FFIEC 030 and FFIEC 030S 18 Question Format OMB Supporting Statement

Supporting Statement for the
Foreign Branch Report of Condition
(FFIEC 030 and FFIEC 030S; OMB No. 7100-0071)
1.

Explain the circumstances that make the collection of information necessary.

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, with revision, the
Federal Financial Institutions Examination Council (FFIEC) Foreign Branch Report of Condition
(FFIEC 030 and FFIEC 030S; OMB No. 7100-0071). Insured domestically chartered
commercial banks and savings associations (U.S. banks) that have one or more branch offices in
a foreign country are required to report balance sheet information for each of their foreign
branches on either the FFIEC 030 or the FFIEC 030S. The FFIEC 030 is collected annually as of
December 31 or quarterly for significant branches as of the last day of each calendar quarter; the
FFIEC 030S is an abbreviated reporting form filed annually by smaller institutions.
The Federal Reserve receives reports for all foreign branches of U.S. banks, regardless of
charter type, on behalf of the U.S. banks’ primary federal bank regulatory agency (Board,
Federal Deposit Insurance Corporation (FDIC), or Office of the Comptroller of the Currency
(OCC) (collectively, the agencies)). The agencies use the FFIEC 030 and FFIEC 030S reports to
fulfill their statutory obligation to supervise foreign operations of domestic banks. The FDIC and
the OCC have also submitted similar requests for OMB review to request this information from
banks under their supervision.
The agencies, under the auspices of the FFIEC, propose to revise the FFIEC 030 by
incorporating line items from the Quarterly Report of Assets and Liabilities of Large Foreign
Offices of U.S. Banks (FR 2502q; OMB No. 7100-0079) into the FFIEC 030. The proposed
revisions to the FFIEC 030 would be effective as of the March 31, 2025, report date for branches
that currently meet the criteria to file the FR 2502q (i.e., those located in the U.K. or Caribbean).
For a branch that does not meet the current criteria to file the FR 2502q, but files the FFIEC 030
on a quarterly basis, the effective date for these new items would be as of December 31, 2025.
There are no proposed revisions to the FFIEC 030S.
2.

Indicate how, by whom, and for what purpose the information is to be used. Except
for a new collection, indicate the actual use the agency has made of the information
received from the current collection.

The FFIEC 030 and FFIEC 030S collect information on the structure and geographic
distribution of foreign branch assets and liabilities. The agencies use this information to plan
examinations and to analyze the foreign operations of U.S. banks, in connection with the
agencies’ statutory responsibility to assess the safety and soundness of the U.S. banks that they
supervise. The information collected by the FFIEC 030 and FFIEC 030S allows the agencies to
measure growth trends by bank, by country, and by bank within country. Additionally, aggregate
data that is publicly released by the agencies are a useful source of information on U.S. bank
activities for the general public. This series of data collected by these reports is the oldest

statistical series that exists for foreign branches of U.S. banks and is an important source for
measuring the growth of these offices.
3.

Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology.

Reporting branches that wish to submit the FFIEC 030 or the FFIEC 030S report
electronically using the Federal Reserve’s Reporting Central application should contact their
Reporting and Reserves District Contact (http://www.frbservices.org/contacts/index.jsp#RR) for
instructions. If the FFIEC 030 or FFIEC 030S report is filed electronically, the completed and
signed original report need not be filed with the appropriate Federal Reserve District Bank.
However, the parent U.S. institution must maintain the completed and signed original report in
its files.
4.
Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.
The FFIEC 030 is the only report through which the agencies collect balance sheet
information on foreign branches of U.S. banks. The Board uses another report, the Quarterly
Report of Assets and Liabilities of Large Foreign Offices of U.S. Banks (FR 2502q; OMB No.
7100-0079), to collect less detailed balance sheet information from parent institutions of foreign
branches or subsidiaries (specifically, those with total assets of $500 million or more). The
FR 2502q collects only gross assets and liabilities by the country of the principal address of the
customer, rather than the type of assets and liabilities of the branch. Although the FR 2502q does
not provide comparable information, the Board may check the FFIEC 030 to verify that
individual branches that report total assets greater than or equal to $500 million also report on the
FR 2502q. The FR 2502q would be discontinued following this clearance.
5.

