FFIEC019_20240808_omb

Supporting Statement for the
Country Exposure Report for U.S. Branches and Agencies of Foreign Banks
(FFIEC 019; OMB No. 7100-0213)
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) Country Exposure Report for U.S.
Branches and Agencies of Foreign Banks (FFIEC 019; OMB No. 7100-0213). The Board
submits this request on behalf of the Board, Federal Deposit Insurance Corporation (FDIC), and
Office of the Comptroller of the Currency (OCC) (the agencies). No separate submission will be
made by the FDIC or OCC. The report is required and must be submitted quarterly by all
individual U.S. branches and agencies of foreign banks that have total direct claims on foreign
residents in excess of $30 million. Each reporting branch or agency provides information for
supervisory purposes on its direct and indirect claims, total adjusted claims on foreign residents,
and information on commitments.
The estimated total annual burden for the FFIEC 019 is 5,560 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
The FFIEC 019 is an important and unique tool for surveillance and oversight that
collects the minimal amount of information needed for supervisory purposes under the
International Banking Act of 1978 (IBA). The FFIEC implemented the FFIEC 019 report in June
1986 in response to supervisory concerns relating to funding practices of certain U.S. branches
and agencies of foreign banks that were raising funds in the United States and other nations’
interbank markets, and then lending the bulk of the funds to home-country residents. Major
funding problems emerged for these U.S. offices when the governments of the parent banks’
home countries encountered severe difficulties in servicing their external debt. In 1985 the
Board, FDIC, and OCC proposed collection of country exposure information from U.S. branches
and agencies in order to supervise their operations more effectively. 1
Quarterly information on significant country risk exposures is very important in
measuring and supervising liquidity positions of the branches and agencies of foreign banks,
which fund themselves primarily in the U.S. domestic money markets by taking large uninsured
deposits from banks, corporations, and individuals. Those branches that are insured by the FDIC
also raise funds from retail customers. The financial regulatory agencies need to be able to assess
the institutions’ ability to repay these deposits.
One important indicator of potential underlying problems is an excessive concentration
In addition, the agencies’ collection of this information is consistent with the Basel Concordat. See Basel
Committee on Banking Supervision, Core Principles for effective banking supervision,
https://www.bis.org/bcbs/publ/d573.htm (April 2024).
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by the U.S. branch or agency in assets due from parties in a single country or a small number of
countries. The regulatory agencies need access to information regarding the level of country
concentrations within a specific branch or agency, to ensure that these institutions, like domestic
banking institutions, are practicing reasonable country risk diversification. The FFIEC 019
assists the agencies in monitoring the extent to which the U.S. branches and agencies are
pursuing prudent diversification policies and limiting potential liquidity pressures.
In addition, FDIC-insured branches of foreign banks are subject to an asset maintenance
requirement (12 CFR 347.210). Under this requirement, in general, an insured branch must
maintain on a daily basis eligible assets in an amount not less than 106 percent of the preceding
quarter’s average book value of the branch’s liabilities, exclusive of liabilities due to related
offices of the foreign bank. The FDIC may require that a higher ratio of eligible assets be
maintained if the financial condition of the insured branch warrants such action. Among the
factors that the FDIC considers in requiring a higher ratio is the concentration of transfer risk to
any one country, including the country in which the foreign branch’s head office is located. The
data from the FFIEC 019 report assist the FDIC in evaluating the existence of such
concentrations and determining whether to require that an insured branch maintain a higher ratio
of eligible assets than the 106 percent minimum.
In order to limit reporting burden, the FFIEC 019 has been designed to collect the
minimum amount of information needed to assess country exposure. The report currently
requires each of the U.S. branches and agencies with claims on foreign parties exceeding $30
million to report (1) its exposure to borrowers in its home country and (2) each country exposure
exceeding $20 million. These requirements are considerably less burdensome than the
information required of domestic banking institutions on the Country Exposure Report
(FFIEC 009; OMB No. 7100-0035), which requires information on all country exposures and
requires considerably greater maturity detail. Because smaller institutions are often more likely
to encounter funding problems than larger ones, the agencies do not believe that it is appropriate
to increase the minimum exposure level that must be reported.
Description of Information Collection
The FFIEC 019 report must be filed by each U.S. branch or agency of a foreign bank that
has total direct claims (including those of its International Banking Facility (IBF))2 on foreign
residents in excess of $30 million. Currently, the branch or agency reports its gross claims on
(1) to residents of its home country (including related non-U.S. offices of the reporting
institution) and (2) residents of foreign countries for which the branch or agency’s adjusted
exposure for the country at least $20 million. The home country exposure must be reported
regardless of the size of the total claims for that nation.

