Agency Information Collection Activities: Announcement of Board Approval under Delegated Authority and Submission to OMB, 70529-70540 [2019-27655]
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Federal Register / Vol. 84, No. 246 / Monday, December 23, 2019 / Notices
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collections of information conducted or
sponsored by the Board. Boardapproved collections of information are
incorporated into the official OMB
inventory of currently approved
collections of information. Copies of the
PRA Submission, supporting
statements, and approved collection of
information instrument(s) are placed
into OMB’s public docket files.
Final Approval under OMB Delegated
Authority of the Extension for Three
Years, Without Revision, the Following
Information Collection:
Report title: Savings Association
Holding Company Report.
Agency form number: FR LL–(b)11.1
OMB control number: 7100–0334.
Frequency: Quarterly,2 annually, and
event-generated.
Respondents: Certain savings and
loan holding companies (SLHCs).
Estimated number of respondents:
Quarterly: 6; annually: 6; eventgenerated: 1.
Estimated average hours per response:
Quarterly: 2; annually: 2; eventgenerated: 2.
Estimated annual burden hours:
Quarterly: 36; annually: 12; eventgenerated: 2.
General description of report: Title III
of the Dodd-Frank Wall Street Reform
and Consumer Protection Act
transferred to the Board the supervisory
functions of the former Office of Thrift
Supervision related to SLHCs and their
non-depository subsidiaries. Pursuant to
section 10(b) the Home Owners’ Loan
Act (HOLA), the Board may require
SLHCs to file reports concerning their
operations. Following the transfer to the
Board of authority to supervise SLHCs,
the Board determined to exempt certain
SLHCs (known as ‘‘exempt SLHCs’’)
from regulatory reporting using the
Board’s existing regulatory reports,
including the Consolidated Financial
Statements for Holding Companies (FR
Y–9C; OMB No. 7100–0128) and the
Parent Company Only Financial
Statements for Small Holding
Companies (FR Y–9SP; OMB No. 7100–
0128). Exempt SLHCs must file the FR
LL–(b)11 quarterly report in order for
the Board to obtain the information that
is necessary to supervise such SLHCs,
monitor their financial condition, and
assess their regulatory compliance. An
SLHC is exempt from filing the FR Y–
1 The internal Agency Tracking Number
previously assigned by the Board to this
information collection was ‘‘FR H–(b)11.’’ The
Board is changing the internal Agency Tracking
Number to ‘‘FR LL–(b)11’’ for the purpose of
consistency.
2 The FR LL–(b)11 is filed quarterly except for the
fourth quarter when the respondent is required to
file its annual report.
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9C or FR Y–9SP if it: (1) Meets the
requirements of section 10(c)(9)(C) of
HOLA (i.e., a ‘‘grandfathered’’ unitary
SLHC) and has primarily commercial
assets, with thrift assets making up less
than 5 percent of the SLHC’s
consolidated assets;3 or (2) primarily
holds insurance-related assets and does
not otherwise submit financial reports
with the U.S. Securities and Exchange
Commission pursuant to sections 13 or
15(d) of the Securities Exchange Act of
1934.
The FR LL–(b)11 collects the
following six categories of information:
(1) Information about U.S. Securities
and Exchange Commission filings;
(2) Reports provided by Nationally
Recognized Statistical Rating
Organizations and Securities Analysts;
(3) Supplemental information for the
Quarterly Savings and Loan Holding
Company Report (FR 2320; OMB No.
7100–0345);
(4) Information about other materially
important events;
(5) Financial statements; and
(6) Other exhibits required by the
Board.
Legal authorization and
confidentiality: The FR LL–10(b)11 is
authorized pursuant to section 10 of the
Home Owners’ Loan Act, which
requires SLHCs to file ‘‘such reports as
may be required by the Board.’’ 4 The FR
LL–(b)11 is mandatory.
Information provided through the FR
LL- (b)11 that corresponds to a ‘‘yes’’
answer to questions 24, 25, and 26 of
the FR 2320 is generally considered to
be confidential under exemption 4 of
the Freedom of Information Act (FOIA),
which protects privileged or
confidential commercial or financial
information.5 If it should be determined
subsequently that any information
collected on these three items must be
released, respondents will be notified.
Individual respondents may request that
other information submitted to the
Board through the FR LL–(b)11 be kept
confidential, and the Board will
determine whether the information is
entitled to confidential treatment on a
case-by-case basis. Information may be
3 Specifically, a grandfathered unitary SLHC is
exempt if (1) as calculated annually as of June 30th,
using the four previous quarters (which includes
the quarter-ended June 30th reporting period), its
savings association subsidiaries’ consolidated assets
make up less than 5 percent of the total
consolidated assets of the grandfathered SLHC on
an enterprise-wide basis for any of these four
quarters; and (2) as calculated annually as of June
30th, using the assets reported as of June 30th,
where more than 50 percent of the assets of the
grandfathered unitary SLHC are derived from
activities that are not otherwise permissible under
HOLA on an enterprise-wide basis.
4 12 U.S.C. 1467a(b)(2)(A).
5 5 U.S.C. 552(b)(4).
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kept confidential under FOIA
exemption 4 or exemption 8, which
exempts from disclosure information
‘‘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.’’ 6
Current actions: On September 10,
2019, the Board published an initial
notice in the Federal Register (84 FR
47514) requesting public comment for
60 days on the extension, without
revision, of the FR LL–(b)11. The
comment period for this notice expired
on November 12, 2019. The Board did
not receive any comments.
Board of Governors of the Federal Reserve
System, December 17, 2019.
Michele Taylor Fennell,
Assistant Secretary of the Board.
[FR Doc. 2019–27599 Filed 12–20–19; 8:45 am]
BILLING CODE 6210–01–P
FEDERAL RESERVE SYSTEM
Agency Information Collection
Activities: Announcement of Board
Approval under Delegated Authority
and Submission to OMB
Board of Governors of the
Federal Reserve System.
ACTION: Approval of Information
Collection.
AGENCY:
The Board of Governors of the
Federal Reserve System (Board) is
adopting two proposals to extend for
three years, with revision, the Capital
Assessments and Stress Testing Reports
(FR Y–14A/Q/M; OMB No. 7100–0341).
The revisions are applicable with as of
dates ranging from December 31, 2019,
to December 31, 2020. This final notice
is adopting two proposals previously
published separately: One proposing to
incorporate current expected credit loss
(CECL) methodology revisions into the
FR Y–14A/Q/M reports (CECL
proposal), and the other proposal to
incorporate non-CECL methodology
revisions into the FR Y–14A/Q/M
reports (non-CECL proposal).
FOR FURTHER INFORMATION CONTACT:
Federal Reserve Board Clearance
Officer—Nuha Elmaghrabi—Office of
the Chief Data Officer, Board of
Governors of the Federal Reserve
System, Washington, DC 20551, (202)
452–3829.
Office of Management and Budget
(OMB) Desk Officer—Shagufta Ahmed—
Office of Information and Regulatory
Affairs, Office of Management and
Budget, New Executive Office Building,
SUMMARY:
65
U.S.C. 552(b)(4) and (8).
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Room 10235, 725 17th Street, NW,
Washington, DC 20503, or by fax to
(202) 395–6974.
A copy of the Paperwork Reduction
Act (PRA) OMB submission, including
the reporting form and instructions,
supporting statement, and other
documentation will be placed into
OMB’s public docket files. These
documents also are available on the
Federal Reserve Board’s public website
at https://www.federalreserve.gov/apps/
reportforms/review.aspx or may be
requested from the agency clearance
officer, whose name appears above.
SUPPLEMENTARY INFORMATION: On June
15, 1984, OMB delegated to the Board
authority under the PRA to approve and
assign OMB control numbers to
collections of information conducted or
sponsored by the Board. Boardapproved collections of information are
incorporated into the official OMB
inventory of currently approved
collections of information. Copies of the
PRA Submission, supporting
statements, and approved collection of
information instrument(s) are placed
into OMB’s public docket files.
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Final Approval Under OMB Delegated
Authority of the Extension for Three
Years, With Revision, of the Following
Information Collection
Report title: Capital Assessments and
Stress Testing Reports.
Agency form number: FR Y–14A/Q/
M.
OMB control number: 7100–0341.
Effective dates: Ranges from
December 31, 2019, to December 31,
2020.
Frequency: Annually, semi-annually,
quarterly, and monthly.
Respondents: The respondent panel
consists of U.S. bank holding companies
(BHCs), U.S. intermediate holding
companies (IHCs) of foreign banking
organizations (FBOs), and covered
savings and loan holding companies
(SLHCs) 1 with $100 billion or more in
total consolidated assets, as based on: (i)
the average of the firm’s total
consolidated assets in the four most
recent quarters as reported quarterly on
the firm’s Consolidated Financial
Statements for Holding Companies (FR
Y–9C); or (ii) if the firm has not filed an
FR Y–9C for each of the most recent four
quarters, then the average of the firm’s
total consolidated assets in the most
recent consecutive quarters as reported
1 SLHCs with $100 billion or more in total
consolidated assets become members of the FR Y–
14A/Q/M panel effective June 30, 2020. See 84 FR
59032 (November 1, 2019).
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quarterly on the firm’s FR Y–9Cs.2
Reporting is required as of the first day
of the quarter immediately following the
quarter in which the respondent meets
this asset threshold, unless otherwise
directed by the Board.
Estimated number of respondents: FR
Y–14A: 35; FR Y–14Q: 35; 3 FR Y–14M:
33.
Estimated average hours per response:
FR Y–14A: 1,030 hours; FR Y–14Q:
1,944 hours; FR Y–14M: 1,075 hours; FR
Y–14 Implementation and On-going
Automation Revisions, 540 hours; FR
Y–14 Attestation On-going Audit and
Review, 2,560 hours.
Estimated annual burden hours: FR
Y–14A: 72,100 hours; FR Y–14Q:
272,160 hours; FR Y–14M: 425,700
hours; FR Y–14 On-going Automation
Revisions, 18,900 hours; FR Y–14
Attestation On-going Audit and Review,
33,280 hours.
General description of report: This
family of information collections is
composed of the following three reports:
• The semi-annual FR Y–14A collects
quantitative projections of balance
sheet, income, losses, and capital across
a range of macroeconomic scenarios and
qualitative information on
methodologies used to develop internal
projections of capital across scenarios.4
• The quarterly FR Y–14Q collects
granular data on various asset classes,
including loans, securities, trading
assets, and pre-provision net revenue
(PPNR) for the reporting period.
• The monthly FR Y–14M is
comprised of three retail portfolio- and
loan-level schedules, and one detailed
address-matching schedule to
supplement two of the portfolio and
loan-level schedules.
The data collected through the FR Y–
14A/Q/M reports provide the Board
2 The Board had separately revised the
respondent panel for the FR Y–14 reports in
connection with the Board’s rule regarding
Prudential Standards for Large Bank Holding
Companies and Savings and Loan Holding
Companies (the ‘‘Tailoring Rule’’). See 84 FR 59230
(November 1, 2019) and 84 FR 50932 (November 1,
2019). Under the Tailoring Rule, the respondent
panel for the FR Y–14 reports is BHCs with total
consolidated assets of $100 billion or more, IHCs
with total consolidated assets of $50 billion or more
that are subsidiaries of an FBO, and covered SLHCs
with $100 billion or more in total consolidated
assets. See 12 CFR 217.2 (defining ‘‘covered savings
and loan holding company’’).
3 The estimated number of respondents for the FR
Y–14M is lower than for the FR Y–14A and FR Y–
14Q because, in recent years, certain respondents to
the FR Y–14A and FR Y–14Q have not met the
materiality thresholds to report the FR Y–14M due
to their lack of mortgage and credit activities. The
Board expects this situation to continue for the
foreseeable future.
4 In certain circumstances, a BHC or U.S. IHC may
be required to re-submit its capital plan. See 12 CFR
225.8(e)(4). Firms that must re-submit their capital
plan generally also must provide a revised FR Y–
14A in connection with their resubmission.
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with the information needed to help
ensure that large firms have strong, firmwide risk measurement and
management processes supporting their
internal assessments of capital adequacy
and that their capital resources are
sufficient given their business focus,
activities, and resulting risk exposures.
The reports are used to support the
Board’s annual Dodd-Frank Act Stress
Test (DFAST) and Comprehensive
Capital Analysis and Review (CCAR)
exercises, which complement other
Board supervisory efforts aimed at
enhancing the continued viability of
large firms, including continuous
monitoring of firms’ planning and
management of liquidity and funding
resources, as well as regular assessments
of credit, market and operational risks,
and associated risk management
practices. Information gathered in this
data collection is also used in the
supervision and regulation of
respondent financial institutions.
Compliance with the information
collection is mandatory.
Legal authorization and
confidentiality: The Board has the
authority to require BHCs to file the FR
Y–14 reports pursuant to section 5 of
the Bank Holding Company Act (‘‘BHC
Act’’) (12 U.S.C. 1844), to require SLHCs
to file the FR Y–14 reports pursuant to
section 10 of the Home Owners’ Loan
Act (12 U.S.C. 1467a(b)), and to require
the U.S. IHCs of FBOs to file the FR Y–
14 reports pursuant to section 5 of the
BHC Act, in conjunction with section 8
of the International Banking Act (12
U.S.C. 3106). The FR Y–14 reports are
mandatory.
The information collected in these
reports is collected as part of the Board’s
supervisory process, and therefore is
afforded confidential treatment
pursuant to exemption 8 of the Freedom
of Information Act (‘‘FOIA’’) (5 U.S.C.
552(b)(8)). In addition, individual
respondents may request that certain
data be afforded confidential treatment
pursuant to exemption 4 of the FOIA,
which exempts from disclosure ‘‘trade
secrets and commercial or financial
information obtained from a person
[that is] privileged or confidential’’ (5
U.S.C. 552(b)(4)). Determinations of
confidentiality based on FOIA
exemption 4 would be made on a caseby-case basis.
Current actions: On July 31, 2019, the
Board published two notices in the
Federal Register (84 FR 37285 and 84
FR 37292) requesting public comment
for 60 days on the extension, with
revision, of the Capital Assessments and
Stress Testing Reports. The Board
proposed to implement a number of
changes to schedules of the FR Y–14A,
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FR Y–14Q, and FR Y–14M reports. The
proposed revisions consisted of deleting
or adding items, adding or expanding
schedules or sub-schedules, and
modifying or clarifying the instructions
for existing data items, primarily on the
FR Y–14Q and FR Y–14M reports. The
Board proposed most of these changes
in an effort to reduce reporting burden
for firms, clarify reporting instructions
and requirements, address
inconsistencies between the FR Y–14
reports and other regulatory reports, and
to account for revised rules and
accounting principles. A limited
number of proposed revisions would
have modified the reporting
requirements and added or expanded
sub-schedules to improve the
availability and quality of data to
enhance supervisory modeling and for
use in DFAST.
The proposed revisions also were
meant to address revised accounting for
credit losses under the Financial
Accounting Standards Board’s (FASB)
Accounting Standards Update (ASU)
No. 2016–13, ‘‘Financial Instruments—
Credit Losses (Topic 326): Measurement
of Credit Losses on Financial
Instruments’’ (ASU 2016–13) and
implement the CECL accounting
methodology across all of the FR Y–14
reports. The proposed changes to the FR
Y–14 reports paralleled the related
changes to the Consolidated Financial
Statements for Holding Companies (FR
Y–9C) for CECL, as appropriate.5 The
proposed reporting changes related to
CECL also were consistent with the
revisions indicated in the interagency
final rule that incorporated the CECL
transition.6
The comment period for the two
notices regarding the Capital
Assessments and Stress Testing Reports
expired on September 30, 2019. The
Board received four comment letters
from banking organizations and one
comment letter from a banking industry
group on its non-CECL proposal. The
Board received one comment letter from
a banking organization and one
comment letter from a banking industry
group on its CECL proposal. All
comments and responses are delineated
below based on whether the comment
was related to the non-CECL or CECL
proposal.
Detailed Discussion of Public
Comments
Timing of Proposed Changes
The Board proposed that all revisions
associated with these proposals to be
5 See
6 See
84 FR 11783 (March 28, 2019).
84 FR 4222 (February 14, 2019).
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effective for September 30, 2019. Four
commenters stated that those revisions
should be delayed so that there would
be time for FR Y–14 filers to set up or
update, as well as adequately test, their
internal reporting systems to adopt the
reporting changes. For the FR Y–14A,
two commenters suggested adjusting the
effective date for most of the revisions
to December 31, 2019, with the
exception of the proposals to eliminate
the deposit funding threshold from the
PPNR schedule and to require IHCs to
provide a cost allocation as a
supplement to their PPNR schedules,
which two commenters proposed to
become effective December 31, 2020.
Another commenter suggested that all
revisions associated with FR Y–14A
become effective December 31, 2020.
