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pdfSupporting Statement for the
Financial Statements of Subsidiaries
(FR 2314, FR 2314S, FR Y-11, FR Y-11S, FR Y-7N, and FR Y-7NS; OMB No. 7100-0073)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years, with
revision, the Financial Statements of Subsidiaries (OMB No. 7100-0073). This information
collection comprises the following reports:
• Financial Statements of Foreign Subsidiaries of U.S. Banking Organizations (FR 2314),1
• Abbreviated Financial Statements of Foreign Subsidiaries of U.S. Banking
Organizations (FR 2314S),
• Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding
Companies (FR Y-11),
• Abbreviated Financial Statements of U.S. Nonbank Subsidiaries of U.S.
Holding Companies (FR Y-11S),
• Financial Statements of U.S. Nonbank Subsidiaries Held by Foreign Banking
Organizations (FR Y-7N), and
• Abbreviated Financial Statements of U.S. Nonbank Subsidiaries Held by
Foreign Banking Organizations (FR Y-7NS).
The FR 2314 reporting forms collect financial information for non-functionally regulated
direct or indirect foreign subsidiaries of U.S. state member banks (SMBs), Edge and agreement
corporations, and holding companies (i.e., bank holding companies, savings and loan holding
companies, securities holding companies, and intermediate holding companies) (collectively
U.S. Banking Organizations (USBOs)). Parent organizations (SMBs, Edge and agreement
corporations, or holding companies) file the FR 2314 on a quarterly or annual basis, or the
FR 2314S on an annual basis, predominantly based on whether the organization meets certain
asset size thresholds. The data from the FR 2314 forms are used to identify current and potential
problems at the foreign subsidiaries of U.S. parent companies, to monitor the activities of U.S.
banking organizations in specific countries, and to develop a better understanding of activities
within the industry, in general, and of individual institutions, in particular.
The FR Y-11 reporting forms collect financial information for individual nonfunctionally regulated U.S. nonbank subsidiaries of domestic holding companies (HCs), which is
essential for monitoring the subsidiaries’ potential impact on the condition of the HC or its
subsidiary banks. HCs file the FR Y-11 on a quarterly or annual basis, or the FR Y-11S on an
annual basis, predominantly based on whether the organization meets certain asset size
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As part of this clearance, the Board cleared the FR 2314, FR 2314S, FR Y-11, FR Y-11S, FR Y-7N, and
FR Y-7NS under the FR 2314 OMB control number 7100-0073. The FR Y-11 and FR Y-11S separate OMB control
number 7100-0244 will be discontinued. The FR Y-7N and FR Y-7NS rows will be removed from OMB control
number 7100-0125. This administrative change simplifies the tracking and clearance process for the six related
forms. This change would not modify the reporting or recordkeeping requirements described in this supporting
statement in any way. The information collection will be titled Financial Statements of Subsidiaries (FR 2314,
FR 2314S, FR Y-11, FR Y-11S, FR Y-7N, and FR Y-7NS; OMB No. 7100-0073).
thresholds. The data from the FR Y-11 forms are used with other holding company data to assess
the condition of HCs that are heavily engaged in nonbanking activities and to monitor the
volume, nature, and condition of their nonbanking operations.
The FR Y-7N and FR Y-7NS collect financial information for certain2 non-functionally
regulated U.S. nonbank subsidiaries held by foreign banking organizations (FBOs) other than
through a U.S. bank holding company, financial holding company (FHC), or U.S. bank. For
purposes of these reports, an FBO is a foreign bank that operates a branch, agency, or
commercial lending company subsidiary in the United States; controls a bank in the United
States; or controls an Edge corporation acquired after March 5, 1987.3 FBOs file the FR Y-7N
quarterly or annually or the FR Y-7NS annually, predominantly based on asset size thresholds.
The Board revised the FR 2314 and FR Y-11 forms and instructions to be consistent with
adopted changes to U.S. generally accepted accounting principles (GAAP) related to troubled
debt restructurings (TDRs), provisions for credit losses on off-balance sheet credit exposures,
and expected recoveries of amounts previously charged off included within the allowances for
credit losses. The Board revised the FR 2314 and FR Y-11 instructions by modifying and
clarifying the recordkeeping requirements related to the submitted form. These revisions will
take effect for the March 31, 2025, as of date.
Additionally, the Board incorporated 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
FR 2314. These revisions will take effect beginning with the March 31, 2025, as of date.
Lastly, the Board removed the Financial Statements of U.S. Nonbank Subsidiaries Held
by Foreign Banking Organizations (FR Y-7N) and Abbreviated Financial Statements of U.S.
Nonbank Subsidiaries Held by Foreign Banking Organizations (FR Y-7NS) from OMB No.
7100-0125. These reports have been moved to the OMB No. for the Financial Statement of
Foreign Subsidiaries of U.S. Banking Organizations, Financial Statement of U.S. Nonbank
Subsidiaries of U.S. Holding Companies (FR 2314, FR 2314S, FR Y-11, FR Y-11S; OMB No.
7100-0073). There are no revisions to the FR 2314S and FR Y-11S at this time.