2

An IBF is a set of asset and liability accounts, which are segregated on the books and records of the establishing
entity and which reflect international transactions. An IBF is established in accordance with the terms of the Federal
Reserve’s Regulation D and after appropriate notification to the Federal Reserve. The establishing entity may be a
U.S. depository institution, a U.S. office of an Edge or agreement corporation, or a U.S. branch or agency of a
foreign bank pursuant to the Federal Reserve’s Regulations D and Q. An IBF is permitted to hold only certain assets
and liabilities. In general, IBF accounts are limited to non-U.S. residents of foreign countries, residents of Puerto
Rico and U.S. territories and possessions, other IBFs, and U.S. and non -U.S. offices of the establishing entity.

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Each reporting branch or agency must report, by country as appropriate information on
its (1) direct claims (claims in which the immediate obligor is a resident of the relevant country),
(2) indirect claims (claims arising because a resident of the relevant country is the ultimate
obligor, through guarantees or other means, of the relevant claim if the immediate obligor is
unable to satisfy the claim) and (3) adjusted claims (total claims once direct claims are reduced
by claims that are guaranteed by parties in another country and increased by direct claims on
parties in other countries that parties in the country have guaranteed). In addition, respondents
must provide information on their outstanding and unused letters of credit that have been issued
for account parties that are residents of the relevant countries. Respondents must also report
claims on related non-U.S. offices that are included in total adjusted claims. Finally, respondents
must provide a breakdown of claims on unrelated foreign residents by the type of borrower or
guarantor (foreign public, unrelated foreign banks, or unrelated foreign residents), and by
maturity (in two categories: one year or less, and over one year).
Respondent Panel
The FFIEC 019 panel comprises all branches and agencies of foreign banks domiciled in
the United States with total direct claims (including those of its IBF) on foreign residents in
excess of $30 million on the quarterly report date.
Frequency and Time Schedule
The FFIEC 019 is filed quarterly as of the last business day of March, June, September,
and December. Each reporting branch or agency must file its report with the appropriate Reserve
Bank within 45 days of the report date.
Public Availability of Data
The agencies do not routinely publicly release information collected through the
FFIEC 019.
Legal Status
The agencies are authorized to collect the FFIEC 019 under the IBA, Federal Deposit
Insurance Act, National Bank Act, and Federal Reserve Act. Section 7 of the IBA (12 U.S.C. §
3105(c)(2)) provides that branches and agencies of foreign banks other than federal branches and
agencies are subject to the same reporting requirements as apply to state member banks under
section 9(6) of the Federal Reserve Act (12 U.S.C. § 324), which requires a state member bank
to make reports of condition to the Federal Reserve Bank of which it becomes a member.
In addition, section 7 of the IBA states that federal branches and agencies are subject to
section 4 of the IBA (12 U.S.C. § 3102(b)), which provides that federal branches and agencies
are subject to all the same duties as would apply to a national bank under the National Bank
Act.3 Section 34 the National Bank Act requires national banks (and thus, by virtue of section 4
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Section 4 of the IBA also provides that in establishing and operating a federal branch or agency, a foreign bank
shall be subject to such rules, regulations, and orders as the Comptroller considers appropriate.