For the FR Y–14Q, two commenters
suggested adjusting the effective date to
delay most of the revisions to December
31, 2019, with the exception of certain
proposed changes to the Counterparty
(Schedule L), Trading (Schedule F), and
Retail (Schedule A) schedules, which
the commenters suggested to delay until
June 30, 2020. One commenter
suggested delaying all proposed
revisions associated with the FR Y–14Q
to March 31, 2020. Finally, for the FR
Y–14M, three commenters suggested
delaying all proposed revisions to
become effective March 31, 2020.
In light of the rationale for delaying
implementation to allow firms adequate
time to set up, update, and test their
internal systems, as well as due to the
fact that the proposed effective date has
already passed, the Board has revised
the effective date from September 30,
2019, to dates ranging from December
31, 2019, to December 31, 2020, for
different aspects of the proposal. The
December 31, 2019, date was chosen as
some revisions are necessary for the
DFAST 2020 stress test cycle, and so
could not have been delayed to a later
date. The effective dates for the other
revisions were chosen as a balance
between data needed by the Board and
industry burden.
Timing of Non-CECL Revisions
For non-CECL revisions associated
with the FR Y–14A, all revisions will be
effective for December 31, 2020, except
the revisions to schedule A.1.d
(Capital), the revisions to schedule A.2.a
(Retail Balance and Loss Projections),
the revisions to schedule A.4 (Trading),
and the revisions made to conform to
changes previously made to the FR Y–
9C. The revisions to schedule A.1.d,
A.2.a, and A.4 will be effective for
December 31, 2019, as they are critical
for the DFAST 2020 stress test cycle.
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For non-CECL revisions associated
with the FR Y–14Q, all revisions will be
effective for March 31, 2020, with the
exception of the revisions to Schedule D
(Regulatory Capital), the addition of the
fair value option (FVO) hedges subschedule to Schedule F (Trading),
certain revisions to Schedule H
(Wholesale), the elimination of
Schedule I ([Mortgage Servicing Rights]
MSR Valuation Schedule), and the
revisions made to conform to changes
previously made to the FR Y–9C, which
will be effective for December 31, 2019,
as well as the revisions to the
Counterparty schedule, which will be
effective for June 30, 2020. The nonCECL FR Y–14Q revisions that are
effective for December 31, 2019, are
needed then because they are critical for
the DFAST 2020 stress test cycle. For
the December 31, 2019, as of date, the
Board will allow firms to submit the
FVO hedges sub-schedule to Schedule F
by March 6, 2020, as opposed to the
February due date for the rest of the FR
Y–14Q. The Board recognizes that one
commenter requested delaying proposed
revisions to the Trading schedule and
the proposal to add a weighted-average
life (WAL) segment variable to the Retail
schedules to June 30, 2020. However,
the Board feels that extending the
effective date by six months will
provide adequate time to set up or
update, as well as adequately test,
pertinent internal systems. In addition,
firms already provide a WAL item on
the FR Y–14A, PPNR schedule
(schedule A.7) at the portfolio level. The
instructions for the new WAL item at
the loan segment level are similar to the
existing WAL items on the PPNR
schedule, and so the Board has added
the item as proposed, except with a
March 31, 2020, effective date.
For non-CECL revisions associated
with the FR Y–14M, all revisions will be
effective for March 31, 2020.
Timing of CECL Revisions
As indicated in the final CECL rule
and as outlined in FR Y–14 CECL
proposal, an institution may reflect the
adoption of ASU 2016–13 on the FR Y–
14 reports beginning with the 2020
stress test cycle. Therefore, all CECLrelated items need to be incorporated
into the FR Y–14 reports for December
31, 2019.
Consistency of Numbering Across the
Two Proposals
The Board also received several
comments about inconsistent
numbering of items across the FR Y–14
reports between the non-CECL and
CECL proposals. Since the Board is
adopting both proposals at once, the
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numbering is consistent in the forms
and instructions provided with this
notice.
Non-CECL Proposal Comments
General
The Board issues technical
instructions so firms know how to
configure their systems and files to
submit the FR Y–14A and FR Y–14Q.
One commenter asked for the Board to
provide these technical instructions
before year-end 2019 so firms have
sufficient time to make any necessary
adjustments. The Board seeks to provide
firms technical instructions in a timely
manner, and seeks to do so with respect
to the technical instructions for these
reporting changes.
FR Y–14A
Schedule A.1.d (Capital)
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The Board proposed to revise the
instructions to the FR Y–14A to provide
guidance on how firms should reflect
the impact of the ‘‘global market
shock’’ 7 on items subject to adjustment
or deduction from capital. Specifically,
if a firm were to adjust its projection of
an item to reflect the impact of the
global market shock, the instructions
would indicate that the firm must also
report an adjusted starting value that
reflects the global market shock for
applicable items. One commenter
questioned whether this revision
conflicts with guidance previously
issued through a CCAR frequently asked
question (FAQ SHK0030),8 in which the
Board stated that firms should not
assume a related decline in portfolio
positions or risk-weighted assets as a
result of global market shock losses.
Another commenter suggested that this
treatment is a significant policy
question that should be separately
clarified by the Board. The Board notes
that the proposed revisions reflect a
departure from the guidance issued in
FAQ SHK0030. In the past, the Board
required firms to report capital using
post-stress losses, but pre-stress values
of certain capital deductions. The Board
is now requiring firms to adjust their
capital deductions to reflect the impact
of the global market shock in order to
make their capital calculation further
7 The global market shock is a set of
instantaneous, hypothetical shocks to a large set of
risk factors. Generally, these shocks involve large
and sudden changes in asset prices, interest rates,
and spreads, reflecting general market dislocation
and heightened uncertainty. The global market
shock impacts the Trading and Counterparty
schedules of the FR Y–14A and FR Y–14Q.
8 https://www.federalreserve.gov/publications/
comprehensive-capital-analysis-and-reviewquestions-and-anwers.htm.
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reflect post-stress values.9 The Board
has adopted this revision as proposed.
To mitigate confusion, the Board is
rescinding FAQ SHK0030, as that
historical guidance is inconsistent with
the new instructions.
The Board proposed to rename item
109 (Potential net operating loss
carrybacks) to ‘‘Taxes previously paid
that the bank holding company could
recover if the bank holding company’s
temporary differences (both deductible
and taxable) fully reverse at the report
date.’’ The Board also proposed to revise
the instructions for this item to state
that firms should report the amount of
taxes previously paid that the firm
could recover through loss carrybacks if
the firm’s temporary differences (both
deductible and taxable) fully reverse at
the report date. The Board proposed
these revisions to reflect provisions in
the Tax Cuts and Jobs Act (TCJA) that
changed the treatment of deferred tax
assets (DTAs).10 One commenter
pointed out that the revisions to this
item did not include taxes previously
paid that the firm could recover through
carrybacks of projected negative taxable
income (i.e., net operating loss and
credits) over the planning horizon. The
commenter further noted that, although
the TCJA eliminated net operating loss
(NOL) carrybacks in the U.S., certain
carrybacks are still allowed (e.g., credits
and capital losses in U.S., as well as
NOL carrybacks in various jurisdictions
like the United Kingdom and certain
U.S. states). The commenter requested
the Board rename item 109 as a result.
To better reflect the applicable
provisions of the TCJA, the Board is
renaming item 109 to ‘‘Taxes previously
paid that the bank holding company
could recover through allowed
carrybacks if the bank holding
company’s DTAs on net operating loss,
tax credits and temporary differences
(both deductible and taxable) fully
reverse at the report date,’’ and is
revising the instructions accordingly.
Schedule A.2.a (Retail Balance and Loss
Projections)
CECL replaced the concept of
purchased credit-impaired (PCI) with
that of purchased credit-deteriorated
(PCD). As a result, the Board proposed
to revise FR Y–14A, Schedule A.2.a, to
include PCD breakouts for all mortgage
categories. One commenter pointed out
that the draft instructions provided with
the proposal specify that these new PCD
fields only apply to home equity items.
Consistent with the language used in the
9 See 84 FR 6664 (April 1, 2019) for more
information on disclosure methodology.
10 Public Law 115–97, 131 Stat. 2054 (2017).
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description of the initial proposal, the
intent of the proposal was to make these
fields applicable to all mortgage line
items. The Board is revising the
instructions accordingly.
Schedule A.7 (Pre-Provision Net
Revenue (PPNR))
The Board proposed eliminating the
deposit funding threshold for the FR Y–
14A, Schedule A.7.b (Net Interest
Income), which is currently optional for
firms with deposits comprising less than
25 percent of total liabilities for any
period reported in any of the four most
recent FR Y–14Q reports. For the reports
as of June 30, 2016, the deposit-funding
threshold was eliminated from the FR
Y–14Q, Schedule G (PPNR). Two
commenters said that removing this
threshold would impose significant
burden on the small subset of firms that
are not currently required to report this
schedule. The commenters
recommended that the Board postpone
this revision until December 31, 2020,
so that firms that are not currently
required to file have ample time to set
up and adequately test their reporting
systems. Given the time necessary for
these firms to set up and adequately test
their reporting systems, the Board has
adopted the revision and has postponed
implementation until December 31,
2020.
The Board proposed adding further
specification surrounding the
requirements for supporting information
provided by U.S. IHCs. Specifically, the
proposal would add instructions to the
supporting documentation requirements
clarifying that IHCs with material
transfer pricing or cost allocation items
with related entities should report these
revenues and expenses in the
appropriate business-line category,
rather than the ‘‘other’’ category. In
addition, the proposal would have
required U.S. IHCs to provide
supporting documentation that
disaggregates the impact of transfer
pricing and cost allocations on revenue
and expense projections to allow the
Board to understand the revenue impact
of these arrangements.
Two commenters said there would
have been insufficient time for IHCs to
provide the proposed cost allocation
breakout items for September 30, 2019,
as these firms are still in the early stages
of shared cost structures. Both
commenters proposed delaying
implementation of these revisions until
December 31, 2020. One commenter
further requested that the Board provide
additional clarification on the proposed
change regarding the granularity
required for the cost allocation, and that
this information not be required for
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stressed scenarios as that would require
substantial investment in IHCs’ models.
Given the concerns posed by the
commenters, the Board has provided
clarification regarding cost allocation in
the FR Y–14A instructions, has added
this clarifying language to the FR Y–
14Q, Schedule G instructions, and has
delayed implementation until December
31, 2020. The Board believes this new
effective date provides sufficient time
for IHCs to gather the necessary
information.
The Board proposed to revise several
items on the PPNR schedules of the FR
Y–14A and FR Y–14Q (Schedule G) to
indicate how dividend income on
equity products should be reported. The
proposed revisions were intended to
align with reporting on the FR Y–9C. In
doing this, the Board proposed that
dividend income on equity products
with readily determinable fair values
not held for trading be reported as
interest income and that dividend
income on equity products held for
trading be reported as noninterest
income. One commenter pointed out
that the FR Y–9C is not explicit as to
how dividend income on equity
products should be reported. The
commenter also pointed out that items
impacted by these revisions flow
through to other PPNR items,
specifically those that relate to the
earned average rate of trading assets.
The Board notes that, under the
proposal, the reporting of dividend
income on equity products may not be
consistent between the FR Y–9C and the
FR Y–14, as the FR Y–9C instructions
are not explicit as to how this income
should be reported. As a result, the
Board has revised the language for item
5B (‘‘Other [sales and trading interest
income]’’) on the FR Y–14A, Schedule
A.7.a and FR Y–14Q, Schedule G.1, to
include equity trading activity not
reported in item 5A (Prime Brokerage
[sales and trading noninterest income]),
instead of a direct reference to dividend
income on equity products with readily
determinable fair values not held for
trading. The Board has also revised the
language for item 18C (‘‘Other [sales and
trading noninterest income]’’) on
Schedules A.7.a and G.1 to remove
references to dividend income on equity
securities held for trading.
The Board proposed to revise item 15
(‘‘Other Interest/Dividend-Bearing
Assets’’) on FR Y–14A, Schedule A.7.b
and FR Y–14Q, Schedule G.2, to include
balances from equity securities with
readily determinable fair values not
held for trading. One commenter
pointed out that this is not consistent
with the FR Y–9C, in which equity
securities with readily determinable fair
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values are reported as ‘‘All other debt
securities and equity securities with
readily determinable fair values not
held for trading purposes’’ (item 1.c),
and not as ‘‘Other earning assets’’ (item
4.b), on Schedule K (Quarterly
Averages). Given this, the commenter
recommended moving balances from
equity securities with readily
determinable fair values not held for
trading from item 15 to item 12
(‘‘Securities AFS and HTM—Other’’).
The Board notes that item 12 is a more
appropriate location for equity
securities with readily determinable fair
values not held for trading, as they share
more risk characteristics with nonequity securities than with other earning
assets. As a result, the Board is updating
the instructions accordingly.
The Board proposed to revise the
PPNR schedules of the FR Y–14A and
FR Y–14Q, as well as Schedule A
(Retail) of the FR Y–14Q, so that loans
(and associated income) in U.S.
territories (including Puerto Rico)
would be treated as international. The
intent of this proposal was to align the
reporting of loans in U.S. territories
between the FR Y–14 and the FR Y–9C.
However, one commenter pointed out
that the reporting of these loans is more
nuanced on the FR Y–9C, as the
treatment can differ within and across
schedules, and so the proposed FR Y–
14 revisions would still result in
inconsistencies between the items on
the PPNR schedules and similar items
on the FR Y–9C. In response, the Board
is revising the proposed instructions to
the PPNR schedules to require firms to
refer to the FR Y–9C for the definition
of domestic and international. This will
result in the classification of loans as
international or domestic on the FR Y–
14 PPNR schedules truly aligning with
those of the FR Y–9C.
For the FR Y–14Q, Schedule A
(Retail), the Board proposed to remove
an exception for loans in U.S. territories
from the international loan-reporting
requirement. However, in contrast to the
PPNR schedules, the existing
instructions for Schedule A already
directed firms to refer to the FR Y–9C
definitions for international and
domestic for applicable loan categories.
Therefore, the Board has adopted the
revisions to the FR Y–14Q, Schedule A
(Retail), as proposed, so that the
definitions of international and
domestic align, without exception, with
those on the FR Y–9C.
Schedule E (Operational Risk)
The Board proposed several revisions
to Schedule E.2 (Material Risk
Identification), one of which was to
rename the ‘‘Risk segment’’ variable to
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‘‘Business line(s)/firm-wide.’’ One
commenter pointed out that the name
‘‘Risk segment’’ provided a clear linkage
to FR Y–14A, Schedule A.6 (BHC or IHC
Operational Risk Scenario Inputs and
Projections), as this schedule also had a
variable named ‘‘Risk segment.’’ The
commenter asked whether the Board
still expects this clear linkage despite
the name change. The Board notes that
the proposed revisions to Schedule E.2
allow for better linkage between the
categories of the difference schedules, as
firms will now have to identify and list
the methodology used to estimate
operational risk model. The Board has
adopted the revisions as proposed.
FR Y–14Q
Schedule D (Regulatory Capital)
The Board proposed to eliminate most
items on Schedule D, as they are
duplicative of reporting elsewhere
because the common equity tier 1
(CET1) capital deductions are now fully
phased-in. One commenter asked for
clarification as to whether the proposed
changes to Schedule D apply to all
firms, or only to non-advanced
approaches firms. The Board notes that
the changes apply to all firms that file
the FR Y–14Q, as there are no
exemptions listed in the proposed
instructions.
While the Board proposed to
eliminate most of the items on Schedule
D, it did retain a limited number of
items that are not reported elsewhere
and proposed to add a handful of items
relating to non-significant investments
subject to a threshold deduction from
CET1 capital. One commenter asked
how one of the new items (item 15—
‘‘DTAs arising from temporary
differences, net of DTLs’’) differs from a
retained item (item 18—‘‘DTAs arising
from temporary differences that could
not be realized through net operating
loss carrybacks, net of related valuation
allowances and net of DTLs’’). The
difference between these two items is
that item 15 is reported before netting of
carrybacks and valuation allowance,
whereas item 18 is inclusive of
valuation allowance and carryback
netting. The Board believes this
reporting is clear based on the
instructions, and has adopted the
revisions as proposed.
The Board proposed to add a new
memoranda item to Schedule D (item
M1—‘‘Taxes paid through the as-of date
of the current fiscal year’’). The
instructions for this item require
respondents to report the amount of
taxes paid during the current fiscal year
through the as-of date that are included
in Schedule D, item 17, ‘‘Potential net
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operating loss carrybacks,’’ assuming
that fiscal years align with calendar
years. One commenter asked whether
the data from this item can be
appropriately sourced from FR Y–9C,
Schedule HI (Income Statement), item 9
(Applicable income taxes (foreign and
domestic)). The Board notes that, based
on the instructions for item M1, firms
should only report income taxes paid
that are included in item 17, which may
not equal the income taxes reported in
FR Y–9C, Schedule HI, item 9. The
Board has adopted the revisions as
proposed.