The current estimated total annual burden for this information collection is 28,024 hours,
and would increase to 32,951 hours. The revisions resulted would result in an increase of 4,927
hours. The form and instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
The FR 2314 reports are the only source of comprehensive and systematic data on the
assets, liabilities, and earnings of the foreign nonbank subsidiaries of U.S. banking organizations
and the data are used to monitor the growth, profitability, and activities of these foreign
companies. The data help the Federal Reserve identify present and potential problems of these
Filing thresholds for each respective report are defined within the “Description of Information Collection” section
of this document.
3
12 CFR 211.21(o).
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companies, monitor their activities in specific countries, and develop a better understanding of
activities within the industry and within specific institutions. This information, coupled with
information from the Foreign Branch Reports of Condition (FFIEC 030; OMB No. 7100-0071),
provides a picture of the breadth and scope of international banking operations for U.S. holding
companies both individually and in the aggregate.
The FR Y-11 reports collect financial information for individual U.S. nonbank
subsidiaries of domestic HCs, which is essential for monitoring the subsidiaries’ potential impact
on the holding company or its subsidiary banks’ condition. Consolidated and parent company
only data do not reveal the extent of the problems that may exist within the nonbank subsidiaries
because the size and operations of bank subsidiaries can mask the operations of nonbank
subsidiaries in a consolidated report.
In addition to providing information used in the supervision of holding companies, the
FR Y-11 reports provide essential information to assist the Federal Reserve in the formulation of
regulations and supervisory policies. The data are also used by the Federal Reserve to respond to
requests from Congress and the public for information on holding companies.
The International Banking Act of 1978 (IBA) establishes a framework for federal
regulation of foreign banks operating in U.S. financial markets. Section 8(a) of the IBA states
that foreign banks that engage in banking in the United States through a U.S. branch, agency or
subsidiary commercial lending company and companies that control such foreign banks are
subject to the provisions of the Bank Holding Company Act of 1956 (BHC Act). The Federal
Reserve uses the data collected on the FR Y-7N and FR Y-7NS to assess an FBO’s ability to be a
continuing source of strength to its U.S. operations and to determine compliance with applicable
U.S. laws and regulations. This information is not available from other sources.
Description of Information Collection
The FR 2314 reports collect financial information for direct or indirect foreign
subsidiaries of USBOs. The FR 2314 consists of an income statement and balance sheet,
schedules that collect information on changes in equity capital, the allowance for loan and lease
losses, off-balance-sheet data items, loans, and a memoranda section. A USBO must file the
FR 2314 quarterly, as of the last calendar day of March, June, September, and December, for its
subsidiary if the subsidiary is owned or controlled by a parent U.S. holding company that has
total consolidated assets of $500 million or more as of June 30 of the preceding year; or if the
USBO files the Consolidated Financial Statements for Holding Companies (FR Y-9C; OMB No.
7100-0128) to meet supervisory needs; or if the subsidiary is owned or controlled by an SMB or
an Edge or agreement corporation that has total consolidated assets equal to or greater than $500
million, and the subsidiary has (1) total assets of $1 billion or more, (2) total off-balance-sheet
activities of at least $5 billion, (3) equity capital of at least 5 percent of the top-tier organization’s
consolidated equity capital, or (4) operating revenue of at least 5 percent of the top-tier
organization’s consolidated operating revenue. The FR 2314 is filed annually, as of December
31, for each individual subsidiary that does not meet the criteria for filing quarterly and that has
total assets of at least $500 million but less than $1 billion.
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The FR 2314S is an abbreviated reporting form that collects four data items: net income,
total assets, equity capital, and total off-balance-sheet data items. The FR 2314S is filed
annually, as of December 31, for each individual subsidiary (that does not meet the criteria for
filing the FR 2314) with total assets of at least $250 million but less than $500 million.
Domestic HCs file the FR Y-11 reports for their U.S. nonbank subsidiaries. The FR Y-11
consists of an income statement and balance sheet, schedules that collect information on changes
in equity capital, the allowance for loan and lease losses, off-balance-sheet data items, loans, and
a memoranda section. A top-tier HC must file the FR Y-11 quarterly for each nonbank subsidiary
that it owns and controls if the top-tier HC has total consolidated assets of $500 million or more
as of June 30 of the preceding year or files the FR Y-9C to meet supervisory needs and the
subsidiary meets any one of the following criteria: (1) total assets of $1 billion or more, (2) total
off-balance-sheet activities of at least $5 billion, (3) equity capital of at least 5 percent of the toptier holding company’s consolidated equity capital, or (4) operating revenue of at least 5 percent
of the top-tier HC’s consolidated operating revenue. The FR Y-11 is filed annually, as of
December 31, by top-tier holding companies for each individual nonbank subsidiary that does
not meet the criteria for filing quarterly and that has total assets of at least $500 million, but less
than $1 billion.
The FR Y-11S is an abbreviated reporting form that collects four data items: net income,
total assets, equity capital, and total off-balance-sheet data items. The FR Y-11S is filed
annually, as of December 31, by top-tier HCs for each individual nonbank subsidiary (that does
not meet the criteria for filing the FR Y-11) with total assets of at least $250 million, but less
than $500 million.