If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize burden.

Of these respondents, 3 for the FFIEC 030 Quarterly; 7 for the FFIEC 030 Annual; and 9
for the FFIEC 030S 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.
The FFIEC 030S is an abbreviated reporting form containing five data items that U.S.
banks must file with regard to foreign branches with total assets between $50 million and $250
million file annually. These data items are the minimum information needed to serve as
indicators of higher business volume, risk, and complexity in small-sized foreign branches. The
reported information also is used to monitor potential developments that may pose risks to the
overall operations of the parent bank. U.S. banks do not have to file an FFIEC 030 or
FFIEC 030S with respect to any foreign branch with total assets of less than $50 million and that
do not otherwise meet the requirements to file the FFIEC 030 quarterly.

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6.

Describe the consequence to Federal program or policy activities if the collection is
not conducted or is conducted less frequently, as well as any technical or legal
obstacles to reducing burden.

If this collection were conducted less frequently than the present annual collection, the
agencies would have insufficient information regarding U.S. bank activity in the Eurocurrency
markets and at specific foreign locations on which to base informed policy decisions, reports to
Congress, and foreign branch examinations. Quarterly reporting by the largest foreign branches
permits agencies to monitor foreign currency markets in a timely manner while minimizing
burden on the respondents as a whole.
7.

Explain any special circumstances that would cause an information collection to be
conducted in a manner inconsistent with 5 CFR 1320.5(d)(2).

This information collection is conducted in a manner consistent with the guidelines in 5
CFR 1320.5(d)(2).
8.

Describe comments in response to the Federal Register notice and efforts to consult
outside the agency.