Schedule F (Trading)
The Board proposed to delineate
reporting of private equity investments
between those reported at fair value and
those reported using accounting
methods other than fair value (non-fair
value). Two commenters asked the
Board to clarify whether the intended
population of the private equity
investments reported at fair value
includes investments required to be
held at fair value, as well as (1)
investments in which FVO accounting
treatment has been elected and (2) fund
positions measured at net asset value
(NAV). In response, the Board notes that
the intended population of the private
equity investments reported at fair value
consists of investments required to be
reported at fair value, including
investments where fair value is
estimated using NAV or where FVO has
been elected. The commenters also
suggested excluding all non-fair value
investments from Schedule F because
they believe the macro scenario is more
appropriate than the global market
shock scenario for capital planning
purposes for these positions. The Board
notes that private equity is the only
asset type where non-fair value
exposures are required to be reported on
Schedule F. Further, the Board notes
that fair value and non-fair value private
equity investments have different risk
characteristics, and so believes it is
essential that these exposures are
separately reported. Since the Board
now has a breakout between fair value
and non-fair value private equity
investments, the Board will be able to
assess whether the macro scenario is
more appropriate than the global market
shock for non-fair value exposures. If
the macro scenario is more appropriate,
then the Board will propose an
alternative treatment in a future
notice.11 The Board has adopted the
revisions as proposed.
11 See 84 FR 6664 (February 28, 2019) for more
information about the Federal Reserve’s model
development and validation practices.
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The Board proposed to add a subschedule that captures FVO loan
hedges. One commenter asked the Board
to expand this sub-schedule to include
all non-trading hedges, regardless of
accounting treatment, as including these
hedges would portray a more accurate
picture of risk and because it may be
difficult for firms to segment hedging
activity that is directly correlated to a
specific accounting treatment. The
Board has been collecting FVO loan
hedge information as a supplement to
the supervisory stress test for several
years, and this proposal was a
formalization of this supplemental
collection. FVO loan hedge information
is critical to adequately assessing the
risks posed by FVO loans. Without this
information, the Board would have no
way to determine whether firms are
mitigating FVO loan risks through
hedging. The Board has adopted the
revisions as proposed, and will consider
expanding the sub-schedule in a future
proposal. The same commenter asked
the Board to clarify whether the as-of
date the FVO loan hedges sub-schedule
should be at quarter end. Consistent
with the instructions published with the
initial proposal, the as-of date for the
FVO loan hedges sub-schedule is
quarter end.
One commenter asked whether the
Board could provide examples of what
should be included in the FVO loan
hedge sub-schedule. The Board is
revising the instructions to add a nonexhaustive list of examples of what
should be included in this subschedule.
The Board proposed to exclude
mandated investments, such as those in
government or government-sponsored
entities and stock exchanges, from
Schedule F. One commenter asked the
Board to further clarify the definition of
mandated investments. The Board
believes the proposed definition is
sufficient, and therefore has adopted the
revisions as proposed. The Board
encourages firms to seek guidance from
the Federal Reserve if they have specific
questions related to bespoke
investments.
The Board did not propose to revise
the list of examples for what to include
the Other Fair Value Assets Subschedule that is currently in the
instructions. However, due to the
placement of the list in the instructions,
one commenter asked that the Board
clarify whether the list applies only to
the Other Fair Value Assets subschedule. The Board is revising the
instructions to make it clear that this list
applies only to the Other Fair Value
Assets sub-schedule.
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Schedule H (Wholesale)
The Board proposed to add two
additional Schedules, H.3 (Line of
Business) and H.4 (Internal Risk Rating
Scale), which would allow for mapping
of each firm’s internal risk ratings and
line of business values to a consistent
benchmark for use in modeling. One
commenter suggested the Board expand
Schedule H.4 to ask for additional
items, such as probability of default
information. The commenter also
suggested expanding Schedule H.4 to
correspond to FR Y–14Q, Schedule L
(Counterparty), instead of just Schedule
H, as both schedules require an internal
and external rating equivalent factor. At
this time, the Board does not need any
additional fields on these schedules, but
will consider expanding Schedule H.4
as part of a future proposal.
Additionally, the Board will not expand
Schedule H.4 to correspond with the
Counterparty schedule at this time, as
the data between the two schedules do
not readily align.
The Board proposed to revise
Schedule H.1 (Corporate Loan Data),
item 25 (‘‘Utilized Exposure Global’’),
and Schedule H.2 (Commercial Real
Estate), item 3 (‘‘Outstanding Balance’’),
to align reporting with the FR Y–9C
definition of loan and lease financing
receivables. This would cause the
exposure amounts reported in Schedule
H.1, item 25, and Schedule H.2, item 3,
to be netted by deferred fees and costs.
One commenter stated that while this
would align with the FR Y–9C, firms
would need significant time to
accurately implement these revisions,
and requested the proposal be dropped
or delayed. These two fields are critical
for modeling, and the Board believes
that aligning the definitions between the
FR Y–14Q and FR Y–9C will enhance
reporting accuracy and improve clarity.
The Board also acknowledges that
unlike the FR Y–9C, the Wholesale
schedule is reported at the facility level,
and so firms need time to adequately
capture the deferred fees and costs.
Therefore, the Board has adopted the
revisions as proposed, but is delaying
implementation until December 31,
2019, so that these fields can be updated
in time for CECL implementation on the
FR Y–14Q, as these fields are critical for
CECL.
The Board proposed to revise the line
of business items (Schedule H.1, item
27; Schedule H.2, item 22) to not require
that the line of business be reported at
origination, as they typically change
over time. One commenter requested the
Board expand the description of these
items to clarify that the current line of
business should be reported. The Board
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believes its proposed revision captures
this point because firms will no longer
be required to report the line of business
at origination, and is more consistent
with the existing instructions for other
items. The Board has adopted the
revision as proposed.
The Board proposed to revise several
Schedule H items to align with the
definition of loans and lease financing
receivables on the FR Y–9C. One
commenter noted that the Board should
also align the definition of major
modification in origination date fields of
Schedules H.1 and H.2 (items 18 and 10,
respectively), with that of the FR Y–9C.
While the Board strives to align
reporting definitions when appropriate,
the definition of a major modification
on Schedule H is much broader than
that of the FR Y–9C and is used to
assess whether there has been a change
in the origination date for all types of
loans. The Board does not believe it is
appropriate to use the FR Y–9C or
GAAP definition of ‘‘modification’’
because this definition is mainly
associated with troubled debt. The
Board has adopted the revision as
proposed.
The Board proposed to revise the
definition of ‘‘country’’ on Schedule H.1
(item 6) to refer to the definition of
‘‘domicile,’’ as defined in the FR Y–9C
glossary. One commenter suggested the
Board also revise Schedule H.1, items 5
(‘‘City’’) and 7 (‘‘Zip Code’’), to
reference the borrower’s domicile in
assigning the obligor’s country in
Schedule H.1, (item 6). The Board
strives to align the definitions of related
items where applicable, and so is
revising the instructions accordingly.
The Board proposed to revise the
maturity date fields of Schedules H.1
and H.2 (item 19 for both) to eliminate
the implied requirement to test
compliance with the terms of the credit
agreement each quarter. One commenter
asked whether this revision means that
firms would now have to factor in the
extension options that are solely at the
discretion of the borrower from
inception, or alternatively, whether it
means that the extended date is only
reported during the extension option
window provided that the borrower has
requested an extension and an
assessment has been made that the
conditions outlined in the agreement
have been complied with. The Board
has adopted the proposed revisions to
the maturity date fields, which is
inclusive of all extension options that
are solely at the borrower’s discretion
regardless of the timing of the extension
option window, including extension
options that are conditional on certain
terms being met without any need to
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assess compliance with the terms of the
credit agreement.
The Board proposed to add items 65
(‘‘Committed Exposure Global Fair
Value’’) and 66 (‘‘Outstanding Balance
Fair Value’’) to Schedule H.2. One
commenter questioned whether these
two new items were capturing
duplicative information, as items 5
(‘‘Committed Exposure Global’’) and 3
(‘‘Outstanding Balance’’), respectively,
seem to capture similar information for
held-for-sale and FVO exposures. The
Board notes that Schedule H.2, items 5
and 3, represent different concepts from
the newly-proposed fair value items 65
and 66. Although there may be cases
where values in items 5 and 3 coincide
with the values in the newly proposed
fair value items (65 and 66,
respectively), in other instances the
values may differ between these fields
(specifically for held-for-sale (HFS)
loans reported at lower of cost or fair
value, when amortized cost is lower
than fair value). The Board has adopted
the revisions as proposed.
The Board proposed to add several
fields related to committed exposure
and utilized exposure global par values,
as well as fair values, to Schedules H.1
(items 102 through 105) and H.2 (items
63 through 66). One commenter had
several questions about these new items.
First, the commenter wanted the Board
to clarify whether firms should report
their share of the global commitments or
the total global commitment of the
entire facility. The Board notes that
firms are expected to report their prorata commitments in the committed
exposure fields. The pro-rata share is
net of adjustments that are noted in the
FR Y–14Q instructions. The
‘‘Committed Exposure Global’’ fields
should include the total commitment
amount, including any unused portfolio
of the commitment. Second, the
commenter asked how to report these
items for facilities that include held-forsale loans or loans accounted for under
a fair value option and held-forinvestment loans. The Board notes that
for loans reported in Schedule H.1, if
the firm reports a value of 3 (‘‘NA’’) in
the ‘‘Lower of Cost or Market Flag’’
(item 86), then it should report ‘‘NA’’ for
items 102 (‘‘Committed Exposure Global
Par Value’’) and 103 (‘‘Utilized
Exposure Global Par Value’’). In cases
where there are multiple loans in the
same facility, firms should report the
consolidated exposure based on the
accounting type for loans that make up
the predominant share of the facility.
Third, the commenter asked whether
firms should continue to report
commitment balances on a trade date
basis. The Board notes that firms should
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continue to report commitment balances
on a trade date basis. The Board has
adopted the revision as proposed.
The Board did not propose any
changes to the treatment of disposed
loans on Schedule H. However, one
commenter suggested that the Board
revise the instructions to allow disposed
facilities to be reported with data as of
the prior reporting cycle rather than the
day of disposition. The Board believes
collecting loan disposition information
as it existed at the point of disposition
is critical, and so will not revise the
current requirements.
Schedule L (Counterparty)
The Board proposed to expand the
scope of granularity of a firm’s reporting
of credit valuation adjustment (CVA)
related data fields from the top 95
percent to all counterparties at the legal
entity level for several sub-schedules.
Four commenters expressed that this
change would cause significant burden
on firms not only from a data
perspective, but also from a technical
perspective, as firms’ and vendors’
systems may not be capable of handling
data sets of that size. The Board
acknowledges the operational concerns
raised by the industry. In doing so, the
Board has adopted a modification of the
proposed revision that limits the scope
of counterparty legal entity identifier
(LEI) level reporting requirements in
Schedules L.1–L.3 12 to top 95%
stressed CVA, in addition to the existing
95% unstressed CVA. For the remaining
counterparties that are not required to
be reported at an individual LEI level,
a new Schedule will be added to collect
summary metrics with respect to their
key attributes, for example by industry,
rating, and region.
Two commenters requested the Board
clarify whether this increased scope
applied to all counterparties, or only
counterparties with CVA. The Board
confirms the scope of the counterparty
population under the adopted
modification of the proposed revision
should apply only to counterparties
with CVA.
In addition to the increased scope in
CVA related fields, the Board proposed
revisions to several definitions
throughout Schedule L. Two
commenters asked for additional
clarification regarding the consistency
of the ‘‘Netting Set ID’’ field throughout
the Schedules, the definition of the
‘‘Trades Not Captured’’ field, as well as
12 Sub-schedules L.1.a through L.1.d.2 capture
information regarding derivatives profile by
counterparty and aggregate across all
counterparties. Sub-schedule L.2 captures expected
exposure profile by counterparty and sub-schedule
L.3 captures credit quality by counterparty.
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whether securities financing
transactions (SFTs) should be included
with derivatives in the same
counterparty data sets. ‘‘Netting Set ID’’
and ‘‘Sub-netting Set ID’’ are optional
fields for certain schedules. To ensure
consistency across Schedule L, the
Board is revising the instructions to
require these field to be reported for all
schedules, and is requiring that they be
reported using the same granularity
across Schedule L. Further, the Board is
revising the instructions to indicate that
the ‘‘Trades Not Captured’’ field should
incorporate types of trades or
counterparties for which CVA is
computed offline (i.e., outside of the
main CVA systems). This is effectively
equivalent to the scope of counterparties
and/or types of trades for which the firm
is unable to submit data requirements
associated with Schedule L.2 that relate
to the components of the CVA. Finally,
the Board is revising the instructions to
clarify that fair-valued SFTs should be
reported in aggregate under Schedule
L.1.e.2 (Additional/Offline CVA
Reserves), as opposed to at the granular
counterparty LEI level reporting under
Schedules L.1, L.2, and L.3. In doing so,
a new line item will be added to collect
fair-valued SFTs separately under
Schedule L.1.e.2.
The Board proposed to require firms
to report certain counterparties on
Schedule L.1.a–L.1.d at a counterparty
legal entity level, rather than a
consolidated parent level. One
commenter recommended that the
reporting of sovereign counterparties
remain unchanged since the proposed
instructions would require incremental
data on whether sovereign
counterparties are state-owned
enterprises, which are backed by the full
faith and credit of a sovereign entity,
and that data is not readily available.
The commenter added that if this
change were required, then the Board
should clarify the definition of ‘‘full
faith and credit of a sovereign entity’’
and how to determine that using North
American Industry Classification
System (NAICS) codes. The commenter
further suggested that the Board confirm
whether the determination of designated
central counterparties (CCPs) not
located in the U.S. is consistent with
those CCPs identified as Qualifying
Central Counterparty (QCCP) under 12
CFR 217. If this is not the intended
population, the commenter
recommended that the Board specify the
supervisory provisions that would
constitute an international CCP being
regulated and supervised in a manner
equivalent to the designated financial
market utilities. The Board notes that
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the proposed change to the instructions
on sovereign and designated CCP
counterparties is a codification of how
the Board requires firms to calculate
their largest counterparty as part of the
large counterparty default (LCPD)
component. However, the Board does
acknowledge the benefit of using the
definitions of sovereign and CCPs that
are consistent with those in the
regulatory capital rules. Given this, the
Board is revising the definitions of
sovereign and CCPs, including the scope
of QCCPs vs non-QCCPs, to correspond
with the definitions in section .2 of the
regulatory capital rules (12 CFR 217), as
recommended by the commenter. As a
result of the Board revising the
instructions to use the definition of
sovereign in regulatory capital rules and
the delaying of the effective date until
June 30, 2020, the Board believes the
concerns raised by the commenter have
been mitigated.
The Board proposed to revise
Schedule L.1.a (Individual
Counterparties—Credit Valuation
Adjustment (CVA)) to clarify that
individual counterparties should be
captured at the legal entity level, rather
than at the aggregated parent or
consolidated level. Two commenters
asked the Board to clarify how this
change impacts Schedule L.1.e
(Aggregate CVA Data by Ratings and
Collateralization) and Schedule L.4
(Aggregate and Top 10 CVA
Sensitivities by Risk Factor). The Board
is revising the instructions to show that
Schedule L.1.e should be reported based
on the immediate counterparty LEI
facing the firm and that Schedule L.4
should continue to be reported at the
aggregated parent or consolidated
counterparty level.
The Board received a comment
recommending that language be added
to the Schedule L instructions
specifying how the schedule should
relate to data reported in FR Y–14A,
Schedule A.5 (Counterparty Credit
Risk). The Board strives to align or
otherwise connect related data fields,
where applicable, and is including
language in the technical instructions to
clarify how the data should reconcile
between these two schedules with
regards to both CVA and LCPD.
FR Y–14M
Schedule A (Domestic First Lien ClosedEnd 1–4 Family Residential Loan) and
Schedule B (Domestic Home Equity
Loan and Home Equity Line)
The Board proposed to revise
Schedules A and B to indicate that in
cases of involuntary terminations, loans
should be reported for up to 24 months
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following termination until data in the
four loss severity fields are available to
report. The Board notes that this change
should apply to loans that have
experienced an involuntary termination
within the past 12 months of the date of
the revised instructions and for which
the four loss severity fields are
available. One commenter asked
whether this revision should only be
applied to accounts where the event
(i.e., charge-off and involuntary
termination) occurred in the first month
after the revision became effective, and
which accounts should now be included
in these schedules. The Board clarifies
that the reporting of accounts where the
event occurred 12 months prior to the
date of the revised instruction is not
changing, and firms are not required to
include accounts where the event
occurred 24 months prior to the date of
the revised instructions.