The FR Y-7N consists of an income statement and a balance sheet; schedules that collect
information on changes in equity capital, changes in the allowance for loan and lease losses, offbalance-sheet data items, and loans; and a memoranda section. All FBOs file the FR Y-7N
quarterly for their significant nonbank subsidiaries that do not have a primary U.S. regulator
other than the Federal Reserve System. FBOs must commence quarterly reporting for a
subsidiary at the end of the quarter in which the subsidiary meets the significance threshold, and
must continue to file quarterly for the remainder of a calendar year even if the subsidiary no
longer satisfies the size requirement for quarterly filing of the FR Y-7N. The FR Y-7N is filed
annually, as of December 31, for each individual nonbank subsidiary that does not meet the
criteria for filing quarterly and that has total assets of at least $500 million.
The FR Y-7NS is an abbreviated reporting form that collects net income, total assets,
equity capital, and total off-balance-sheet data items. The FR Y-7NS is filed annually, as of
December 31, by top-tier FBOs for each individual nonbank subsidiary that does not have a
primary U.S. regulator other than the Federal Reserve System (and does not meet the filing
criteria for filing the FR Y-7N) with total assets greater than or equal to $250 million.
Respondent Panel
USBOs file the FR 2314 and FR 2314S for their foreign subsidiaries. U.S. HCs file the
FR Y-11 and FR Y-11S for U.S. nonbank subsidiaries they own or control. The FR 2314S and
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FR Y-11S provide burden relief to smaller entities, as abbreviated reporting is permitted with
respect to entities with total assets of at least $250 million, but not greater than $500 million.
Top-tier FBOs file the FR Y-7N and FR Y-7NS for each U.S. nonbank subsidiary it owns or
controls.
Frequency and Time Schedule
The FR 2314 and FR Y-11 are filed quarterly and annually. The FR 2314S and FR Y-11S
are filed annually. HCs are required to file the quarterly FR 2314 and FR Y-11 as of the end of
March, June, September, and December, and must submit them within sixty days after the as of
date. The annual FR 2314 and FR Y-11, FR 2314S, and FR Y-11S are filed as of December 31
and are also submitted within sixty days after the as of date. FBOs are required to file the
FR Y-7N (quarterly or annually) and FR Y-7NS (annually) reports 60 calendar days after the
report date.
Proposed Revisions to the FR 2314 and FR Y-11
Provisions for Credit Losses on Off-Balance-Sheet Credit Exposures
On June 16, 2016, the Financial Accounting Standards Board (FASB) issued Accounting
Standards Update (ASU) 2016-13, Topic 326, “Financial Instruments – Credit Losses” (ASU
2016-13). Within Topic 326, paragraph 326-20-30-11 states: “[a]n entity shall report in net
income (as a credit loss expense) the amount necessary to adjust the liability for credit losses for
management’s current estimate of expected credit losses on off-balance-sheet credit exposures.”
Off-balance-sheet credit exposures include loan commitments, standby letters of credit, and
financial guarantees not accounted for as insurance, and other similar instruments except for
those within the scope of Accounting Standards Codification (ASC) Topic 815 on derivatives
and hedging.
Throughout Topic 326, the FASB refers to provisions for credit losses as “credit loss
expense.” For example, paragraph 326-20-30-1 states: “[a]n entity shall report in net income (as
a credit loss expense) the amount necessary to adjust the allowance for credit losses (ACL) for
management’s current estimate of expected credit losses on financial assets”. Thus, Topic 326
does not prohibit recording the adjustment to the liability for expected credit losses on offbalance-sheet credit exposures within the provisions for credit losses reported in the income
statement.
To align with GAAP, the Board has revised the FR 2314 and FR Y-11 instructions to
direct USBOs and holding companies to report provisions for expected credit losses on offbalance-sheet credit exposures as part of the total amount of provisions for credit losses in
Schedule IS, Income Statement, item 4, with respect to their foreign subsidiaries and U.S.
nonbank subsidiaries, respectively. The inclusion of provisions for expected credit losses on offbalance-sheet credit exposures in the provisions for credit losses presented in Schedule IS,
item 4, would cause a loss of transparency within the overall reported amount of provisions for
credit losses between provisions attributable to on- and off-balance-sheet credit exposures. To
enhance transparency and differentiate these provisions, the Board added Memorandum item 3,
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“Provisions for credit losses on off-balance-sheet credit exposures,” to Schedule IS-B, “Changes
in Allowances for Credit Losses,” which would identify the portion of the overall amount of the
provisions for credit losses reported in Schedule IS, item 4, attributable to the provisions for
expected credit losses on off-balance-sheet credit exposures.
In addition, the Board revised footnote 3 on Schedule IS-B, item 4, “Provisions for credit
losses,” of the FR 2314 and FR Y-11 reporting form to reflect that the sum of item 4, Column A
through Column C, plus Schedule IS-B, Memorandum items 1 and 3 must equal Schedule IS,
item 4.” These revisions to the FR 2314 and FR Y-11 will be effective as of March 31, 2025, and
would be consistent with revisions adopted4 for the Consolidated Financial Statements for
Holding Companies (FR Y-9C, OMB No. 7100-0128).
Expected Recoveries of Amounts Previously Charged Off Included within the Allowances
for Credit Losses
Within Topic 326, paragraph 326-20-30-1 states: “[t]he [ACL] is a valuation account that
is deducted from, or added to, the amortized cost basis of the financial asset(s) to present the net
amount expected to be collected on the financial asset. Expected recoveries of amounts
previously written off and expected to be written off shall be included in the valuation account
and shall not exceed the aggregate of amounts previously written off and expected to be written
off by an entity.” The terms “written off,” as used in Topic 326, and “charged off,” as used in the
FR 2314 and FR Y-11 instructions, are used interchangeably in this discussion.