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of the IBA, federal branches and agencies) to make reports of condition to the OCC in
accordance with the Federal Deposit Insurance Act (12 U.S.C. § 161(a)). Section 34 of the
National Bank Act also allows the OCC to call for additional reports of condition containing
such information as the Comptroller prescribes.4
Finally, section 7 of the IBA provides that federal branches and agencies are subject in
the same manner as member banks to section 11(a) of the Federal Reserve Act (12 U.S.C. §
248), which authorizes the Board to require member banks to provide it with reports of the
accounts, books, and affairs and liabilities and assets, as the Board deems necessary.
Section 13 of the IBA authorizes the Board, FDIC, and OCC to issue such rules,
regulations, and orders as each of them deems necessary to perform their respective duties and
functions under Chapter 32 of Title 12, which governs foreign bank participation in domestic
markets (12 U.S.C. § 3108(a)). The agencies’ duties and functions under Chapter 32 consist of
overseeing the activities of foreign branches and agencies in the United States, including (but not
limited to) determining whether it is necessary to terminate those activities (e.g., due to unsafe or
unsound banking practices or financial stability risk posed to the United States posed by the
branch or agency that has not been mitigated by home country financial regulation). 5 This
authority thus allows the agencies to impose reporting requirements as necessary to perform their
duties and functions of overseeing the activities of foreign branches and agencies.
Section 13 of the IBA further provides that the Board has authority over the
administration, interpretation, and enforcement of provisions of the Federal Reserve Act that
apply to foreign banks or branches thereof under Chapter 32 and which are made applicable to
nonmember insured banks by the Federal Deposit Insurance Act (12 U.S.C. § 3108(c)).
However, the FDIC has authority to require a duplicate copy of any report that the Board
requires under this authority.
Section 7 of the Federal Deposit Insurance Act provides that state nonmember banks and
foreign banks with insured branches that are not federal branches are required to make reports of
condition to the FDIC, as the FDIC may require (12 U.S.C. § 1817(a)(1)). The obligation to
respond to the FFIEC 019 is mandatory.
The information submitted in the FFIEC 019 may be exempt from public disclosure
pursuant to the Freedom of Information Act (FOIA), under exemptions 4 and/or 8 (12 U.S.C. §§
552(b)(4), (b)(8)). Exemption 4 applies to confidential commercial or financial information that
is both customarily and actually treated as private by its owner (12 U.S.C. § 552(b)(4)).6 If a
respondent believes that any of the public portions of its FFIEC 019 report would be exempt
from disclosure under exemption 4 of the FOIA, the respondent may request confidential
treatment for such information. Exemption 8 exempts from disclosure information “contained in
or related to examination, operating, or condition reports prepared by, on behalf of, or for the use
4

See 12 U.S.C. § 161(a). Section 34 refers only to national banks (i.e., associations). However, under section 4 of
the IBA, federal branches and agencies are generally subject to all the same duties that apply to national banks,
which includes reporting requirements. See 12 U.S.C. § 3102(b).
5 12 U.S.C. §§ 3105(c) (examination and reporting authority); 3105(e) (termination authority).
6 See Food Marketing Institute v. Argus Leader Media, 588 U.S. 427, 440 (2019).

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of an agency responsible for the regulation or supervision of financial institutions” (12 U.S.C. §
552(b)(8)). As documents related to the branches and agencies’ condition prepared for the use of
the agencies, which are responsible for the regulation and supervision of financial institutions,
FFIEC 019 reports may also be exempt from disclosure under exemption 8.
Consultation Outside the Agency
The Board coordinated and consulted with the FDIC and OCC with respect to this
proposal to extend the FFIEC 019.
Public Comments
On March 4, 2024, the Board published an initial notice in the Federal Register (89 FR
15575) requesting public comment for 60 days on the extension, without revision, of the
FFIEC 019. The comment period for this notice expired on May 3, 2024. The Board did not
receive any comments. On July 30, 2024, the Board published a final notice in the Federal
Register (89 FR 61119) requesting public comment for 30 days on the extension, without
revision, of the FFIEC 019. The comment period for this notice expires on August 29, 2024.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FFIEC 019 is
5,560 hours. The estimated total number of respondents is based on the number of respondents
that submitted a FFIEC 019 report as of March 31, 2024. These reporting requirements represent
less than 1 percent of the Board’s total paperwork burden.

FFIEC 019
Current

Estimated
number of
respondents7
139

Estimated
Estimated
annual
average hours
frequency per response
4
10

Estimated
annual burden
hours
5,560

The estimated total annual cost to the public for the FFIEC 019 is $388,366.8
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
7

Of these respondents, 24 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. There are no special accommodations given to mitigate
the burden on small institutions.
8 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 $23, 45% Financial
Managers at $84, 15% Lawyers at $85, and 10% Chief Executives at $124). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2023, published April 3, 2024, 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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OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing the
FFIEC 019 is $13,100. The Federal Reserve System collects and processes the data for all three
of the federal bank regulatory agencies.

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