The Board received two other
comments on its proposal regarding
reporting cases of involuntary
terminations on Schedule A and B. The
first comment states that this proposal
will create additional operational
burden, specifically as it relates to loans
serviced by others. Per the comment,
loan servicers are responsible for
tracking non-performing loans/lines,
regardless of lien position, through the
full loss mitigation process. When a
loan/line is involuntary liquidated, the
servicer is responsible for recording all
of the loss severity information and
passing that information to the bank that
owns the loan/line. When this happens,
the owning bank removes the liquidated
loan/line from its system. The
commenter points out that this revision
should only be applied prospectively
(i.e., for accounts with involuntary
terminations from the date of the
revised instructions forward). The
second comment asks that certain
commercial and serviced loans be
exempt from this treatment, and asks to
confirm whether all fields on Schedules
A and B need to be filled out for these
loans/lines, or whether only the loss
severity fields need to be filled out.
The Board notes that only a portion of
recoveries are realized within the first
12 months after charge-off, and so
moving to a 24 month window would
portray a more complete picture of
applicable recoveries. The Board further
notes that in the case of involuntary
terminations, loans should be reported
for up to 24 months following
termination, until the data on specified
fields (items 93 (‘‘Total Debt at Time of
any Involuntary Termination’’), 94 (‘‘Net
Recovery Amount’’), 95 (‘‘Credit
Enhanced Amount’’), and 121 (‘‘Sales
Price of Property’’)) are available to
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report. If the data are available sooner,
the firm does not have to continue
reporting these loans in the following
months. Moreover, these fields should
only be reported for any portfolio or
private securitized loans that
experienced involuntary terminations.
Per the proposal, the Board will require
firms to carry involuntary liquidated
loans/lines up to 24 months to fully
populate all fields up until all the fields
are captured or 24 months. A firm does
not need to change its reporting
conventions for loans before and after
the involuntary liquidations. The Board
has adopted the revision as proposed.
The Board proposed to revise item 65
(‘‘Foreclosures Status’’) of Schedule A to
clarify that in the month a loan
liquidates, a firm should report the loan
as a post-sale foreclosure. One
commenter noted that a loan could have
moved from a post-sale foreclosure to
real estate owned in the month a loan
liquidates, and suggested the Board
clarify in the instructions that item 65
should be reported as of the month end
in the month the loan liquidates. The
Board notes that the instructions for this
item already require reporting as of the
end of the reporting month. However,
for clarification purposes, the Board is
revising the instructions to indicate that
if a loan was in foreclosure in the prior
month, and the loan liquidates during
the current month, then it should be
reported as a post-sale foreclosure.
The Board proposed to revise
Schedule A, item 59, and Schedule B,
item 43 (both ‘‘Principal and Interest
(P&I) Amount Current’’), to clarify that
firms should report the principal and
interest due from the borrower in the
reporting month, even in cases of
balloon loans that mature in the
reporting month. One commenter
pointed out that this clarification
contradicts other parts of these items
instructions, which state that a loan in
the process of paying off in a reporting
month can be reported with a value of
zero. As a result, the Board is revising
the instructions for these two items to
state that for balloon loans in the
process of paying off in a reporting
month, firms should report the full
amount due.
The Board proposed to add two new
items to Schedule B (items 118
(‘‘Charge-off Amount’’) and 119
(‘‘Charge-off Date’’)). A commenter
asked whether similar fields should
have been added to Schedule A. The
Board did not propose to add these
fields to Schedule A, as it does not need
this information for that loan
population.
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Schedule D (Domestic Credit Card)
The Board proposed to revise the
instructions for Schedule D to state if an
account at the time of closure or chargeoff had a positive unpaid balance that
needed to be repaid or recovered, then
information on that account should be
reported up to 24 months after the
closure or charge-off. Previously,
information on that account would have
only been reported up to 12 months
after the closure or charge-off. A
commenter noted that this requirement
should only be applied prospectively
due to the burden of retrieving data
from the past 24 months. The Board
notes that only a portion of recoveries
are realized within the first 12 months
after charge-off, and so moving to a 24
month window would portray a more
complete picture of applicable
recoveries. The Board notes that this
reporting change should only apply to
loans that have experienced a charge-off
or termination event within the past 12
months of the date of the revised
instructions. The Board has adopted this
revision as proposed.
The same commenter asked the Board
to clarify when closed accounts should
be excluded in cases when they have a
zero balances at closure and in cases
where they do not. The Board clarifies
that charge-off and non-charge off
accounts should be have a zero balance
reported in the month they close, and
should be excluded in the month after
they close. Accounts that have a balance
greater than zero when closed should be
reported up to 24 months after they
close.
The Board proposed to update the
instructions for items 17 (‘‘Managed
Recoveries’’) and 18 (‘‘Booked
Recoveries’’) on Schedule D to clarify
that all gross charge-offs, including
those related to acquired impaired
loans, should be included. One
commenter asked why charge-offs
should be included in amounts related
to recoveries. The Board is revising the
instructions to make it clear that these
items should be capturing the recovery
of the charged-off amount for acquired
impaired loans.
The Board proposed to add a clause
to the instructions for item 68
(‘‘Account Sold Flag’’) on Schedule D to
indicate that firms must start to report
this item from the sale announcement
date. The instructions were previously
ambiguous as to when to begin to report
this item. One commenter asked how
this item should be reported if the sale
has been announced but the accounts in
the portfolio to be sold have not yet
been finalized. The commenter asked
the Board to allow for firms to not report
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this item if the information needed to
report is not available as of the sale
announcement date. The Board needs
the information reported in this item as
soon as it is available in order to
adequately assess the risk effects of
portfolios that are in the process of
being sold, and so has adopted the
revision as proposed.
One commenter requested revising
the FR Y–14M to be reported quarterly
instead of monthly, citing reporting
burden of monthly filing as a rationale.
Monthly data collection allows the
Board’s financial models to be sensitive
to high-frequency changes in risk
drivers, and so the Board will continue
to require monthly data.
The Board did not propose revising
how retired fields on the FR Y–14M
should be reported. However, a
commenter requested the Board confirm
whether retired fields should be
removed from the report or remain in
the schedules but reported with null
values. The Board confirms that due to
previously received industry feedback
regarding the burden of renumbering
items, retired fields should continue to
reported and reported with null values.
CECL Proposal Comments
General
The Board proposed to add items and
update references to the FR Y–14
reports to incorporate CECL. One
commenter expressed concern that firms
would be required to produce additional
information in order to demonstrate
how their projections incorporating
CECL differ from what the projections
would have been under the incurredloss methodology, even if the firms
intend to retire their incurred-loss
models upon adoption of CECL and do
not intend to maintain parallel
processes. The commenter referenced
CCAR FAQ GEN0207,13 in which the
Board stated that firms should prepare
to submit documentation on the
methodology used to produce the
capital plan submission in accordance
with the capital plan rule. CCAR FAQ
GEN0207 further stated that examiners
may request any additional
documentation necessary to understand
and support the firm’s estimated
stressed capital insomuch as the firm
relied upon that information to create
and approve that plan. Per the response
to CCAR FAQ GEN0207, firms are not
required to maintain parallel
methodologies (i.e., CECL and incurredloss). Firms only need to provide
documentation on the methodology
13 https://www.federalreserve.gov/publications/
comprehensive-capital-analysis-and-reviewquestions-and-anwers.htm.
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used in their projections and capital
plans.
The Board received a comment
regarding whether the effective dates for
CECL filers will be revised based on
FASB’s recent proposal to delay CECL
effective dates for certain institutions
(FASB approved this proposal on
October 17, 2019).14 The Board had
initially proposed to remove incurredloss model items and references from
the FR Y–14 reports by March 31, 2022,
at the latest, as that was the anticipated
time by which all filers would have
adopted CECL. However, given this
extension, the Board is delaying the
removal of these items until March 31,
2023.
The Board received a comment asking
how the implementation of CECL would
impact the disclosure of DFAST/CCAR
results. The commenter points out that
the fundamental inconsistencies
between how the Board and
participating firms will calculate credit
loss allowances over the projection
horizon will present challenges in
comparing the risk profiles and capital
planning capabilities of firms. Further,
per the comment, stakeholders may
have difficulty evaluating and
understanding firms’ stress-test
disclosures, as well as the DFAST and
CCAR results, because of the different
methodologies used among firms and by
the Board. To avoid potential confusion
for stakeholders, the commenter
recommends that the Board explain in
its DFAST and CCAR results
publications that its projections for the
supervisory severely adverse scenario
are not comparable to firms’ projections
for the same scenario because of the
fundamentally different methodologies
used by the Board and firms to project
credit loss allowances, and that firms’
own projections may not be comparable
to one another’s because of differences
in how they incorporated CECL into
their projection methodologies. Finally,
the commenter recommends that to
further promote clear communication to
stakeholders and stakeholders’
understanding of the stress test results,
the Board should provide a template
disclosure that firms could include in
their own DFAST disclosures
explaining that their projections may
not be comparable to those of other
firms, and are not comparable to those
of the Board because of methodological
differences relating to the projections of
credit loss allowances. In response, the
Board understands the concerns posed
by the commenter, and will consider
14 https://www.fasb.org/jsp/FASB/Document_C/
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Disclaimer=true.
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this comment as part of its results
disclosure process.
FR Y–14A
General
In the initial proposal, the Board
mentioned that it would update
applicable reporting instructions to
account for the exclusion of
unconditionally cancelable
commitments from the allowance for
credit losses off-balance sheet
exposures. One commenter pointed out
that the Board did not make any such
revisions. The Board notes that the
reference to updating applicable
instructions should not have been made
in the initial proposal because the only
instructions that mention
unconditionally cancelable
commitments refer to the definition on
the FR Y–9C, and so no additional
updates were necessary.
Schedule A.1.a (Income Statement)
The Board proposed to add items that
capture the provisions, net charge-offs,
and allowances for held-to-maturity
(HTM) and available-for-sale (AFS) debt
securities to Schedule A.1.a. However,
the Board did not add items that capture
these fields for all other financial assets
that fall within the scope of CECL, such
as securities purchased under
agreements to resell and other assets.
One commenter pointed out that
without adding these items, net income
as reported on Schedule A.1.a would
not be accurate. The Board notes that
under the proposed instructions, net
income would not reconcile across the
FR Y–14 and FR Y–9C reports, and is
revising the form and instructions to
add applicable items to capture all other
financial assets that fall within the
scope of CECL.
Schedule A.1.b (Balance Sheet)
The Board proposed to revise the
instructions for ‘‘Other assets’’ (item
129) to change the FR Y–9C items
referenced in the definition.
Specifically, the Board proposed to
remove references to FR Y–9C, Schedule
HC (Balance Sheet), items 8
(‘‘Investments in unconsolidated
subsidiaries and associated companies’’)
and 9 (‘‘Direct and indirect investments
in real estate ventures’’). One
commenter noted that if the references
to items 8 and 9 were removed, then the
total assets balances would not
reconcile between the FR Y–14A and FR
Y–9C. The Board notes the total
balances would not reconcile under the
proposed revision, and is revising the
instructions to add back these
references.
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Schedule A.1.d (Capital)
The Board proposed several revisions
to Schedule A.1.d to mirror those made
to FR Y–9C, Schedule HC–R (Regulatory
Capital), Part I (Regulatory Capital
Components and Ratios), to incorporate
the adoption of CECL. One commenter
pointed out that in the proposed
revisions for item 54 (‘‘Allowance for
loan and lease losses includable in tier
2 capital’’), the Board did not properly
mirror the revisions to the equivalent
item on the FR Y–9C, Schedule HC–R,
Part I (item 30.a), in that it did not add
a clause to the instructions for item 54
specifying that firms should only
include the portion of allowance for
loan and lease losses (ALLL) or adjusted
allowances for credit losses (AACL) that
is includable in tier 2 capital, per the
regulatory capital rule. The Board notes
that this clause should be added to the
instructions, as only the ALLL or AACL
that is included in tier 2 capital should
be included in item 54, and is revising
the instructions for item 54 to use
language in the equivalent FR Y–9C
item.
The Board did not propose to revise
the instructions for item 96
(‘‘Supplementary leverage ratio
exposure’’) to state that firms that have
adopted ASU 2016–13 and have elected
to apply the transition provision should
incorporate the effects of this transition.
One commenter pointed out that per the
regulatory capital rules, the transitional
amount should also be applied to the
supplementary leverage ratio, and
suggested the Board revise the
instructions for item 96 to indicate so.
The Board confirms that the transitional
amount should be applied to the
supplementary leverage ratio. However,
the current instructions for item 96
directly reference the regulatory capital
rules, which describe the items to which
the transitional amount applies. Given
this, the Board does not believe any
further clarification is necessary.
The Board did not propose to add an
item to separately capture the AACL on
PCD assets on the FR Y–14. One
commenter asked the Board to confirm
it will not ask firms to provide this
information through a supplemental
request. The Board does not intend to
add an item to separately capture this
value on the FR Y–14.
Schedules A.3.f and A.3.g (Expected
Credit Loss and Provision for Credit
Loss—HTM and AFS Securities,
Respectively)
The Board proposed to add Schedules
A.3.f and A.3.g to capture allowance for
credit loss information on HTM and
AFS securities. One commenter asked
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whether the ‘‘Total allowance for credit
loss’’ items on both schedules should be
reported as of the prior quarter, the
current quarter, or a projected quarter.
The Board is revising the instructions to
clarify that these items should be
reported as of the report date (i.e.,
current quarter).
One commenter requested that the
Board specify what the ‘‘Expected loss’’
item in both schedules consists of,
whether it corresponds to any FR Y–9C
item, and how it differs from the
‘‘Provision for credit loss’’ item that is
also on both schedules. The ‘‘Expected
loss’’ item is the expected credit losses
as defined by ASU 2016–13 and before
applying the ‘‘fair value floor’’ that
limits the amount of the allowance for
credit losses to the amount by which
fair value is below amortized cost. This
item should equal FR Y–9C, Schedule
HI–B (Charge-offs and Recoveries on
Loans and Leases and Changes in
Allowances for Credit Losses), Part 2
(Change in Allowances for Credit
Losses), item 5 (‘‘Provision for credit
losses’’). To avoid confusion, the Board
is renaming the ‘‘Expected loss’’ item to
‘‘Expected credit loss before applying
the fair value floor,’’ and is revising the
instructions to indicate this as well.
Also in response to this comment, the
Board is removing the ‘‘Amortized cost
of securities intended to sell or will be
required to sell before recovery of
amortized cost’’ item from Schedule
A.3.g, as it is no longer necessary.
Finally, one commenter asked the
Board to confirm that the sum of
provision for credit loss items reported
on Schedules A.3.f and A.3.g should
equal proposed items 91.b (‘‘Provisions
for credit losses on held-to-maturity
debt securities during the quarter’’) and
91.c (‘‘Provisions for credit losses on
available-for-sale securities during the
quarter’’) on Schedule A.1.a,
respectively. The Board confirms these
values should be equal.
Collection of Supplemental CECL
Information
The Board proposed to add a
collection of supplemental CECL
information to be reported by
institutions that adopt ASU 2016–13
that captures the timing and impact of
CECL adoption as of December 31. This
collection would require firms to report
actual values (i.e., not projected) that
incorporate the adoption of CECL on the
FR Y–14A, in the stress test cycle year
of adoption. One commenter notes that
the collection of supplemental CECL
information would not require reporting
of information on the stressed impact of
CECL on either existing portfolios or on
newly originated exposures during the
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stress test horizon. The commenter is
also concerned that this proposed
collection would not provide the Board
with the insight it is seeking into the
stressed impacts of CECL since these
potential losses are important
components of overall CECL estimates.
The commenter further suggested that
the Board provide a description of the
relationship between each item on
Collection of Supplemental CECL
information and items on the FR Y–14A,
Summary sub-schedules. Finally, the
commenter pointed out that the
instructions for item 6 (‘‘Total
allowance for credit losses’’) refer to
sub-items 5.a and 5.b, which do not
exist.
The Board notes that it intends to
collect information of the day 1
unstressed impact; that is, the effect of
the change in accounting principles on
the effective date of CECL (i.e., not the
impact over the entire projection
horizon). The Board also notes that
because this collection is a pro-forma
estimate of the effect of the change in
accounting principles, there is no
relationship between items on this
schedule and other FR Y–14A items
corresponding to prior quarter end
financial statement data. The Board
believes that it will have sufficient data
under the collection to reflect the
impact of stress losses under CECL
accounting. Therefore, the Board has
adopted this revision as proposed,
except that it is revising the heading on
the form to make it clear that the Board
is asking for the effect of changes in
accounting principles, and it is revising
the instructions for item 6 to refer to the
sub-items of item 6. For clarification
purposes, the Board is also updating the
FR Y–14A instructions to include
language about when this schedule
should be filed and which items need to
be reported for certain firms.