Under GAAP, before an institution’s adoption of Topic 326, expected recoveries of
amounts previously written off would not be included in the measurement of the allowance for
loan and lease losses; recoveries would be recorded only when received. Under Topic 326,
including expected recoveries of amounts previously written off within allowances for credit
losses reduces the overall amount of these allowances. Amounts related to an individual asset are
written off or charged off when deemed uncollectible. However, under Topic 326, institutions
can, in some circumstances, reduce the amount of the ACL that would otherwise be calculated
for a pool of assets with similar risk characteristics that includes charged-off assets on the same
day the charge-offs were taken by the estimated amount of expected recoveries of amounts
written off on these assets. Reducing the ACL by amounts of expected recoveries prior to
collection effectively “reverses” a charge-off.
Therefore, to align with GAAP and provide transparency for expected recoveries of
amounts with inherently higher risk, the Board has added new line item, Memorandum item 4 to
Schedule IS-B, “Changes in Allowances for Credit Losses,” to capture the “Estimated amount of
expected recoveries of amounts previously written off included within the ACL on loans and
leases held for investment (included in item 6, column A, ‘Balance end of current period,’
above).” These revisions to the FR 2314 and FR Y-11 would be effective as of March 31, 2025,
and would be consistent with revisions adopted5 for the FR Y-9C.
4
5
See 86 FR 92 (January 4, 2021).
See 86 FR 92 (January 4, 2021).
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Troubled Debt Restructurings and Vintage Disclosures
On March 31, 2022, the FASB issued ASU 2022-02, “Financial Instruments – Credit
Losses (Topic 326): Troubled Debt Restructurings and Vintage Disclosures” (ASU 2022-02),
which eliminates the TDR recognition and measurement guidance for entities that have adopted6
ASU 2016-13. Instead of identifying and accounting for TDRs separately from other loan
modifications, all loans modified from the beginning of the fiscal year in which the new standard
is adopted by a holding company would be accounted for in accordance with ASC 310-20-35,
“Receivables–Nonrefundable Fees and Other Costs – Subsequent Measurement”, as amended by
ASU 2022-02. In addition, the new standard enhances financial statement disclosure
requirements for certain loan modifications to borrowers experiencing financial difficulty. These
disclosures include qualitative information regarding how initial modifications and subsequent
performance of such modifications impact the allowance for credit losses.
Under ASU 2022-02, USBOs and HCs would only include loans that were modified to
borrowers experiencing financial difficulty from the beginning of the fiscal year of adoption and
in subsequent periods in their disclosures for financial statement purposes. TDRs or
modifications made prior to the beginning of the fiscal year of adoption would not be included in
these enhanced financial statement disclosures in the period of adoption or in any subsequent
periods. Additionally, per ASU 2022-02, USBOs and HCs would not be required to use a
discounted cash flow (DCF) approach to measure the allowance for credit loss on the modified
loans. However, if a USBO or HC chooses to use a DCF approach, it would be required to use
the post-modification expected interest rate to discount expected cash flows. Per ASC 326-2035-5, “Investments – Financial Instruments-Credit Losses – Measured at Amortized Cost –
Subsequent Measurement,” modified loans for which repayment is expected to be provided
substantially through the operation or sale of the collateral when the borrower is experiencing
financial difficulty would still be considered to be collateral-dependent. For regulatory reporting
purposes, the allowance for credit losses for a collateral-dependent loan would continue to be
measured using the fair value of collateral (less cost to sell, when appropriate), regardless of
whether foreclosure is probable.
ASU 2022-02 was effective for all USBOs and HCs, as of December 31, 2023, and
eliminates the recognition and measurement accounting guidance for TDRs. USBOs and HCs,
with respect to their foreign and U.S nonbank subsidiaries, should no longer report TDRs on
Schedule BS-A, Loans and Lease Financing Receivable. To be consistent with GAAP
recognition and disclosure requirements, the Board has revised the FR 2314 and FR Y-11 form
and instructions to align with the definition of loan modifications to borrowers experiencing
financial difficulty. Specifically, the Board is has replaced, as appropriate, references to
“troubled debt restructurings” with “modifications to borrowers experiencing financial
difficulty” in the FR 2314 and FR Y-11 forms and instructions. These changes would enable the
Board to better understand the level of loan modification activity at holding companies. The
Board would benefit from having reliable data about modification activity that is captured
outside of the on-site examination process. This data would provide the Board with information
to assess the loan quality and performance of modified loans.
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ASU 2016-13 was effective for all USBOs and HCs as of December 31, 2023.
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The Board has revised the FR 2314 and FR Y-11 reporting form and instructions as
discussed in detail below:
Schedule BS-A, Loans and Lease Financing Receivables, item 7.d – USBOs and
holding companies, with respect to their foreign and U.S nonbank subsidiaries, would
continue to report detail on loan modifications to borrowers experiencing financial
difficulty in Schedule BS-A, Loan and Lease Financing Receivables, item 7.d on the
FR 2314 and FR Y-11. The modifications reported in item 7.d would need to meet the
definition of “loan modifications to borrowers experiencing financial difficulty” as
described in ASU 2022-02, which includes only those modifications which occurred in
the previous 12 months.7 Loan modifications to borrowers experiencing financial
difficulty include financing receivables that had been modified in the form of principal
forgiveness, an interest rate reduction, an other-than-insignificant payment delay or a
term extension (or a combination thereof). The FR 2314 and FR Y-11 forms and
instructions would be updated to include references to “loan modifications to borrowers
experiencing financial difficulty” and remove references to the TDR framework.