On January 19, 2024, the agencies, under the auspices of the FFIEC, published an initial
notice in the Federal Register (89 FR 3708) requesting public comment for 60 days on the
extension, with revision, of the FFIEC 030 and FFIEC 030S. The comment period for this notice
expired on March 19, 2024. The agencies received comments from two banking associations.
These comments were generally supportive of the proposed new line items. After reviewing the
comments, the agencies are moving forward with the proposed revisions to the FFIEC 030, with
certain modifications. The specific comments, the agencies’ responses, and pertinent
modifications follow.
First, one commenter urged the agencies to limit the scope of respondents subject to the
proposed Schedule RAL-A to those that meet the current criteria to file the FR 2502q. The
commenter stated that there are significant scoping differences between the FR 2502q and the
FFIEC 030. The FR 2502q reporting is limited to branches with total assets of $2 billion or more
and that are located in the United Kingdom (U.K.) or the Caribbean. The FFIEC 030 quarterly
reporting requirements, however, scope in any branch with either total assets of at least $2 billion
or commitments to purchase foreign currencies and U.S. dollar exchange (a purchase of U.S.
dollar exchange is equivalent to a sale of foreign currency) of at least $5 billion as of the end of a
calendar quarter. The commenter stated that the FFIEC 030’s reporting scope, without the
geographic limitation to branches in the U.K. and the Caribbean, results in a much greater
reporting burden on firms.
Furthermore, this commenter also stated that the proposed changes and increased
granularity of the items reported would necessitate both the development of new systems, as well
as modifications to existing ones. For example, the commenter noted the amount to be reported
on proposed Schedule RAL-A, line item 5, “Assets that are claims on U.S. addressees other than
depository institutions,” includes new sub-line items that are more granular than the amount
currently reported in FR 2502q item 1.c, “U.S. addresses other than depository institutions,” and
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would increase burden to all filers of the FFIEC 030. This reporting burden would be greatest on
respondents that have newly scoped-in entities that would be reporting this information for the
first time. In light of this, the commenter requested that, if the scope of respondents on the
proposed FFIEC 030 Schedule RAL-A is not limited to those that currently meet the criteria to
file the FR 2502q, branches would need at least four quarters from publication of the final forms
and instructions to implement the revisions. However, if the scope were limited to branches that
meet the current criteria to file the FR 2502q, branches would only need two additional quarters
to implement the proposal.
The agencies acknowledge that branches may need additional time to develop their
reporting systems to implement these changes. As such, the agencies will delay the
implementation date based on the branch meeting the criteria to file the FR 2502q. Beginning as
of the March 31, 2025, report date, all branches that are located in the U.K. or Caribbean (that
are not located in a U.S. military facility), and with total assets of at least $2 billion (as reported
in Schedule RAL, item 11) as of the end of the calendar quarter, must complete new Schedule
RAL-A. Beginning as of the December 31, 2025, report date, all branches required to report the
FFIEC 030 on a quarterly basis must complete new Schedule RAL-A without any geographic
limitation of being located in the U.K. or Caribbean. Branches that file the FFIEC 030 on an
annual basis do not need to report the new items. The FFIEC 030 instructions will be updated to
reflect these changes.
Second, the commenter requested that the agencies clarify the reporting of proposed
Schedule RAL-A, line item 5, “Assets that are claims on U.S. addressees other than depository
institutions,” by adding a Micro Data Reference Manual (MDRM) number and to include in the
instructions that this line item is not an aggregate total of its sub-items. The commenter also
requested that the agencies clarify whether Schedule RAL-A, line item 6, “Liabilities to U.S.
addressees other than depository institutions,” is intended to extend to all liabilities or if
respondents should report only deposit liabilities. In response, the agencies are revising the
report form by adding a MDRM to line item 5 on Schedule RAL-A and also clarifying in the
instructions that line item 5 on Schedule RAL-A is not an aggregate total of sub-items 5.a
through 5.d. The agencies are also clarifying in the instructions of Scheduled RAL-A, line
item 6, that it is intended to extend to all liabilities and not only to deposit liabilities.
Lastly, separate from this proposal, on June 7, 2024, the Board published in the Federal
Register an initial notice1 requesting public comment for 60 days on the extension with revision
to the Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314).
The comment period of the June notice ended on August 6, 2024, and the Board received a
comment from a banking trade organization regarding the proposed changes to the FFIEC 030.
Specifically, the commenter requested clarification on the reporting of claims/liabilities with
related institutions on the FFIEC 030. In the proposed instructions of Schedule RAL-A line items
5 and 6, it states to “Report claims/liabilities on U.S. addressees other than parent bank and other
depository institutions” and contains no specific instructions on how to treat claims/liabilities
with related institutions. However, on the proposed FR 2314 Schedule BS-Q line items 3 and 4,
the instructions explicitly state to “exclude balances with related institutions.”

1

See 89 FR 48639 (June 7. 2024).

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The commenter requested that the Board work with the other agencies to clarify that
balances with related institutions, as defined in FFIEC 030S and reported in FFIEC 030 proposed
Schedule RAL-A items 1-4, should be excluded for the purposes of FFIEC 030 Schedule RAL-A
items 5 and 6. In response to the commenter, to make the instructions more parallel between the
FFIEC 030 and FR 2314, the agencies will clarify in the FFIEC 030 instructions to explicitly
exclude balances with related institutions from the amounts reported in Schedule RAL-A, items
5 and 6.
The proposed revisions to the FFIEC 030 would be effective as of the March 31, 2025,
report date for branches that currently meet the criteria to file the FR 2502q (i.e., those located in
the U.K. or Caribbean). For a branch that does not meet the current criteria to file the FR 2502q,
but files the FFIEC 030 on a quarterly basis, the effective date for these new items will be as of
December 31, 2025.
On October 7, 2024, the agencies, under the auspices of the FFIEC, published a final
notice in the Federal Register (89 FR 81137) requesting public comment for 30 days on the
extension, with revision, of the FFIEC 030 and FFIEC 030S. The comment period for this notice
expires on November 6, 2024.
9.

Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There are no payments or gifts provided to respondents.

10.

Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or agency policy. If the collection requires a
systems of records notice (SORN) or privacy impact assessment (PIA), those should
be cited and described here.

The information that is required to be provided on the FFIEC 030 and FFIEC 030S is
collected as part of the Board’s supervisory process. Accordingly, such information is afforded
confidential treatment under exemption 8 of the Freedom of Information Act (FOIA), which
protects information from disclosure that is contained in or related to the examination or
supervision of a financial institution (5 U.S.C. § 552(b)(8)). In addition, the FFIEC 030 and
FFIEC 030S are likely to contain nonpublic commercial or financial information, which is both
customarily and actually treated as private by the respondent. Accordingly, such information
may be withheld under exemption 4 of the FOIA (5 U.S.C. § 552(b)(4)). In limited
circumstances, aggregate data for multiple respondents, which does not reveal the identity of any
individual respondent, may be released to the public.
11.

Provide additional justification for any questions of a sensitive nature.
There are no questions of a sensitive nature.

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12.

Provide estimates of the annual hourly burden of the collection of information.

As shown in the table below, the estimated total annual burden for the FFIEC 030 and
FFIEC 030S is 289 hours, and would increase to 367 hours with the proposed revisions. These
reporting requirements represent less than 1 percent of the Board’s total paperwork burden.

FFIEC 030 and FFIEC 030S

Estimated
number of
respondents

Estimated
Estimated
annual
average hours
frequency per response

Estimated
annual burden
hours

Current
FFIEC 030 Quarterly
FFIEC 030 Annual

21
10

4
1

2.98
2.98

250
30

FFIEC 030S

9

1

0.95

9
289

21
10
9

4
1
1

3.91
2.98
0.95

328
30
9

Current Total
Proposed
FFIEC 030 Quarterly
FFIEC 030 Annual
FFIEC 030S
Proposed Total

367

Change

78

The estimated total annual cost to the public for the FFIEC 030 and FFIEC 030S is
$20,187, and would increase to $25,635 with the proposed revisions.
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/.
13.

Provide an estimate for the total annual cost burden to respondents or record
keepers resulting from the collection of information.
There are no annualized costs to the respondents.

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14.

Provide estimates of annualized costs to the Federal government.

The estimated annual cost to the Federal Reserve System for collecting and processing
the FFIEC 030 and FFIEC 030S is $35,200. The Federal Reserve System collects and processes
the data for all three of the agencies.
15.

Explain the reasons for any program changes or adjustments reported on the
burden worksheet.