FR Y–14Q
Schedule B (Securities)
The Board proposed to add two items
to Schedule B that would only be
completed by firms that have adopted
CECL (‘‘Amount of allowance for credit
losses’’ and ‘‘Writeoffs’’). One
commenter asked whether the Board
will specify that reporting debt
securities on a trade-lot level will
continue to apply to firms that have
adopted CECL if they calculate their
credit loss allowances for AFS debt
securities on security-level basis or for
HTM debt securities on either a
security-level or pool-level basis. The
Board is revising the instructions for
these two items to instruct firms that if
a given allowance measurement or
specific writeoff applies to more than
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70539
one row on the reporting form, to
allocate the allowances across the
relevant investments on a pro rata basis,
based on amortized cost.
The Board proposed instructions for
‘‘Writeoffs’’ to require firms to report
any writeoffs of the security during the
quarter. One commenter asked the
Board to clarify whether that means on
a quarter-to-date, year-to-date, or
lifetime-to-date basis. The Board is
revising the instructions to clarify that
this item should be reported on a
quarter-to-date basis.
Schedule D (Regulatory Capital)
The Board proposed minor revisions
to Schedule D in the CECL proposal, but
substantial revisions to the schedule in
the non-CECL proposal. Two firms
commented as to how to reconcile
revisions in the event that certain text
and items were eliminated in one
proposal but not the other. Since the
Board has adopted both proposals at the
same time, the combined instructions
document should clear up any
ambiguity. Further, the Board clarifies
that Schedule D should be reported by
all firms that file the FR Y–14Q, and not
just advanced approaches firms.
Schedule H (Wholesale)
The Board proposed to revise the
instructions to Schedule H.1, item 24
(‘‘Committed Exposure Global’’) to
require firms to report the total
commitment amount as the sum of loan
and lease financing receivables recorded
in FR Y–9C, Schedule HC–C (reported
in field 25—‘‘Utilized Exposure
Global’’) and any unused portion of the
commitment recorded in Schedules HC–
F (Other Assets), HC–G (Other
Liabilities), and HC–L (Derivatives and
Off-Balance Sheet Items). One
commenter said that this revision made
it unclear what to report in this item,
and recommended the Board clarify the
types of unused loan commitments that
should be reported instead of
referencing other FR Y–14Q or FR Y–9C
items. The Board does not believe
further clarification is necessary for two
reasons. First, the Schedule H
instructions already define the
reportable facilities. Second, the Board
believes it is better to leverage existing
instructions within or across reports in
order to reduce burden and improve
data accuracy. The Board has adopted
the revision as proposed.
The Board proposed to add additional
items to Schedules H.1 and H.2 that are
only reported by firms that have
adopted CECL. Two of these items,
‘‘ASC326–20’’ and ‘‘Purchased Credit
Deteriorated Noncredit Discount’’
(Schedule H.1—items 102 and 103;
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Schedule H.2—items 63 and 64,
respectively), require firms to report the
information at the credit facility level, if
available, or if not, at a pro-rated
allocation from the collective (pool)
basis. One commenter stated it was
unclear which basis should be used for
the proposed allocation. Further, the
commenter is concerned that without a
prescribed allocation methodology,
methods could vary broadly across
firms. Per the comment, this
inconsistency would weaken
comparability and reduce the value of
this schedule. Finally, the commenter
requested the Board remove the
requirements proposed in these two
items, and instead prescribe a clear
allocation methodology. The Board
believes that the reporting firm is in the
best position to determine the
appropriate allocation methodology,
and does not want to impose additional
burden by prescribing a single
allocation methodology. The Board has
adopted the revision as proposed.
FR Y–14M
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Generally, institutions subject to filing
the FR Y–14 reports would reflect the
CECL standard in data reported on the
FR Y–14A, FR Y–14Q, and FR Y–14M,
with as-of dates following the start of
the firm’s fiscal year and the adoption
of the standard, beginning with the FR
Y–14 reports as of December 31, 2019.
In the initial proposal, the Board
instructed firms to refer the final CECL
rule for specifics surrounding inclusion
of credit losses in a given stress test
cycle. One commenter asked if a firm
that adopts CECL January 1, 2020, could
report CECL-related FR Y–14M items on
a best effort basis for its January and
February 2020 FR Y–14M submissions.
The rationale for this request is that a
firm will be required to file other
regulatory reports reflecting CECL for
the first time as of March 31, 2020 (FR
Y–9C, FR Y–14Q, Securities and
Exchange Commission (SEC) reports,
etc.). In light of the concerns posed in
this comment, the Board is allowing
CECL-related FR Y–14M items to be
reported on a best effort basis for the
January and February 2020 submissions.
Board of Governors of the Federal Reserve
System, December 18, 2019.
Michele Taylor Fennell,
Assistant Secretary of the Board.
[FR Doc. 2019–27655 Filed 12–20–19; 8:45 am]
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FEDERAL RESERVE SYSTEM
Agency Information Collection
Activities: Announcement of Board
Approval Under Delegated Authority
and Submission to OMB
Board of Governors of the
Federal Reserve System.
SUMMARY: The Board of Governors of the
Federal Reserve System (Board) is
adopting a proposal to extend without
revision, the Notice of Branch Closure
(FR 4031; OMB No. 7100–0264).
FOR FURTHER INFORMATION CONTACT:
Federal Reserve Board Clearance
Officer—Nuha Elmaghrabi—Office of
the Chief Data Officer, Board of
Governors of the Federal Reserve
System, Washington, DC 20551, (202)
452–3829.
Office of Management and Budget
(OMB) Desk Officer—Shagufta
Ahmed—Office of Information and
Regulatory Affairs, Office of
Management and Budget, New
Executive Office Building, Room
10235, 725 17th Street NW,
Washington, DC 20503, or by fax to
(202) 395–6974.
A copy of the Paperwork Reduction
Act (PRA) OMB submission, including
the reporting form and instructions,
supporting statement, and other
documentation will be placed into
OMB’s public docket files. These
documents also are available on the
Federal Reserve Board’s public website
at https://www.federalreserve.gov/apps/
reportforms/review.aspx or may be
requested from the agency clearance
officer, whose name appears above.
SUPPLEMENTARY INFORMATION: On June
15, 1984, OMB delegated to the Board
authority under the PRA to approve and
assign OMB control numbers to
collections of information conducted or
sponsored by the Board. Boardapproved collections of information are
incorporated into the official OMB
inventory of currently approved
collections of information. Copies of the
PRA Submission, supporting
statements, and approved collection of
information instrument(s) are placed
into OMB’s public docket files.
Final Approval Under OMB Delegated
Authority of the Extension for Three
Years, Without Revision, of the
Following Information Collection:
Report title: Notice of Branch Closure.
Agency form number: FR 4031.
OMB control number: 7100–0264.
Frequency: On occasion.
Respondents: State member banks
(SMBs).
Estimated number of respondents:
Reporting: Regulatory notice, 91;
AGENCY:
PO 00000
Frm 00048
Fmt 4703
Sfmt 4703
Disclosure: Customer mailing, 91 and
posted notice, 91; Recordkeeping:
Adoption of policy, 1.
Estimated average hours per response:
Reporting: Regulatory notice, 2 hours;
Disclosure: Customer mailing, 0.75 hour
and posted notice, 0.25 hour;
Recordkeeping: Adoption of policy, 8
hours.
Estimated annual burden hours:
Reporting: Regulatory notice, 182 hours;
Disclosure: Customer mailing, 68 hours
and posted notice, 23 hours; and
Recordkeeping: Adoption of policy, 8
hours.
General description of report: The
reporting, recordkeeping, and disclosure
requirements regarding the closing of
any branch of an insured depository
institution are contained in section 42 of
the Federal Deposit Insurance Act (FDI
Act), as supplemented by an interagency
policy statement on branch closings.
There is no reporting form associated
with the reporting portion of this
information collection; SMBs notify
their appropriate Reserve Bank by letter
prior to closing a branch.
Legal authorization and
confidentiality: The FR 4031 is
authorized pursuant to Section 42(a)(1)
of the FDI Act and section 11 of the
Federal Reserve Act, which authorizes
the Board to require SMBs to submit
information as the Board deems
necessary.1 The reporting requirements
associated with FR 4031 are mandatory.
Generally, individual respondent data
submitted pursuant to the FR 4031 is
not considered to be confidential;
however, a SMB may request
confidential treatment pursuant to
exemption 4 of the Freedom of
Information Act, which protects trade
secrets and privileged or confidential
commercial or financial information.2
Current actions: On September 10,
2019, the Board published a notice in
the Federal Register (84 FR 47516)
requesting public comment for 60 days
on the extension, without revision, of
the FR 4031. The comment period for
this notice expired on September 12,
2019. The Board did not receive any
comments.
Board of Governors of the Federal Reserve
System, December 17, 2019.
Michele Taylor Fennell,
Assistant Secretary of the Board.
[FR Doc. 2019–27601 Filed 12–20–19; 8:45 am]
BILLING CODE 6210–01–P
1 12
25
U.S.C. 1831r–1(a)(1); 12 U.S.C. 248(a).
U.S.C. 552(b)(4).
E:\FR\FM\23DEN1.SGM
23DEN1
Agencies
[Federal Register Volume 84, Number 246 (Monday, December 23, 2019)]
[Notices]
[Pages 70529-70540]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-27655]
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FEDERAL RESERVE SYSTEM
Agency Information Collection Activities: Announcement of Board
Approval under Delegated Authority and Submission to OMB
AGENCY: Board of Governors of the Federal Reserve System.
ACTION: Approval of Information Collection.
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SUMMARY: The Board of Governors of the Federal Reserve System (Board)
is adopting two proposals to extend for three years, with revision, the
Capital Assessments and Stress Testing Reports (FR Y-14A/Q/M; OMB No.
7100-0341). The revisions are applicable with as of dates ranging from
December 31, 2019, to December 31, 2020. This final notice is adopting
two proposals previously published separately: One proposing to
incorporate current expected credit loss (CECL) methodology revisions
into the FR Y-14A/Q/M reports (CECL proposal), and the other proposal
to incorporate non-CECL methodology revisions into the FR Y-14A/Q/M
reports (non-CECL proposal).
FOR FURTHER INFORMATION CONTACT: Federal Reserve Board Clearance
Officer--Nuha Elmaghrabi--Office of the Chief Data Officer, Board of
Governors of the Federal Reserve System, Washington, DC 20551, (202)
452-3829.
Office of Management and Budget (OMB) Desk Officer--Shagufta
Ahmed--Office of Information and Regulatory Affairs, Office of
Management and Budget, New Executive Office Building,
[[Page 70530]]
Room 10235, 725 17th Street, NW, Washington, DC 20503, or by fax to
(202) 395-6974.
A copy of the Paperwork Reduction Act (PRA) OMB submission,
including the reporting form and instructions, supporting statement,
and other documentation will be placed into OMB's public docket files.
These documents also are available on the Federal Reserve Board's
public website at https://www.federalreserve.gov/apps/reportforms/review.aspx or may be requested from the agency clearance officer,
whose name appears above.
SUPPLEMENTARY INFORMATION: On June 15, 1984, OMB delegated to the Board
authority under the PRA to approve and assign OMB control numbers to
collections of information conducted or sponsored by the Board. Board-
approved collections of information are incorporated into the official
OMB inventory of currently approved collections of information. Copies
of the PRA Submission, supporting statements, and approved collection
of information instrument(s) are placed into OMB's public docket files.
Final Approval Under OMB Delegated Authority of the Extension for Three
Years, With Revision, of the Following Information Collection
Report title: Capital Assessments and Stress Testing Reports.
Agency form number: FR Y-14A/Q/M.
OMB control number: 7100-0341.
Effective dates: Ranges from December 31, 2019, to December 31,
2020.
Frequency: Annually, semi-annually, quarterly, and monthly.
Respondents: The respondent panel consists of U.S. bank holding
companies (BHCs), U.S. intermediate holding companies (IHCs) of foreign
banking organizations (FBOs), and covered savings and loan holding
companies (SLHCs) \1\ with $100 billion or more in total consolidated
assets, as based on: (i) the average of the firm's total consolidated
assets in the four most recent quarters as reported quarterly on the
firm's Consolidated Financial Statements for Holding Companies (FR Y-
9C); or (ii) if the firm has not filed an FR Y-9C for each of the most
recent four quarters, then the average of the firm's total consolidated
assets in the most recent consecutive quarters as reported quarterly on
the firm's FR Y-9Cs.\2\ Reporting is required as of the first day of
the quarter immediately following the quarter in which the respondent
meets this asset threshold, unless otherwise directed by the Board.
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\1\ SLHCs with $100 billion or more in total consolidated assets
become members of the FR Y-14A/Q/M panel effective June 30, 2020.
See 84 FR 59032 (November 1, 2019).
\2\ The Board had separately revised the respondent panel for
the FR Y-14 reports in connection with the Board's rule regarding
Prudential Standards for Large Bank Holding Companies and Savings
and Loan Holding Companies (the ``Tailoring Rule''). See 84 FR 59230
(November 1, 2019) and 84 FR 50932 (November 1, 2019). Under the
Tailoring Rule, the respondent panel for the FR Y-14 reports is BHCs
with total consolidated assets of $100 billion or more, IHCs with
total consolidated assets of $50 billion or more that are
subsidiaries of an FBO, and covered SLHCs with $100 billion or more
in total consolidated assets. See 12 CFR 217.2 (defining ``covered
savings and loan holding company'').
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Estimated number of respondents: FR Y-14A: 35; FR Y-14Q: 35; \3\ FR
Y-14M: 33.
---------------------------------------------------------------------------
\3\ The estimated number of respondents for the FR Y-14M is
lower than for the FR Y-14A and FR Y-14Q because, in recent years,
certain respondents to the FR Y-14A and FR Y-14Q have not met the
materiality thresholds to report the FR Y-14M due to their lack of
mortgage and credit activities. The Board expects this situation to
continue for the foreseeable future.
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Estimated average hours per response: FR Y-14A: 1,030 hours; FR Y-
14Q: 1,944 hours; FR Y-14M: 1,075 hours; FR Y-14 Implementation and On-
going Automation Revisions, 540 hours; FR Y-14 Attestation On-going
Audit and Review, 2,560 hours.
Estimated annual burden hours: FR Y-14A: 72,100 hours; FR Y-14Q:
272,160 hours; FR Y-14M: 425,700 hours; FR Y-14 On-going Automation
Revisions, 18,900 hours; FR Y-14 Attestation On-going Audit and Review,
33,280 hours.
General description of report: This family of information
collections is composed of the following three reports:
The semi-annual FR Y-14A collects quantitative projections
of balance sheet, income, losses, and capital across a range of
macroeconomic scenarios and qualitative information on methodologies
used to develop internal projections of capital across scenarios.\4\
---------------------------------------------------------------------------
\4\ In certain circumstances, a BHC or U.S. IHC may be required
to re-submit its capital plan. See 12 CFR 225.8(e)(4). Firms that
must re-submit their capital plan generally also must provide a
revised FR Y-14A in connection with their resubmission.
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The quarterly FR Y-14Q collects granular data on various
asset classes, including loans, securities, trading assets, and pre-
provision net revenue (PPNR) for the reporting period.
The monthly FR Y-14M is comprised of three retail
portfolio- and loan-level schedules, and one detailed address-matching
schedule to supplement two of the portfolio and loan-level schedules.
The data collected through the FR Y-14A/Q/M reports provide the
Board with the information needed to help ensure that large firms have
strong, firm-wide risk measurement and management processes supporting
their internal assessments of capital adequacy and that their capital
resources are sufficient given their business focus, activities, and
resulting risk exposures. The reports are used to support the Board's
annual Dodd-Frank Act Stress Test (DFAST) and Comprehensive Capital
Analysis and Review (CCAR) exercises, which complement other Board
supervisory efforts aimed at enhancing the continued viability of large
firms, including continuous monitoring of firms' planning and
management of liquidity and funding resources, as well as regular
assessments of credit, market and operational risks, and associated
risk management practices. Information gathered in this data collection
is also used in the supervision and regulation of respondent financial
institutions. Compliance with the information collection is mandatory.
Legal authorization and confidentiality: The Board has the
authority to require BHCs to file the FR Y-14 reports pursuant to
section 5 of the Bank Holding Company Act (``BHC Act'') (12 U.S.C.
1844), to require SLHCs to file the FR Y-14 reports pursuant to section
10 of the Home Owners' Loan Act (12 U.S.C. 1467a(b)), and to require
the U.S. IHCs of FBOs to file the FR Y-14 reports pursuant to section 5
of the BHC Act, in conjunction with section 8 of the International
Banking Act (12 U.S.C. 3106). The FR Y-14 reports are mandatory.
The information collected in these reports is collected as part of
the Board's supervisory process, and therefore is afforded confidential
treatment pursuant to exemption 8 of the Freedom of Information Act
(``FOIA'') (5 U.S.C. 552(b)(8)). In addition, individual respondents
may request that certain data be afforded confidential treatment
pursuant to exemption 4 of the FOIA, which exempts from disclosure
``trade secrets and commercial or financial information obtained from a
person [that is] privileged or confidential'' (5 U.S.C. 552(b)(4)).