These items added to the FR 2314 and FR Y-11 would be effective as of March 31, 2025,
and are consistent with items currently to be added to the FR Y-9C.8
Incorporate line items from the FR 2502q into the FR 2314
The FR 2502q collects data on the claims and liabilities with U.S.-resident and foreignresident 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.9 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, along with other Federal government
data users, such as the Bureau of Economic Analysis (BEA), a bureau of the Department of
Commerce, have 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
ASU 2022-02 requires disclosures on modifications to borrowers experiencing financial difficulty made “within
the previous 12 months preceding the payment default when the debtor was experiencing financial difficulty at the
time of the modification”. See ASC 310-10-50-44, “Receivables – Overall – Disclosure – Modifications to Debtors
Experiencing Financial Difficulty.”
8
See 89 FR 90284 (November 15, 2024).
9
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.
7
8
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. In addition, the BEA uses
FR 2502q data from the Memoranda section on branches of U.S. banks in its estimates of the
U.S. International Transactions Accounts and the International Investment Position.
Following a 2015 revision that substantially reduced the size of the FR 2502q report, the
Board has assessed its use of the remaining 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. The Board has added a new schedule with six
new line items to the FR 2314 to collect the information currently collected by the FR 2502q.
The title of the new schedule would be: “Schedule BS-Q, Due From, Due To, and Other.
Four of the new line items would provide a granular breakout of what is currently
collected on Schedule BS, Balance Sheet, line items 9 and 16. Two of the new line items would
be new to the FR 2314 information collection. Specifically, the Board has included the following
line items in the new Schedule BS-Q, Due From, Due To, and Other:
Item 1a: Balances due from related institutions in the U.S.,
Item 1b: Balances due from related institutions in foreign countries,
Item 2a: Balances due to related institutions in the U.S.,
Item 2b: Balances due to related institutions in foreign countries,
Item 3: Assets that are claims on U.S. addressees other than depository institutions, and
Item 4: Liabilities to U.S. addressees other than depository institutions.
The Board, Office of the Comptroller, and Federal Deposit Insurance Corporation
proposed similar revisions to the FFIEC 030 in a separate notice.10 The Board expects to
discontinue the FR 2502q effective as of March 31, 2025.
Clarification of Recordkeeping Requirements
The Board also modified and clarified the FR 2314 and FR Y-11 instructions to require
paper and electronic filers to maintain in their files a physical or electronic scanned copy of the
manually signed and attested FR 2314 and FR Y-11 submissions for a period of three years after
submission. Currently, the instructions for the FR 2314 and FR Y-11 require respondents to
maintain these records but do not specify the duration of the recordkeeping requirement. The
three-year retention period is consistent with requirements for many other Board reports and is
an appropriate time to ensure that examiners have access to the records during the period in
which most issues regarding the reported information would likely arise.
Reassigning FR Y-7N and FR Y-7NS to OMB No.7100-0073
In 2002, the Federal Reserve revised the FR Y-7 and implemented the FR Y-7N,
FR Y-7NS, and FR Y-7Q. Revisions to the FR Y-7 included: moving the risk-based capital
reporting requirement to the FR Y-7Q and moving the data from U.S. nonbank subsidiaries held
directly by a foreign parent to the FR Y-7N or FR Y-7NS. Currently, the FR Y-7N, FR Y-7NS,
10
See 89 FR 3708 (January 19, 2024).
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and FR Y-7Q share the same OMB Control Number (7100-0125). However, the FR Y-7N,
FR Y-7NS, and FR Y-7Q have been extended with revision in unison, only 1 out of 12 proposals
in the past 10 years. Typically, the FR Y-7N and FR Y-7NS are revised in tandem with the
FR 2314 and FR Y-11 reports due to these reports collecting similar data, but from different
respondents. Past proposed revisions to the FR Y-7Q typically only impacted the FR Y-7Q since
there is not any similarity in the line items of the FR Y-7N and FR Y-7NS.
Therefore, following the completion of this clearance, forms FR Y-7N and FR Y-7NS
will be reassigned to the OMB Control Number (7100-0073) for the FR 2314 and FR Y-11
reports. The FR Y-7Q will continue using its current OMB Control Number (7100-0125).
Splitting the FR Y-7N and FR Y-7NS reports from the FR Y-7Q will assist the Board in being
more efficient with clearing these information collections.
Public Availability of Data
The data from these reports are not published routinely.
