 8
(5 U.S.C. § 552(b)(8)), because it is matter 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.
Consultation Outside the Agency
The Board, FDIC, and OCC coordinated in developing this clearance.

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 of the
foreign banking organizations that are 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 FFIEC 101 report.
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Public Comments
On June 29, 2023, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (88 FR 42131) requesting public comment for 60 days on the
extension, without revision, of the FFIEC 101. The comment period for this notice expired on
August 28, 2023. The agencies did not receive any comments. On October 13, 2023, the
agencies, under the auspices of the FFIEC, published a final notice in the Federal Register (88
FR 71083) requesting public comment for 30 days on the extension, with revision, of the
FFIEC 101. The comment period for this notice expires on November 13, 2023.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FFIEC 101 is
35,288 hours. These reporting requirements represent less than 1 percent of the Board’s total
paperwork burden.
Estimated Estimated
Estimated
number of
annual
average hours
respondents6 frequency per response

FFIEC 101

Estimated
annual burden
hours

SMBs
BHCs and SLHCs
BHCs and SLHCs
(SLR Tables 1 and 2 only)

4
9

4
4

674
677

10,784
24,372

5

4

3

60

IHCs

6

4

3

72
35,288

Total

The estimated total annual cost to the public for the FFIEC 101 is $2,337,830.7
Sensitive Questions
This collection of information contains no questions of a sensitive nature, as defined by
OMB guidelines.

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Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $850 million in total assets). Size standards effective March 17, 2023. See
https://www.sba.gov/document/support-table-size-standards.
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Total cost to the responding public is estimated using the following formula: total burden hours, multiplied by the
cost of staffing, where the cost of staffing is calculated as a percent of time for each occupational group multiplied
by the group’s hourly rate and then summed (30% Office & Administrative Support at $22, 45% Financial
Managers at $80, 15% Lawyers at $79, and 10% Chief Executives at $118). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2022, published April 25, 2023, 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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Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
report is $157,700 per year.

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