Determinations of confidentiality based on FOIA exemption 4 would be
made on a case-by-case basis.
Current actions: On July 31, 2019, the Board published two notices
in the Federal Register (84 FR 37285 and 84 FR 37292) requesting public
comment for 60 days on the extension, with revision, of the Capital
Assessments and Stress Testing Reports. The Board proposed to implement
a number of changes to schedules of the FR Y-14A,
[[Page 70531]]
FR Y-14Q, and FR Y-14M reports. The proposed revisions consisted of
deleting or adding items, adding or expanding schedules or sub-
schedules, and modifying or clarifying the instructions for existing
data items, primarily on the FR Y-14Q and FR Y-14M reports. The Board
proposed most of these changes in an effort to reduce reporting burden
for firms, clarify reporting instructions and requirements, address
inconsistencies between the FR Y-14 reports and other regulatory
reports, and to account for revised rules and accounting principles. A
limited number of proposed revisions would have modified the reporting
requirements and added or expanded sub-schedules to improve the
availability and quality of data to enhance supervisory modeling and
for use in DFAST.
The proposed revisions also were meant to address revised
accounting for credit losses under the Financial Accounting Standards
Board's (FASB) Accounting Standards Update (ASU) No. 2016-13,
``Financial Instruments--Credit Losses (Topic 326): Measurement of
Credit Losses on Financial Instruments'' (ASU 2016-13) and implement
the CECL accounting methodology across all of the FR Y-14 reports. The
proposed changes to the FR Y-14 reports paralleled the related changes
to the Consolidated Financial Statements for Holding Companies (FR Y-
9C) for CECL, as appropriate.\5\ The proposed reporting changes related
to CECL also were consistent with the revisions indicated in the
interagency final rule that incorporated the CECL transition.\6\
---------------------------------------------------------------------------
\5\ See 84 FR 11783 (March 28, 2019).
\6\ See 84 FR 4222 (February 14, 2019).
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The comment period for the two notices regarding the Capital
Assessments and Stress Testing Reports expired on September 30, 2019.
The Board received four comment letters from banking organizations and
one comment letter from a banking industry group on its non-CECL
proposal. The Board received one comment letter from a banking
organization and one comment letter from a banking industry group on
its CECL proposal. All comments and responses are delineated below
based on whether the comment was related to the non-CECL or CECL
proposal.
Detailed Discussion of Public Comments
Timing of Proposed Changes
The Board proposed that all revisions associated with these
proposals to be effective for September 30, 2019. Four commenters
stated that those revisions should be delayed so that there would be
time for FR Y-14 filers to set up or update, as well as adequately
test, their internal reporting systems to adopt the reporting changes.
For the FR Y-14A, two commenters suggested adjusting the effective date
for most of the revisions to December 31, 2019, with the exception of
the proposals to eliminate the deposit funding threshold from the PPNR
schedule and to require IHCs to provide a cost allocation as a
supplement to their PPNR schedules, which two commenters proposed to
become effective December 31, 2020. Another commenter suggested that
all revisions associated with FR Y-14A become effective December 31,
2020. For the FR Y-14Q, two commenters suggested adjusting the
effective date to delay most of the revisions to December 31, 2019,
with the exception of certain proposed changes to the Counterparty
(Schedule L), Trading (Schedule F), and Retail (Schedule A) schedules,
which the commenters suggested to delay until June 30, 2020. One
commenter suggested delaying all proposed revisions associated with the
FR Y-14Q to March 31, 2020. Finally, for the FR Y-14M, three commenters
suggested delaying all proposed revisions to become effective March 31,
2020.
In light of the rationale for delaying implementation to allow
firms adequate time to set up, update, and test their internal systems,
as well as due to the fact that the proposed effective date has already
passed, the Board has revised the effective date from September 30,
2019, to dates ranging from December 31, 2019, to December 31, 2020,
for different aspects of the proposal. The December 31, 2019, date was
chosen as some revisions are necessary for the DFAST 2020 stress test
cycle, and so could not have been delayed to a later date. The
effective dates for the other revisions were chosen as a balance
between data needed by the Board and industry burden.
Timing of Non-CECL Revisions
For non-CECL revisions associated with the FR Y-14A, all revisions
will be effective for December 31, 2020, except the revisions to
schedule A.1.d (Capital), the revisions to schedule A.2.a (Retail
Balance and Loss Projections), the revisions to schedule A.4 (Trading),
and the revisions made to conform to changes previously made to the FR
Y-9C. The revisions to schedule A.1.d, A.2.a, and A.4 will be effective
for December 31, 2019, as they are critical for the DFAST 2020 stress
test cycle.
For non-CECL revisions associated with the FR Y-14Q, all revisions
will be effective for March 31, 2020, with the exception of the
revisions to Schedule D (Regulatory Capital), the addition of the fair
value option (FVO) hedges sub-schedule to Schedule F (Trading), certain
revisions to Schedule H (Wholesale), the elimination of Schedule I
([Mortgage Servicing Rights] MSR Valuation Schedule), and the revisions
made to conform to changes previously made to the FR Y-9C, which will
be effective for December 31, 2019, as well as the revisions to the
Counterparty schedule, which will be effective for June 30, 2020. The
non-CECL FR Y-14Q revisions that are effective for December 31, 2019,
are needed then because they are critical for the DFAST 2020 stress
test cycle. For the December 31, 2019, as of date, the Board will allow
firms to submit the FVO hedges sub-schedule to Schedule F by March 6,
2020, as opposed to the February due date for the rest of the FR Y-14Q.
The Board recognizes that one commenter requested delaying proposed
revisions to the Trading schedule and the proposal to add a weighted-
average life (WAL) segment variable to the Retail schedules to June 30,
2020. However, the Board feels that extending the effective date by six
months will provide adequate time to set up or update, as well as
adequately test, pertinent internal systems. In addition, firms already
provide a WAL item on the FR Y-14A, PPNR schedule (schedule A.7) at the
portfolio level. The instructions for the new WAL item at the loan
segment level are similar to the existing WAL items on the PPNR
schedule, and so the Board has added the item as proposed, except with
a March 31, 2020, effective date.
For non-CECL revisions associated with the FR Y-14M, all revisions
will be effective for March 31, 2020.
Timing of CECL Revisions
As indicated in the final CECL rule and as outlined in FR Y-14 CECL
proposal, an institution may reflect the adoption of ASU 2016-13 on the
FR Y-14 reports beginning with the 2020 stress test cycle. Therefore,
all CECL-related items need to be incorporated into the FR Y-14 reports
for December 31, 2019.
Consistency of Numbering Across the Two Proposals
The Board also received several comments about inconsistent
numbering of items across the FR Y-14 reports between the non-CECL and
CECL proposals. Since the Board is adopting both proposals at once, the
[[Page 70532]]
numbering is consistent in the forms and instructions provided with
this notice.
Non-CECL Proposal Comments
General
The Board issues technical instructions so firms know how to
configure their systems and files to submit the FR Y-14A and FR Y-14Q.
One commenter asked for the Board to provide these technical
instructions before year-end 2019 so firms have sufficient time to make
any necessary adjustments. The Board seeks to provide firms technical
instructions in a timely manner, and seeks to do so with respect to the
technical instructions for these reporting changes.
FR Y-14A
Schedule A.1.d (Capital)
The Board proposed to revise the instructions to the FR Y-14A to
provide guidance on how firms should reflect the impact of the ``global
market shock'' \7\ on items subject to adjustment or deduction from
capital. Specifically, if a firm were to adjust its projection of an
item to reflect the impact of the global market shock, the instructions
would indicate that the firm must also report an adjusted starting
value that reflects the global market shock for applicable items. One
commenter questioned whether this revision conflicts with guidance
previously issued through a CCAR frequently asked question (FAQ
SHK0030),\8\ in which the Board stated that firms should not assume a
related decline in portfolio positions or risk-weighted assets as a
result of global market shock losses. Another commenter suggested that
this treatment is a significant policy question that should be
separately clarified by the Board. The Board notes that the proposed
revisions reflect a departure from the guidance issued in FAQ SHK0030.
In the past, the Board required firms to report capital using post-
stress losses, but pre-stress values of certain capital deductions. The
Board is now requiring firms to adjust their capital deductions to
reflect the impact of the global market shock in order to make their
capital calculation further reflect post-stress values.\9\ The Board
has adopted this revision as proposed. To mitigate confusion, the Board
is rescinding FAQ SHK0030, as that historical guidance is inconsistent
with the new instructions.
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\7\ The global market shock is a set of instantaneous,
hypothetical shocks to a large set of risk factors. Generally, these
shocks involve large and sudden changes in asset prices, interest
rates, and spreads, reflecting general market dislocation and
heightened uncertainty. The global market shock impacts the Trading
and Counterparty schedules of the FR Y-14A and FR Y-14Q.
\8\ https://www.federalreserve.gov/publications/comprehensive-capital-analysis-and-review-questions-and-anwers.htm.
\9\ See 84 FR 6664 (April 1, 2019) for more information on
disclosure methodology.
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The Board proposed to rename item 109 (Potential net operating loss
carrybacks) to ``Taxes previously paid that the bank holding company
could recover if the bank holding company's temporary differences (both
deductible and taxable) fully reverse at the report date.'' The Board
also proposed to revise the instructions for this item to state that
firms should report the amount of taxes previously paid that the firm
could recover through loss carrybacks if the firm's temporary
differences (both deductible and taxable) fully reverse at the report
date. The Board proposed these revisions to reflect provisions in the
Tax Cuts and Jobs Act (TCJA) that changed the treatment of deferred tax
assets (DTAs).\10\ One commenter pointed out that the revisions to this
item did not include taxes previously paid that the firm could recover
through carrybacks of projected negative taxable income (i.e., net
operating loss and credits) over the planning horizon. The commenter
further noted that, although the TCJA eliminated net operating loss
(NOL) carrybacks in the U.S., certain carrybacks are still allowed
(e.g., credits and capital losses in U.S., as well as NOL carrybacks in
various jurisdictions like the United Kingdom and certain U.S. states).
The commenter requested the Board rename item 109 as a result. To
better reflect the applicable provisions of the TCJA, the Board is
renaming item 109 to ``Taxes previously paid that the bank holding
company could recover through allowed carrybacks if the bank holding
company's DTAs on net operating loss, tax credits and temporary
differences (both deductible and taxable) fully reverse at the report
date,'' and is revising the instructions accordingly.
---------------------------------------------------------------------------
\10\ Public Law 115-97, 131 Stat. 2054 (2017).
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Schedule A.2.a (Retail Balance and Loss Projections)
CECL replaced the concept of purchased credit-impaired (PCI) with
that of purchased credit-deteriorated (PCD). As a result, the Board
proposed to revise FR Y-14A, Schedule A.2.a, to include PCD breakouts
for all mortgage categories. One commenter pointed out that the draft
instructions provided with the proposal specify that these new PCD
fields only apply to home equity items. Consistent with the language
used in the description of the initial proposal, the intent of the
proposal was to make these fields applicable to all mortgage line
items. The Board is revising the instructions accordingly.
Schedule A.7 (Pre-Provision Net Revenue (PPNR))
The Board proposed eliminating the deposit funding threshold for
the FR Y-14A, Schedule A.7.b (Net Interest Income), which is currently
optional for firms with deposits comprising less than 25 percent of
total liabilities for any period reported in any of the four most
recent FR Y-14Q reports. For the reports as of June 30, 2016, the
deposit-funding threshold was eliminated from the FR Y-14Q, Schedule G
(PPNR). Two commenters said that removing this threshold would impose
significant burden on the small subset of firms that are not currently
required to report this schedule. The commenters recommended that the
Board postpone this revision until December 31, 2020, so that firms
that are not currently required to file have ample time to set up and
adequately test their reporting systems. Given the time necessary for
these firms to set up and adequately test their reporting systems, the
Board has adopted the revision and has postponed implementation until
December 31, 2020.
The Board proposed adding further specification surrounding the
requirements for supporting information provided by U.S. IHCs.
Specifically, the proposal would add instructions to the supporting
documentation requirements clarifying that IHCs with material transfer
pricing or cost allocation items with related entities should report
these revenues and expenses in the appropriate business-line category,
rather than the ``other'' category. In addition, the proposal would
have required U.S. IHCs to provide supporting documentation that
disaggregates the impact of transfer pricing and cost allocations on
revenue and expense projections to allow the Board to understand the
revenue impact of these arrangements.
Two commenters said there would have been insufficient time for
IHCs to provide the proposed cost allocation breakout items for
September 30, 2019, as these firms are still in the early stages of
shared cost structures. Both commenters proposed delaying
implementation of these revisions until December 31, 2020. One
commenter further requested that the Board provide additional
clarification on the proposed change regarding the granularity required
for the cost allocation, and that this information not be required for
[[Page 70533]]
stressed scenarios as that would require substantial investment in
IHCs' models. Given the concerns posed by the commenters, the Board has
provided clarification regarding cost allocation in the FR Y-14A
instructions, has added this clarifying language to the FR Y-14Q,
Schedule G instructions, and has delayed implementation until December
31, 2020. The Board believes this new effective date provides
sufficient time for IHCs to gather the necessary information.
The Board proposed to revise several items on the PPNR schedules of
the FR Y-14A and FR Y-14Q (Schedule G) to indicate how dividend income
on equity products should be reported. The proposed revisions were
intended to align with reporting on the FR Y-9C. In doing this, the
Board proposed that dividend income on equity products with readily
determinable fair values not held for trading be reported as interest
income and that dividend income on equity products held for trading be
reported as noninterest income. One commenter pointed out that the FR
Y-9C is not explicit as to how dividend income on equity products
should be reported. The commenter also pointed out that items impacted
by these revisions flow through to other PPNR items, specifically those
that relate to the earned average rate of trading assets. The Board
notes that, under the proposal, the reporting of dividend income on
equity products may not be consistent between the FR Y-9C and the FR Y-
14, as the FR Y-9C instructions are not explicit as to how this income
should be reported. As a result, the Board has revised the language for
item 5B (``Other [sales and trading interest income]'') on the FR Y-
14A, Schedule A.7.a and FR Y-14Q, Schedule G.1, to include equity
trading activity not reported in item 5A (Prime Brokerage [sales and
trading noninterest income]), instead of a direct reference to dividend
income on equity products with readily determinable fair values not
held for trading. The Board has also revised the language for item 18C
(``Other [sales and trading noninterest income]'') on Schedules A.7.a
and G.1 to remove references to dividend income on equity securities
held for trading.
The Board proposed to revise item 15 (``Other Interest/Dividend-
Bearing Assets'') on FR Y-14A, Schedule A.7.b and FR Y-14Q, Schedule
G.2, to include balances from equity securities with readily
determinable fair values not held for trading. One commenter pointed
out that this is not consistent with the FR Y-9C, in which equity
securities with readily determinable fair values are reported as ``All
other debt securities and equity securities with readily determinable
fair values not held for trading purposes'' (item 1.c), and not as
``Other earning assets'' (item 4.b), on Schedule K (Quarterly
Averages). Given this, the commenter recommended moving balances from
equity securities with readily determinable fair values not held for
trading from item 15 to item 12 (``Securities AFS and HTM--Other'').
The Board notes that item 12 is a more appropriate location for equity
securities with readily determinable fair values not held for trading,
as they share more risk characteristics with non-equity securities than
with other earning assets. As a result, the Board is updating the
instructions accordingly.
The Board proposed to revise the PPNR schedules of the FR Y-14A and
FR Y-14Q, as well as Schedule A (Retail) of the FR Y-14Q, so that loans
(and associated income) in U.S. territories (including Puerto Rico)
would be treated as international. The intent of this proposal was to
align the reporting of loans in U.S. territories between the FR Y-14
and the FR Y-9C. However, one commenter pointed out that the reporting
of these loans is more nuanced on the FR Y-9C, as the treatment can
differ within and across schedules, and so the proposed FR Y-14
revisions would still result in inconsistencies between the items on
the PPNR schedules and similar items on the FR Y-9C. In response, the
Board is revising the proposed instructions to the PPNR schedules to
require firms to refer to the FR Y-9C for the definition of domestic
and international. This will result in the classification of loans as
international or domestic on the FR Y-14 PPNR schedules truly aligning
with those of the FR Y-9C.
For the FR Y-14Q, Schedule A (Retail), the Board proposed to remove
an exception for loans in U.S. territories from the international loan-
reporting requirement. However, in contrast to the PPNR schedules, the
existing instructions for Schedule A already directed firms to refer to
the FR Y-9C definitions for international and domestic for applicable
loan categories. Therefore, the Board has adopted the revisions to the
FR Y-14Q, Schedule A (Retail), as proposed, so that the definitions of
international and domestic align, without exception, with those on the
FR Y-9C.