Legal Status
The revisions to the FR 2314 and FR Y-11 series of reports do not implicate the existing
legal authority to collect the relevant information. With respect to relevant holding companies,
the FR 2314 and FR Y 11 series of reports are both authorized pursuant to section 5(c) of the
BHC Act (12 U.S.C. § 1844(c)) (BHCs and IHCs), section 10(b)(2) of the Homeowners’ Loan
Act (12 U.S.C. § 1467a(b)(2)) (SLHCs), section 165 of the Dodd-Frank Wall Street Reform and
Consumer Protection Act (Dodd-Frank Act) (12 U.S.C. § 5365) (IHCs), and section 618 of the
Dodd-Frank Act (12 U.S.C. § 1850a) (securities holding companies). With respect to nonfunctionally regulated direct or indirect foreign subsidiaries of U.S. SMBs and Edge and
agreement corporations, the FR 2314 series of reports is authorized by sections 9(6), 25(7), and
25A(17) of the Federal Reserve Act, respectively (12 U.S.C. §§ 324, 602, and 625). The
obligation of covered institutions to report financial information through the FR 2314 and
FR Y-11 series of reports is mandatory.
The FR Y-7N and FR Y-7NS are authorized by the BHC Act (12 U.S.C. § 1844(c)) and
IBA (12 U.S.C. §§ 3105(c), 3106(c), and 3108). The FR Y-7N and FR Y-7NS are additionally
authorized by section 165 of the Dodd-Frank Act (12 U.S.C. § 5365). The FR Y-7N and
FR Y-7NS and are mandatory
The information collected through the FR 2314 and FR Y-11 series of reports is generally
not considered confidential. However, to the extent particular data submitted by a covered
institution is used by the Board to make discrete examination or other supervisory findings, such
implicated data may be exempt from disclosure pursuant to exemption 8 of Freedom of
Information Act (FOIA) (5 U.S.C. § 552(b)(8)). Additionally, to the extent that such information
constitutes nonpublic commercial or financial information, which is both customarily and
actually treated as private by the covered institution, the covered institution may request
confidential treatment pursuant to exemption 4 of FOIA (5 U.S.C. § 552(b)(4)). Finally, to the
extent that such information constitutes private, personal information, the covered institution
10
may request confidential treatment on behalf of affected personnel pursuant to exemption 6 of
FOIA, which covers personal information “the disclosure of which would constitute a clearly
unwarranted invasion of personal privacy” (5 U.S.C. § 552(b)(6)). Application of any of these
FOIA exemptions would be done on a case-by-case basis depending on the particular
circumstances.
The information contained on the FR Y-7N and FR Y-7NS is generally not considered
confidential unless an applicant requests confidential treatment in accordance with the Board’s
Rules Regarding Availability of Information.11 Requests for confidential treatment of
information are reviewed on a case-by-case basis. Information provided on the FR Y-7N and
FR Y-7NS may be exempt from disclosure pursuant to exemption 4 of the FOIA if it is
commercial or financial information that is customarily and actually treated as private by the
respondent (5 U.S.C. § 552(b)(4)). Submissions of the FR Y-7N and FR Y-7NS may also
contain personnel and medical files the disclosure of which would constitute an unwarranted
invasion of personal privacy of individuals involved, which are protected under exemption 6 of
the FOIA (5 U.S.C. § 552(b)(6)); or information contained in or related to examination,
operating, or condition reports prepared by, on behalf of, or for the use of an agency responsible
for the regulation or supervision of financial institutions, which are protected under exemption 8
of the FOIA (5 U.S.C. § 552(b)(8)).
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On June 7, 2024, the Board published an initial notice in the Federal Register (89 FR
48639) requesting public comment for 60 days on the extension, with revision, of the FR 2314
and FR Y-11. The comment period for this notice expired on August 6, 2024. Board received
one comment letter on the FR 2314 and FR Y-11 notice. Additionally, the Board did receive one
comment regarding the Foreign Branch Report of Condition (FFIEC 030 and FFIEC 030S),
however, the comment is not related to these collections. After considering the comments
received, the Board is proceeding with the revisions to the FR 2314, FR Y-11, FR Y-7N, and
FR Y-7NS as proposed, but with certain modifications. There are no changes to the FR 2314S
and FR Y-11S. The specific comments, the Board’s responses, and pertinent modifications
follow. On February 5, 2025, the Board published a final notice in the Federal Register (90 FR
9027).
Detailed Discussion of Public Comments
ASU 2022-02, “Financial Instruments-Credit Losses (Topic): Troubled Debt
Restructurings and Vintage Disclosures”
The commenter is supportive of the proposed revisions to align the regulatory reporting
of loan modifications to borrowers experiencing financial difficulty (LMBEFD) on the FR 2314,
11
12 CFR 261.17.
11
FR Y-11, and FR Y-7N in accordance with ASU 2022-02. The commenter specifically
commended the Board for properly aligning the reporting standard to U.S. GAAP and current
firm practices, which will allow for the collection of relevant information without undue
regulatory reporting burden to institutions. The commenter also encouraged the Board to
implement ASU 2022-02 across all regulatory reporting forms, including the Consolidated
Reports of Condition and Income (Call Reports) (FFIEC 031, FFIEC 041, and FFIEC 051; OMB
No. 7100-0036). In response, the Board is proceeding with these revisions as proposed to the
FR 2314, FR Y-11, and FR Y-7N. The Board recently published in the Federal Register, a
notice12 to implement similar changes to the FR Y-9C, FR Y-9LP and FR 2886b. With regard to
aligning the reporting of LMBEFD in accordance with ASU 2022-02 on the Call Report, the
Office of the Comptroller of the Currency (OCC), Treasury; Federal Deposit Insurance
Corporation (FDIC); and Board (collectively, the agencies) are continuing to evaluate the
comments on their September 2023 proposal.13 Upon conclusion of their review, the agencies
will adopt a standard through a subsequent Paperwork Reduction Act (PRA) notice with a 30day public comment period.