The FR 2502q collects data on the claims and liabilities with U.S.-resident versus
foreign-resident counterparties on the balance sheets of major foreign branches and large
banking subsidiaries of U.S. head offices of bank holding companies, commercial banks, and
Edge and agreement corporations.2 For the reporting purposes of the FR 2502q, large foreign
branches are currently defined as those that file the Foreign Branch Report of Condition
(FFIEC 030; OMB No. 7100-0071) with total assets, Schedule BS, item 11, of $2 billion or
more. Large banking subsidiaries are defined as those that file the Financial Statements of
Foreign Subsidiaries of U.S. Banking Organizations (FR 2314; OMB No. 7100-0073) quarterly,
have a banking charter, and have assets of $2 billion or more and deposits of $10 million or
more, Schedule BS, item 10, and Schedule BS-M, item 6, respectively.
The Division of International Finance at the Board has an interest in knowing the
amounts of the claims and liabilities of U.S.-chartered banks with respect to residents of the U.S.
The FR 2502q provides data about activities in foreign offices by location and type of offices
that are unavailable from other reporting forms. For example, because banks’ submissions that
underlie the quarterly Federal Financial Institutions Examination Council (FFIEC) Country
Exposure Report (FFIEC 009; OMB No. 7100-0035) are consolidated on a worldwide basis, they
do not indicate which particular offices are involved in lending to or borrowing from U.S. or
foreign residents.
Following a 2015 revision that substantially reduced the size of the FR 2502q report, the
Board has assessed its use of the data collected in the FR 2502q and has determined that the data
could instead be effectively collected through the FR 2314 and FFIEC 030, and that doing so
would reduce overall respondent burden.
In addition, standardizing the collection of foreign branch lending data through the
FFIEC reporting process will improve useability by the FDIC and OCC. The current FR 2502q
collection is managed and run solely by the Board. The proposed shift of certain items to the
FFIEC 030 will make it easier for the FDIC and OCC to use the data reported in those items, as
well as providing those agencies with a more direct role in proposing changes to the data items to
improve the usefulness of the collection for all three agencies.
Therefore, the agencies propose to add a new schedule to the FFIEC 030 to collect the
information currently collected by the FR 2502q and add additional line items to collect granular
Prior to 2015, the FR 2502q collected a full geographic distribution of claims and liabilities from these
respondents. However, data on individual foreign counterparty countries became redundant with the expansion of
other international data collections.
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detail related to loans and lease receivables. The title of the new schedule would be “Schedule
RAL-A – Due From, Due To, and Other.” In addition, the agencies are adding a schedule name
to the current Assets; Liabilities; Derivatives and Off-Balance-Sheet Items; and Memoranda
section of the report form. The title of this schedule will be “RAL – Assets and Liabilities.”
Adding a schedule name to this section will help separate the current items from the proposed
new items that will only be applicable to respondents that are required to submit their FFIEC 030
report on a quarterly basis. Respondents that submit their FFIEC 030 report on an annual basis
will not need to complete the proposed new schedule.
Eight of the proposed line items would provide a granular breakout of what is currently
collected on line items 8, 9, 16, and 17. The remaining six proposed line items would be new to
the FFIEC 030 report. The agencies propose to incorporate the following line items from the
FR 2502q into FFIEC 030, Schedule RAL-A – Due From, Due To, and Other:
Item 1a: Gross due from head office and U.S. branches of this bank,
Item 1b: Gross due from other foreign branches of this bank,
Item 2a: Gross due from consolidated subsidiaries of this bank in the U.S.,
Item 2b: Gross due from consolidated subsidiaries of this bank in foreign countries,
Item 3a: Gross due to head office and U.S. branches of this bank,
Item 3b: Gross due to other foreign branches of this bank,
Item 4a: Gross due from consolidated subsidiaries of this bank in the U.S.,
Item 4b: Gross due from consolidated subsidiaries of this bank in foreign countries,
Item 5: Assets that are claims on U.S. addressees other than depository institutions, and
Item 6: Liabilities to U.S. addressees other than depository institutions.
In addition, the proposed line items below would provide the agencies with more granular
data about certain categories of loans and lease receivables, which is expected to be reported in
the balance of line item 5 above. Collection of the additional line items would provide the
agencies with the ability to analyze lending by foreign branches of U.S. banks to U.S. addresses
in different sectors. For example, it is not uncommon for foreign branches to make loans secured
by U.S. real estate. As lending to nondepository institutions continues to increase, segmenting
the lending between foreign and U.S. addresses improves the ability of agencies to assess risks to
this type of lending. The same reasoning applies to commercial and industrial loans and all other
loans and leases. The proposed sub-set of line items are as follows:
Assets that are claims on U.S. addressees other than depository institutions:
Item 5a: Loans secured by real estate,
Item 5b: Loans to nondepository financial institutions,
Item 5c: Commercial and industrial loans, and
Item 5d: All other loans and all leases.
These proposed revisions would reduce the burden on respondents and assist the agencies
in meeting shared data needs with shared resources. The Board will propose similar revisions to
the FR 2314 in a separate notice. If these revisions are adopted, the Board expects to discontinue
the FR 2502q, effective as of June 30, 2024.

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16.

Provide information regarding plans for publication of data.

Aggregate data are published in the Federal Reserve Annual Report and the Department
of Commerce’s Annual Statistical Digest.
17.

If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
No such approval is sought.

18.

Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
There are no exceptions.

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