Schedule E (Operational Risk)
The Board proposed several revisions to Schedule E.2 (Material Risk
Identification), one of which was to rename the ``Risk segment''
variable to ``Business line(s)/firm-wide.'' One commenter pointed out
that the name ``Risk segment'' provided a clear linkage to FR Y-14A,
Schedule A.6 (BHC or IHC Operational Risk Scenario Inputs and
Projections), as this schedule also had a variable named ``Risk
segment.'' The commenter asked whether the Board still expects this
clear linkage despite the name change. The Board notes that the
proposed revisions to Schedule E.2 allow for better linkage between the
categories of the difference schedules, as firms will now have to
identify and list the methodology used to estimate operational risk
model. The Board has adopted the revisions as proposed.
FR Y-14Q
Schedule D (Regulatory Capital)
The Board proposed to eliminate most items on Schedule D, as they
are duplicative of reporting elsewhere because the common equity tier 1
(CET1) capital deductions are now fully phased-in. One commenter asked
for clarification as to whether the proposed changes to Schedule D
apply to all firms, or only to non-advanced approaches firms. The Board
notes that the changes apply to all firms that file the FR Y-14Q, as
there are no exemptions listed in the proposed instructions.
While the Board proposed to eliminate most of the items on Schedule
D, it did retain a limited number of items that are not reported
elsewhere and proposed to add a handful of items relating to non-
significant investments subject to a threshold deduction from CET1
capital. One commenter asked how one of the new items (item 15--``DTAs
arising from temporary differences, net of DTLs'') differs from a
retained item (item 18--``DTAs arising from temporary differences that
could not be realized through net operating loss carrybacks, net of
related valuation allowances and net of DTLs''). The difference between
these two items is that item 15 is reported before netting of
carrybacks and valuation allowance, whereas item 18 is inclusive of
valuation allowance and carryback netting. The Board believes this
reporting is clear based on the instructions, and has adopted the
revisions as proposed.
The Board proposed to add a new memoranda item to Schedule D (item
M1--``Taxes paid through the as-of date of the current fiscal year'').
The instructions for this item require respondents to report the amount
of taxes paid during the current fiscal year through the as-of date
that are included in Schedule D, item 17, ``Potential net
[[Page 70534]]
operating loss carrybacks,'' assuming that fiscal years align with
calendar years. One commenter asked whether the data from this item can
be appropriately sourced from FR Y-9C, Schedule HI (Income Statement),
item 9 (Applicable income taxes (foreign and domestic)). The Board
notes that, based on the instructions for item M1, firms should only
report income taxes paid that are included in item 17, which may not
equal the income taxes reported in FR Y-9C, Schedule HI, item 9. The
Board has adopted the revisions as proposed.
Schedule F (Trading)
The Board proposed to delineate reporting of private equity
investments between those reported at fair value and those reported
using accounting methods other than fair value (non-fair value). Two
commenters asked the Board to clarify whether the intended population
of the private equity investments reported at fair value includes
investments required to be held at fair value, as well as (1)
investments in which FVO accounting treatment has been elected and (2)
fund positions measured at net asset value (NAV). In response, the
Board notes that the intended population of the private equity
investments reported at fair value consists of investments required to
be reported at fair value, including investments where fair value is
estimated using NAV or where FVO has been elected. The commenters also
suggested excluding all non-fair value investments from Schedule F
because they believe the macro scenario is more appropriate than the
global market shock scenario for capital planning purposes for these
positions. The Board notes that private equity is the only asset type
where non-fair value exposures are required to be reported on Schedule
F. Further, the Board notes that fair value and non-fair value private
equity investments have different risk characteristics, and so believes
it is essential that these exposures are separately reported. Since the
Board now has a breakout between fair value and non-fair value private
equity investments, the Board will be able to assess whether the macro
scenario is more appropriate than the global market shock for non-fair
value exposures. If the macro scenario is more appropriate, then the
Board will propose an alternative treatment in a future notice.\11\ The
Board has adopted the revisions as proposed.
---------------------------------------------------------------------------
\11\ See 84 FR 6664 (February 28, 2019) for more information
about the Federal Reserve's model development and validation
practices.
---------------------------------------------------------------------------
The Board proposed to add a sub-schedule that captures FVO loan
hedges. One commenter asked the Board to expand this sub-schedule to
include all non-trading hedges, regardless of accounting treatment, as
including these hedges would portray a more accurate picture of risk
and because it may be difficult for firms to segment hedging activity
that is directly correlated to a specific accounting treatment. The
Board has been collecting FVO loan hedge information as a supplement to
the supervisory stress test for several years, and this proposal was a
formalization of this supplemental collection. FVO loan hedge
information is critical to adequately assessing the risks posed by FVO
loans. Without this information, the Board would have no way to
determine whether firms are mitigating FVO loan risks through hedging.
The Board has adopted the revisions as proposed, and will consider
expanding the sub-schedule in a future proposal. The same commenter
asked the Board to clarify whether the as-of date the FVO loan hedges
sub-schedule should be at quarter end. Consistent with the instructions
published with the initial proposal, the as-of date for the FVO loan
hedges sub-schedule is quarter end.
One commenter asked whether the Board could provide examples of
what should be included in the FVO loan hedge sub-schedule. The Board
is revising the instructions to add a non-exhaustive list of examples
of what should be included in this sub-schedule.
The Board proposed to exclude mandated investments, such as those
in government or government-sponsored entities and stock exchanges,
from Schedule F. One commenter asked the Board to further clarify the
definition of mandated investments. The Board believes the proposed
definition is sufficient, and therefore has adopted the revisions as
proposed. The Board encourages firms to seek guidance from the Federal
Reserve if they have specific questions related to bespoke investments.
The Board did not propose to revise the list of examples for what
to include the Other Fair Value Assets Sub-schedule that is currently
in the instructions. However, due to the placement of the list in the
instructions, one commenter asked that the Board clarify whether the
list applies only to the Other Fair Value Assets sub-schedule. The
Board is revising the instructions to make it clear that this list
applies only to the Other Fair Value Assets sub-schedule.
Schedule H (Wholesale)
The Board proposed to add two additional Schedules, H.3 (Line of
Business) and H.4 (Internal Risk Rating Scale), which would allow for
mapping of each firm's internal risk ratings and line of business
values to a consistent benchmark for use in modeling. One commenter
suggested the Board expand Schedule H.4 to ask for additional items,
such as probability of default information. The commenter also
suggested expanding Schedule H.4 to correspond to FR Y-14Q, Schedule L
(Counterparty), instead of just Schedule H, as both schedules require
an internal and external rating equivalent factor. At this time, the
Board does not need any additional fields on these schedules, but will
consider expanding Schedule H.4 as part of a future proposal.
Additionally, the Board will not expand Schedule H.4 to correspond with
the Counterparty schedule at this time, as the data between the two
schedules do not readily align.
The Board proposed to revise Schedule H.1 (Corporate Loan Data),
item 25 (``Utilized Exposure Global''), and Schedule H.2 (Commercial
Real Estate), item 3 (``Outstanding Balance''), to align reporting with
the FR Y-9C definition of loan and lease financing receivables. This
would cause the exposure amounts reported in Schedule H.1, item 25, and
Schedule H.2, item 3, to be netted by deferred fees and costs. One
commenter stated that while this would align with the FR Y-9C, firms
would need significant time to accurately implement these revisions,
and requested the proposal be dropped or delayed. These two fields are
critical for modeling, and the Board believes that aligning the
definitions between the FR Y-14Q and FR Y-9C will enhance reporting
accuracy and improve clarity. The Board also acknowledges that unlike
the FR Y-9C, the Wholesale schedule is reported at the facility level,
and so firms need time to adequately capture the deferred fees and
costs. Therefore, the Board has adopted the revisions as proposed, but
is delaying implementation until December 31, 2019, so that these
fields can be updated in time for CECL implementation on the FR Y-14Q,
as these fields are critical for CECL.
The Board proposed to revise the line of business items (Schedule
H.1, item 27; Schedule H.2, item 22) to not require that the line of
business be reported at origination, as they typically change over
time. One commenter requested the Board expand the description of these
items to clarify that the current line of business should be reported.
The Board
[[Page 70535]]
believes its proposed revision captures this point because firms will
no longer be required to report the line of business at origination,
and is more consistent with the existing instructions for other items.
The Board has adopted the revision as proposed.
The Board proposed to revise several Schedule H items to align with
the definition of loans and lease financing receivables on the FR Y-9C.
One commenter noted that the Board should also align the definition of
major modification in origination date fields of Schedules H.1 and H.2
(items 18 and 10, respectively), with that of the FR Y-9C. While the
Board strives to align reporting definitions when appropriate, the
definition of a major modification on Schedule H is much broader than
that of the FR Y-9C and is used to assess whether there has been a
change in the origination date for all types of loans. The Board does
not believe it is appropriate to use the FR Y-9C or GAAP definition of
``modification'' because this definition is mainly associated with
troubled debt. The Board has adopted the revision as proposed.
The Board proposed to revise the definition of ``country'' on
Schedule H.1 (item 6) to refer to the definition of ``domicile,'' as
defined in the FR Y-9C glossary. One commenter suggested the Board also
revise Schedule H.1, items 5 (``City'') and 7 (``Zip Code''), to
reference the borrower's domicile in assigning the obligor's country in
Schedule H.1, (item 6). The Board strives to align the definitions of
related items where applicable, and so is revising the instructions
accordingly.
The Board proposed to revise the maturity date fields of Schedules
H.1 and H.2 (item 19 for both) to eliminate the implied requirement to
test compliance with the terms of the credit agreement each quarter.
One commenter asked whether this revision means that firms would now
have to factor in the extension options that are solely at the
discretion of the borrower from inception, or alternatively, whether it
means that the extended date is only reported during the extension
option window provided that the borrower has requested an extension and
an assessment has been made that the conditions outlined in the
agreement have been complied with. The Board has adopted the proposed
revisions to the maturity date fields, which is inclusive of all
extension options that are solely at the borrower's discretion
regardless of the timing of the extension option window, including
extension options that are conditional on certain terms being met
without any need to assess compliance with the terms of the credit
agreement.
The Board proposed to add items 65 (``Committed Exposure Global
Fair Value'') and 66 (``Outstanding Balance Fair Value'') to Schedule
H.2. One commenter questioned whether these two new items were
capturing duplicative information, as items 5 (``Committed Exposure
Global'') and 3 (``Outstanding Balance''), respectively, seem to
capture similar information for held-for-sale and FVO exposures. The
Board notes that Schedule H.2, items 5 and 3, represent different
concepts from the newly-proposed fair value items 65 and 66. Although
there may be cases where values in items 5 and 3 coincide with the
values in the newly proposed fair value items (65 and 66,
respectively), in other instances the values may differ between these
fields (specifically for held-for-sale (HFS) loans reported at lower of
cost or fair value, when amortized cost is lower than fair value). The
Board has adopted the revisions as proposed.
The Board proposed to add several fields related to committed
exposure and utilized exposure global par values, as well as fair
values, to Schedules H.1 (items 102 through 105) and H.2 (items 63
through 66). One commenter had several questions about these new items.
First, the commenter wanted the Board to clarify whether firms should
report their share of the global commitments or the total global
commitment of the entire facility. The Board notes that firms are
expected to report their pro-rata commitments in the committed exposure
fields. The pro-rata share is net of adjustments that are noted in the
FR Y-14Q instructions. The ``Committed Exposure Global'' fields should
include the total commitment amount, including any unused portfolio of
the commitment. Second, the commenter asked how to report these items
for facilities that include held-for-sale loans or loans accounted for
under a fair value option and held-for-investment loans. The Board
notes that for loans reported in Schedule H.1, if the firm reports a
value of 3 (``NA'') in the ``Lower of Cost or Market Flag'' (item 86),
then it should report ``NA'' for items 102 (``Committed Exposure Global
Par Value'') and 103 (``Utilized Exposure Global Par Value''). In cases
where there are multiple loans in the same facility, firms should
report the consolidated exposure based on the accounting type for loans
that make up the predominant share of the facility. Third, the
commenter asked whether firms should continue to report commitment
balances on a trade date basis. The Board notes that firms should
continue to report commitment balances on a trade date basis. The Board
has adopted the revision as proposed.
The Board did not propose any changes to the treatment of disposed
loans on Schedule H. However, one commenter suggested that the Board
revise the instructions to allow disposed facilities to be reported
with data as of the prior reporting cycle rather than the day of
disposition. The Board believes collecting loan disposition information
as it existed at the point of disposition is critical, and so will not
revise the current requirements.
Schedule L (Counterparty)
The Board proposed to expand the scope of granularity of a firm's
reporting of credit valuation adjustment (CVA) related data fields from
the top 95 percent to all counterparties at the legal entity level for
several sub-schedules. Four commenters expressed that this change would
cause significant burden on firms not only from a data perspective, but
also from a technical perspective, as firms' and vendors' systems may
not be capable of handling data sets of that size. The Board
acknowledges the operational concerns raised by the industry. In doing
so, the Board has adopted a modification of the proposed revision that
limits the scope of counterparty legal entity identifier (LEI) level
reporting requirements in Schedules L.1-L.3 \12\ to top 95% stressed
CVA, in addition to the existing 95% unstressed CVA. For the remaining
counterparties that are not required to be reported at an individual
LEI level, a new Schedule will be added to collect summary metrics with
respect to their key attributes, for example by industry, rating, and
region.
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\12\ Sub-schedules L.1.a through L.1.d.2 capture information
regarding derivatives profile by counterparty and aggregate across
all counterparties. Sub-schedule L.2 captures expected exposure
profile by counterparty and sub-schedule L.3 captures credit quality
by counterparty.
---------------------------------------------------------------------------
Two commenters requested the Board clarify whether this increased
scope applied to all counterparties, or only counterparties with CVA.
The Board confirms the scope of the counterparty population under the
adopted modification of the proposed revision should apply only to
counterparties with CVA.
In addition to the increased scope in CVA related fields, the Board
proposed revisions to several definitions throughout Schedule L. Two
commenters asked for additional clarification regarding the consistency
of the ``Netting Set ID'' field throughout the Schedules, the
definition of the ``Trades Not Captured'' field, as well as
[[Page 70536]]
whether securities financing transactions (SFTs) should be included
with derivatives in the same counterparty data sets. ``Netting Set ID''
and ``Sub-netting Set ID'' are optional fields for certain schedules.
To ensure consistency across Schedule L, the Board is revising the
instructions to require these field to be reported for all schedules,
and is requiring that they be reported using the same granularity
across Schedule L. Further, the Board is revising the instructions to
indicate that the ``Trades Not Captured'' field should incorporate
types of trades or counterparties for which CVA is computed offline
(i.e., outside of the main CVA systems). This is effectively equivalent
to the scope of counterparties and/or types of trades for which the
firm is unable to submit data requirements associated with Schedule L.2
that relate to the components of the CVA. Finally, the Board is
revising the instructions to clarify that fair-valued SFTs should be
reported in aggregate under Schedule L.1.e.2 (Additional/Offline CVA
Reserves), as opposed to at the granular counterparty LEI level
reporting under Schedules L.1, L.2, and L.3. In doing so, a new line
item will be added to collect fair-valued SFTs separately under
Schedule L.1.e.2.
The Board proposed to require firms to report certain
counterparties on Schedule L.1.a-L.1.d at a counterparty legal entity
level, rather than a consolidated parent level. One commenter
recommended that the reporting of sovereign counterparties remain
unchanged since the proposed instructions would require incremental
data on whether sovereign counterparties are state-owned enterprises,
which are backed by the full faith and credit of a sovereign entity,
and that data is not readily available. The commenter added that if
this change were required, then the Board should clarify the definition
of ``full faith and credit of a sovereign entity'' and how to determine
that using North American Industry Classification System (NAICS) codes.
The commenter further suggested that the Board confirm whether the
determination of designated central counterparties (CCPs) not located
in the U.S. is consistent with those CCPs identified as Qualifying
Central Counterparty (QCCP) under 12 CFR 217. If this is not the
intended population, the commenter recommended that the Board specify
the supervisory provisions that would constitute an international CCP
being regulated and supervised in a manner equivalent to the designated
financial market utilities. The Board notes that the proposed change to
the instructions on sovereign and designated CCP counterparties is a
codification of how the Board requires firms to calculate their largest
counterparty as part of the large counterparty default (LCPD)
component. However, the Board does acknowledge the benefit of using the
definitions of sovereign and CCPs that are consistent with those in the
regulatory capital rules. Given this, the Board is revising the
definitions of sovereign and CCPs, including the scope of QCCPs vs non-
QCCPs, to correspond with the definitions in section .2 of the
regulatory capital rules (12 CFR 217), as recommended by the commenter.
As a result of the Board revising the instructions to use the
definition of sovereign in regulatory capital rules and the delaying of
the effective date until June 30, 2020, the Board believes the concerns
raised by the commenter have been mitigated.