Incorporate line items from the FR 2502q into the FR 2314
The commenter is supportive of incorporating line items from the FR 2502q into the
FR 2314. However, the commenter requested the Board to modify certain aspects of the
proposal. First, the commenter urged the Board to limit the scope of respondents subject to the
proposed Schedule BS-Q, “Due From, Due To, and Other” 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 FR 2314. The FR 2502q reporting is limited to branches and foreign
subsidiaries with total assets of $2 billion or more and that are located in the United Kingdom
(U.K.) or the Caribbean. The FR 2314 quarterly instructions state that a U.S. Banking
Organization (USBO) must file the report quarterly for its foreign subsidiary if the parent U.S.
holding company has total consolidated assets of $500 million or more or files the FR Y-9C, or
the subsidiary is owned or controlled by a state member bank or an Edge or agreement
corporation that has total consolidated assets equal to or greater than $500 million, and the
subsidiary meets any one of several criteria14. The commenter stated that the FR 2314’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. This reporting burden would be greatest on respondents that
12
See 89 FR 80244 (October 2, 2024)
See 88 FR 66933 (September 28, 2023).
14
A USBO must file the FR 2314 quarterly for its foreign subsidiary if the parent U.S. holding company has total
consolidated assets of $500 million or more or files the FR Y-9C, or the subsidiary is owned or controlled by a state
member bank or an Edge or agreement corporation that has total consolidated assets equal to or greater than $500
million, and the subsidiary meets any one of the following criteria: (1) total assets of the foreign subsidiary are equal
to or greater than $1 billion, (2) the foreign subsidiary’s off-balance-sheet activities are equal to or greater than $5
billion, (3) the foreign subsidiary’s equity capital is equal to or greater than 5 percent of the top-tier organization’s
consolidated equity capital, or (4) the foreign subsidiary’s operating revenue is equal to or greater than 5 percent of
the top-tier organization’s consolidated operating revenue.
13
12
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 FR 2314
Schedule BS-Q 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 Board agrees with the commenter that broadening the criteria for reporting the
proposed FR 2314 Schedule BS-Q beyond the current reporting criteria for the FR 2502q may
impose additional burden on FR 2314 respondents. The draft notice would align the requirement
to report the new items on the FR 2314 Schedule BS-Q with the current reporting requirements
of the FR 2502q. Foreign subsidiaries that file the FR 2314 on an annual basis would not report
the new items. The FR 2314 instructions would be updated to reflect the approved changes.
Substantially restricting the scope of institutions required to complete Schedule BS-Q should
additionally limit the burden incurred due to system revisions necessary to implement the
revisions. Although the proposed line items would be new on the FR 2314, there would be fewer
items reported and they would be at the same level of granularity as currently reported on the
FR 2502q. However, the Board acknowledges that U.S. HCs and their foreign subsidiaries may
need additional time initially to develop their reporting systems to implement these changes. As
such, the Board will delay the requirement to complete Schedule BS-Q until March 31, 2025.
Other Comments Received
The commenter noted that the notice proposes to revise the instructions of FR 2314 and
FR Y-11, Schedule IS, line item 4, “Provision for Credit Losses”, to instruct respondents to
include provisions for credit losses on all financial assets and off-balance-sheet credit exposures.
The commenter stated that, despite this proposed revision, contradictory language stating to
“exclude provision for credit losses on off-balance-sheet credit exposures and provisions for
allocated transfer risk, both of which should be reported in Schedule IS, line item 7, “Noninterest
expense” remains in the current instructions of Schedule IS, line item 4, “Provisions for Credit
Losses”. The commenter also noted that the current instructions of Schedule IS line item 7(a),
“Pertaining to nonrelated organizations”, states to “report any provision for credit losses related
to off-balance sheet credit exposures”.
Therefore, the commenter requested the Board to clarify and remove the requirement to
exclude the provision for credit losses on off-balance sheet credit exposures from Schedule IS,
line item 4, “Provisions for Credit Losses” and instead report on line item 7, “Noninterest
expense”. In response to the commenter, the Board explicitly notes that provisions for credit
losses on off-balance sheet and provisions for allocated transfer risk should be reflected in
FR 2314 and FR Y-11 Schedule IS, item 4, “Provisions for Credit Losses” and excluded from
Schedule IS item 7, “Noninterest expense”. This clarification is also applicable to FR Y-7N
Schedule IS, items 4, “Provisions for Credit Losses” and 7, “Noninterest expense”. Therefore,
the Board will update the instructions of FR 2314, FR Y-7N, and FR Y-11 Schedule IS items 4,
“Provisions for Credit Losses” and 7, “Noninterest expense” accordingly.
13
The commenter seeks clarification on the treatment of proposed FR 2314 Schedule BS-Q
line items 3, “Assets that are claims on U.S. addressees other than depository institutions” and 4,
“Liabilities to U.S. addressees other than depository institutions”. The instructions of proposed
Schedule BS-Q state to exclude balances with related institutions from line items 3, “Assets that
are claims on U.S. addressees other than depository institutions” and 4, “Liabilities to U.S.
addressees other than depository institutions”, while BS-Q, line items 1, “Balances due from
related institutions, gross” and 2, “Balances due to related institutions, gross” represent balances
due from and due to related institutions, gross as stated in the line item caption name. The
commenter requested that Board revise the instructions to explicitly clarify that these balances
reported in Schedule BS-Q line items 1, “Balances due from related institutions, gross” and 2,
“Balances due to related institutions, gross” should be excluded when reporting the balances in
line items 3, “Assets that are claims on U.S. addressees other than depository institutions” and 4,
“Liabilities to U.S. addressees other than depository institutions”. In response, the Board will
revise the instructions accordingly to explicitly clarify that balances with related institutions are
excluded from BS-Q, line items 3, “Assets that are claims on U.S. addressees other than
depository institutions” and 4, “Liabilities to U.S. addressees other than depository institutions”.
The commenter also stated that proposed revisions to the draft report forms of FR 2314
and FR Y-11, Schedule IS-B, Memoranda items M3 and M4 contain a reference to a footnote 6
following the name of the line items. However, there is no visible citation to footnote 6 on the
draft report form. The commenter requested that footnote 6 be added and after release,
respondents should have an opportunity to ask any relevant questions or comments on this item.
In response to the commenter, Schedule IS-B, Memoranda items M3 and M4 should not
reference footnote 6 following the name of the line items on the respective report forms.
Therefore, the report forms will be updated accordingly to no longer reference footnote 6.
Lastly, the commenter requested clarity regarding what is meant by the statement that six
line items from the FR 2502q would be incorporated into the proposed FR 2314 Schedule BS-Q,
when it appears that only one line item is included. The commenter stated that, although there are
six line items on the proposed FR 2314 Schedule BS-Q, only line items 3 and 4, which break out
FR 2502q line item 1.c. are from the FR 2502q. In response to the commenter, the Board
acknowledges that not all six line items that were proposed to be incorporated into the FR 2314
are explicitly from the FR 2502q. However, the intent of these new line items is to allow for the
discontinuation of the FR 2502q and to support the supervisory data needs of the FR 2502q data
users.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 2314,
FR 2314S, FR Y-11, FR Y-11S, and FR Y-7N, FR Y-7NS reports is 28,024 hours, and would
increase to 32,951 hours with the revisions. The estimated number of quarterly FR 2314 and
FR Y-11 respondents is based on data submitted for the June 30, 2023, as of date. The estimated
number of annual FR 2314, FR 2314S, FR Y-11, and FR Y-11S respondents is based on data
submitted for the December 31, 2022, as of date. The estimated number of quarterly FR Y-7N
respondents is based on data submitted for the June 30, 2023, as of date. The estimated number
of annual FR Y-7N and FR Y-7NS respondents is based on data submitted for the December 31,
14
2022, as of date. The revisions to the FR Y-7N and FR Y-7NS forms are described in the
supporting statement for the FR Y-7Q OMB No. (7100-0125). The FR Y-7N and FR Y-7NS
burden has been removed from that supporting statement and included in the table below. These
reporting and recordkeeping requirements represent less than 1 percent of the Board’s total
paperwork burden.
FR 2314, FR 2314S,
FR Y-11, FR Y-11S,
FR Y-7N, FR Y-7NS
Current
Reporting
FR 2314 (quarterly)
Estimated
Estimated
Estimated
number of
annual
average hours
respondents15 frequency per response
Estimated
annual burden
hours
434
4
7.2
12,499
223
295
386
211
286
1
1
4
1
1
7.2
1
7.6
7.6
1
1,606
295
11,734
1,604
286
28,024
434
4
8.1
14,062
FR 2314 (annual)
FR 2314S
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S
FR Y-7N (quarterly)
FR Y-7N (annual)
FR Y-7NS
Recordkeeping
FR 2314 (quarterly)
223
295
386
211
286
29
14
13
1
1
4
1
1
4
1
1
7.9
1
8.3
8.3
1
8.3
8.3
1
1,762
295
12,815
1,751
286
963
116
13
434
4
0.2
347
FR 2314 (annual)
FR 2314S
223
295
1
1
0.2
0.2
45
59
FR 2314 (annual)
FR 2314S
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S
Current Total
Proposed
Reporting
FR 2314 (quarterly)
15
Of these respondents, 45 FR 2314 (quarterly), 152 FR 2314 (annual), 295 FR 2314S, 82 FR Y-11 (quarterly), 162
FR Y-11 (annual), 286 FR Y-11S, 0 FR Y-7N (quarterly), 12 FR Y-7N (annual), and 13 FR Y-7NS 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.
15
FR Y-11 (quarterly)
FR Y-11 (annual)
FR Y-11S
FR Y-7N (quarterly)
FR Y-7N (annual)
FR Y-7NS
Proposed Total
386
211
286
29
14
13
4
1
1
4
1
1
Change
0.2
0.2
0.2
0.2
0.2
0.2
309
42
57
23
3
3
32,951
4,927
The estimated total annual cost to the public for this information collection is $1,957,476,
and would increase to $2,301,627 with the revisions.16
Sensitive Questions
This information collection 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 for collecting and processing these
reports is $203,300.
16
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/.
16
| File Type | application/pdf |
| File Modified | 2025-03-13 |
| File Created | 2025-03-13 |