The Board proposed to revise Schedule L.1.a (Individual
Counterparties--Credit Valuation Adjustment (CVA)) to clarify that
individual counterparties should be captured at the legal entity level,
rather than at the aggregated parent or consolidated level. Two
commenters asked the Board to clarify how this change impacts Schedule
L.1.e (Aggregate CVA Data by Ratings and Collateralization) and
Schedule L.4 (Aggregate and Top 10 CVA Sensitivities by Risk Factor).
The Board is revising the instructions to show that Schedule L.1.e
should be reported based on the immediate counterparty LEI facing the
firm and that Schedule L.4 should continue to be reported at the
aggregated parent or consolidated counterparty level.
The Board received a comment recommending that language be added to
the Schedule L instructions specifying how the schedule should relate
to data reported in FR Y-14A, Schedule A.5 (Counterparty Credit Risk).
The Board strives to align or otherwise connect related data fields,
where applicable, and is including language in the technical
instructions to clarify how the data should reconcile between these two
schedules with regards to both CVA and LCPD.
FR Y-14M
Schedule A (Domestic First Lien Closed-End 1-4 Family Residential Loan)
and Schedule B (Domestic Home Equity Loan and Home Equity Line)
The Board proposed to revise Schedules A and B to indicate that in
cases of involuntary terminations, loans should be reported for up to
24 months following termination until data in the four loss severity
fields are available to report. The Board notes that this change should
apply to loans that have experienced an involuntary termination within
the past 12 months of the date of the revised instructions and for
which the four loss severity fields are available. One commenter asked
whether this revision should only be applied to accounts where the
event (i.e., charge-off and involuntary termination) occurred in the
first month after the revision became effective, and which accounts
should now be included in these schedules. The Board clarifies that the
reporting of accounts where the event occurred 12 months prior to the
date of the revised instruction is not changing, and firms are not
required to include accounts where the event occurred 24 months prior
to the date of the revised instructions.
The Board received two other comments on its proposal regarding
reporting cases of involuntary terminations on Schedule A and B. The
first comment states that this proposal will create additional
operational burden, specifically as it relates to loans serviced by
others. Per the comment, loan servicers are responsible for tracking
non-performing loans/lines, regardless of lien position, through the
full loss mitigation process. When a loan/line is involuntary
liquidated, the servicer is responsible for recording all of the loss
severity information and passing that information to the bank that owns
the loan/line. When this happens, the owning bank removes the
liquidated loan/line from its system. The commenter points out that
this revision should only be applied prospectively (i.e., for accounts
with involuntary terminations from the date of the revised instructions
forward). The second comment asks that certain commercial and serviced
loans be exempt from this treatment, and asks to confirm whether all
fields on Schedules A and B need to be filled out for these loans/
lines, or whether only the loss severity fields need to be filled out.
The Board notes that only a portion of recoveries are realized
within the first 12 months after charge-off, and so moving to a 24
month window would portray a more complete picture of applicable
recoveries. The Board further notes that in the case of involuntary
terminations, loans should be reported for up to 24 months following
termination, until the data on specified fields (items 93 (``Total Debt
at Time of any Involuntary Termination''), 94 (``Net Recovery
Amount''), 95 (``Credit Enhanced Amount''), and 121 (``Sales Price of
Property'')) are available to
[[Page 70537]]
report. If the data are available sooner, the firm does not have to
continue reporting these loans in the following months. Moreover, these
fields should only be reported for any portfolio or private securitized
loans that experienced involuntary terminations. Per the proposal, the
Board will require firms to carry involuntary liquidated loans/lines up
to 24 months to fully populate all fields up until all the fields are
captured or 24 months. A firm does not need to change its reporting
conventions for loans before and after the involuntary liquidations.
The Board has adopted the revision as proposed.
The Board proposed to revise item 65 (``Foreclosures Status'') of
Schedule A to clarify that in the month a loan liquidates, a firm
should report the loan as a post-sale foreclosure. One commenter noted
that a loan could have moved from a post-sale foreclosure to real
estate owned in the month a loan liquidates, and suggested the Board
clarify in the instructions that item 65 should be reported as of the
month end in the month the loan liquidates. The Board notes that the
instructions for this item already require reporting as of the end of
the reporting month. However, for clarification purposes, the Board is
revising the instructions to indicate that if a loan was in foreclosure
in the prior month, and the loan liquidates during the current month,
then it should be reported as a post-sale foreclosure.
The Board proposed to revise Schedule A, item 59, and Schedule B,
item 43 (both ``Principal and Interest (P&I) Amount Current''), to
clarify that firms should report the principal and interest due from
the borrower in the reporting month, even in cases of balloon loans
that mature in the reporting month. One commenter pointed out that this
clarification contradicts other parts of these items instructions,
which state that a loan in the process of paying off in a reporting
month can be reported with a value of zero. As a result, the Board is
revising the instructions for these two items to state that for balloon
loans in the process of paying off in a reporting month, firms should
report the full amount due.
The Board proposed to add two new items to Schedule B (items 118
(``Charge-off Amount'') and 119 (``Charge-off Date'')). A commenter
asked whether similar fields should have been added to Schedule A. The
Board did not propose to add these fields to Schedule A, as it does not
need this information for that loan population.
Schedule D (Domestic Credit Card)
The Board proposed to revise the instructions for Schedule D to
state if an account at the time of closure or charge-off had a positive
unpaid balance that needed to be repaid or recovered, then information
on that account should be reported up to 24 months after the closure or
charge-off. Previously, information on that account would have only
been reported up to 12 months after the closure or charge-off. A
commenter noted that this requirement should only be applied
prospectively due to the burden of retrieving data from the past 24
months. The Board notes that only a portion of recoveries are realized
within the first 12 months after charge-off, and so moving to a 24
month window would portray a more complete picture of applicable
recoveries. The Board notes that this reporting change should only
apply to loans that have experienced a charge-off or termination event
within the past 12 months of the date of the revised instructions. The
Board has adopted this revision as proposed.
The same commenter asked the Board to clarify when closed accounts
should be excluded in cases when they have a zero balances at closure
and in cases where they do not. The Board clarifies that charge-off and
non-charge off accounts should be have a zero balance reported in the
month they close, and should be excluded in the month after they close.
Accounts that have a balance greater than zero when closed should be
reported up to 24 months after they close.
The Board proposed to update the instructions for items 17
(``Managed Recoveries'') and 18 (``Booked Recoveries'') on Schedule D
to clarify that all gross charge-offs, including those related to
acquired impaired loans, should be included. One commenter asked why
charge-offs should be included in amounts related to recoveries. The
Board is revising the instructions to make it clear that these items
should be capturing the recovery of the charged-off amount for acquired
impaired loans.
The Board proposed to add a clause to the instructions for item 68
(``Account Sold Flag'') on Schedule D to indicate that firms must start
to report this item from the sale announcement date. The instructions
were previously ambiguous as to when to begin to report this item. One
commenter asked how this item should be reported if the sale has been
announced but the accounts in the portfolio to be sold have not yet
been finalized. The commenter asked the Board to allow for firms to not
report this item if the information needed to report is not available
as of the sale announcement date. The Board needs the information
reported in this item as soon as it is available in order to adequately
assess the risk effects of portfolios that are in the process of being
sold, and so has adopted the revision as proposed.
One commenter requested revising the FR Y-14M to be reported
quarterly instead of monthly, citing reporting burden of monthly filing
as a rationale. Monthly data collection allows the Board's financial
models to be sensitive to high-frequency changes in risk drivers, and
so the Board will continue to require monthly data.
The Board did not propose revising how retired fields on the FR Y-
14M should be reported. However, a commenter requested the Board
confirm whether retired fields should be removed from the report or
remain in the schedules but reported with null values. The Board
confirms that due to previously received industry feedback regarding
the burden of renumbering items, retired fields should continue to
reported and reported with null values.
CECL Proposal Comments
General
The Board proposed to add items and update references to the FR Y-
14 reports to incorporate CECL. One commenter expressed concern that
firms would be required to produce additional information in order to
demonstrate how their projections incorporating CECL differ from what
the projections would have been under the incurred-loss methodology,
even if the firms intend to retire their incurred-loss models upon
adoption of CECL and do not intend to maintain parallel processes. The
commenter referenced CCAR FAQ GEN0207,\13\ in which the Board stated
that firms should prepare to submit documentation on the methodology
used to produce the capital plan submission in accordance with the
capital plan rule. CCAR FAQ GEN0207 further stated that examiners may
request any additional documentation necessary to understand and
support the firm's estimated stressed capital insomuch as the firm
relied upon that information to create and approve that plan. Per the
response to CCAR FAQ GEN0207, firms are not required to maintain
parallel methodologies (i.e., CECL and incurred-loss). Firms only need
to provide documentation on the methodology
[[Page 70538]]
used in their projections and capital plans.
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\13\ https://www.federalreserve.gov/publications/comprehensive-capital-analysis-and-review-questions-and-anwers.htm.
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The Board received a comment regarding whether the effective dates
for CECL filers will be revised based on FASB's recent proposal to
delay CECL effective dates for certain institutions (FASB approved this
proposal on October 17, 2019).\14\ The Board had initially proposed to
remove incurred-loss model items and references from the FR Y-14
reports by March 31, 2022, at the latest, as that was the anticipated
time by which all filers would have adopted CECL. However, given this
extension, the Board is delaying the removal of these items until March
31, 2023.
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\14\ https://www.fasb.org/jsp/FASB/Document_C/DocumentPage?cid=117617376157&acceptedDisclaimer=true.
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The Board received a comment asking how the implementation of CECL
would impact the disclosure of DFAST/CCAR results. The commenter points
out that the fundamental inconsistencies between how the Board and
participating firms will calculate credit loss allowances over the
projection horizon will present challenges in comparing the risk
profiles and capital planning capabilities of firms. Further, per the
comment, stakeholders may have difficulty evaluating and understanding
firms' stress-test disclosures, as well as the DFAST and CCAR results,
because of the different methodologies used among firms and by the
Board. To avoid potential confusion for stakeholders, the commenter
recommends that the Board explain in its DFAST and CCAR results
publications that its projections for the supervisory severely adverse
scenario are not comparable to firms' projections for the same scenario
because of the fundamentally different methodologies used by the Board
and firms to project credit loss allowances, and that firms' own
projections may not be comparable to one another's because of
differences in how they incorporated CECL into their projection
methodologies. Finally, the commenter recommends that to further
promote clear communication to stakeholders and stakeholders'
understanding of the stress test results, the Board should provide a
template disclosure that firms could include in their own DFAST
disclosures explaining that their projections may not be comparable to
those of other firms, and are not comparable to those of the Board
because of methodological differences relating to the projections of
credit loss allowances. In response, the Board understands the concerns
posed by the commenter, and will consider this comment as part of its
results disclosure process.
FR Y-14A
General
In the initial proposal, the Board mentioned that it would update
applicable reporting instructions to account for the exclusion of
unconditionally cancelable commitments from the allowance for credit
losses off-balance sheet exposures. One commenter pointed out that the
Board did not make any such revisions. The Board notes that the
reference to updating applicable instructions should not have been made
in the initial proposal because the only instructions that mention
unconditionally cancelable commitments refer to the definition on the
FR Y-9C, and so no additional updates were necessary.
Schedule A.1.a (Income Statement)
The Board proposed to add items that capture the provisions, net
charge-offs, and allowances for held-to-maturity (HTM) and available-
for-sale (AFS) debt securities to Schedule A.1.a. However, the Board
did not add items that capture these fields for all other financial
assets that fall within the scope of CECL, such as securities purchased
under agreements to resell and other assets. One commenter pointed out
that without adding these items, net income as reported on Schedule
A.1.a would not be accurate. The Board notes that under the proposed
instructions, net income would not reconcile across the FR Y-14 and FR
Y-9C reports, and is revising the form and instructions to add
applicable items to capture all other financial assets that fall within
the scope of CECL.
Schedule A.1.b (Balance Sheet)
The Board proposed to revise the instructions for ``Other assets''
(item 129) to change the FR Y-9C items referenced in the definition.
Specifically, the Board proposed to remove references to FR Y-9C,
Schedule HC (Balance Sheet), items 8 (``Investments in unconsolidated
subsidiaries and associated companies'') and 9 (``Direct and indirect
investments in real estate ventures''). One commenter noted that if the
references to items 8 and 9 were removed, then the total assets
balances would not reconcile between the FR Y-14A and FR Y-9C. The
Board notes the total balances would not reconcile under the proposed
revision, and is revising the instructions to add back these
references.
Schedule A.1.d (Capital)
The Board proposed several revisions to Schedule A.1.d to mirror
those made to FR Y-9C, Schedule HC-R (Regulatory Capital), Part I
(Regulatory Capital Components and Ratios), to incorporate the adoption
of CECL. One commenter pointed out that in the proposed revisions for
item 54 (``Allowance for loan and lease losses includable in tier 2
capital''), the Board did not properly mirror the revisions to the
equivalent item on the FR Y-9C, Schedule HC-R, Part I (item 30.a), in
that it did not add a clause to the instructions for item 54 specifying
that firms should only include the portion of allowance for loan and
lease losses (ALLL) or adjusted allowances for credit losses (AACL)
that is includable in tier 2 capital, per the regulatory capital rule.
The Board notes that this clause should be added to the instructions,
as only the ALLL or AACL that is included in tier 2 capital should be
included in item 54, and is revising the instructions for item 54 to
use language in the equivalent FR Y-9C item.
The Board did not propose to revise the instructions for item 96
(``Supplementary leverage ratio exposure'') to state that firms that
have adopted ASU 2016-13 and have elected to apply the transition
provision should incorporate the effects of this transition. One
commenter pointed out that per the regulatory capital rules, the
transitional amount should also be applied to the supplementary
leverage ratio, and suggested the Board revise the instructions for
item 96 to indicate so. The Board confirms that the transitional amount
should be applied to the supplementary leverage ratio. However, the
current instructions for item 96 directly reference the regulatory
capital rules, which describe the items to which the transitional
amount applies. Given this, the Board does not believe any further
clarification is necessary.
The Board did not propose to add an item to separately capture the
AACL on PCD assets on the FR Y-14. One commenter asked the Board to
confirm it will not ask firms to provide this information through a
supplemental request. The Board does not intend to add an item to
separately capture this value on the FR Y-14.
Schedules A.3.f and A.3.g (Expected Credit Loss and Provision for
Credit Loss--HTM and AFS Securities, Respectively)
The Board proposed to add Schedules A.3.f and A.3.g to capture
allowance for credit loss information on HTM and AFS securities. One
commenter asked
[[Page 70539]]
whether the ``Total allowance for credit loss'' items on both schedules
should be reported as of the prior quarter, the current quarter, or a
projected quarter. The Board is revising the instructions to clarify
that these items should be reported as of the report date (i.e.,
current quarter).
One commenter requested that the Board specify what the ``Expected
loss'' item in both schedules consists of, whether it corresponds to
any FR Y-9C item, and how it differs from the ``Provision for credit
loss'' item that is also on both schedules. The ``Expected loss'' item
is the expected credit losses as defined by ASU 2016-13 and before
applying the ``fair value floor'' that limits the amount of the
allowance for credit losses to the amount by which fair value is below
amortized cost. This item should equal FR Y-9C, Schedule HI-B (Charge-
offs and Recoveries on Loans and Leases and Changes in Allowances for
Credit Losses), Part 2 (Change in Allowances for Credit Losses), item 5
(``Provision for credit losses''). To avoid confusion, the Board is
renaming the ``Expected loss'' item to ``Expected credit loss before
applying the fair value floor,'' and is revising the instructions to
indicate this as well. Also in response to this comment, the Board is
removing the ``Amortized cost of securities intended to sell or will be
required to sell before recovery of amortized cost'' item from Schedule
A.3.g, as it is no longer necessary.
Finally, one commenter asked the Board to confirm that the sum of
provision for credit loss items reported on Schedules A.3.f and A.3.g
should equal proposed items 91.b (``Provisions for credit losses on
held-to-maturity debt securities during the quarter'') and 91.c
(``Provisions for credit losses on available-for-sale securities during
the quarter'') on Schedule A.1.a, respectively. The Board confirms
these values should be equal.
Collection of Supplemental CECL Information
The Board proposed to add a collection of supplemental CECL
information to be reported by institutions that adopt ASU 2016-13 that
captures the timing and impact of CECL adoption as of December 31. This
collection would require firms to report actual values (i.e., not
projected) that incorporate the adoption of CECL on the FR Y-14A, in
the stress test cycle year of adoption. One commenter notes that the
collection of supplemental CECL information would not require reporting
of information on the stressed impact of CECL on either existing
portfolios or on newly originated exposures during the stress test
horizon. The commenter is also concerned that this proposed collection
would not provide the Board with the insight it is seeking into the
stressed impacts of CECL since these potential losses are important
components of overall CECL estimates. The commenter further suggested
that the Board provide a description of the relationship between each
item on Collection of Supplemental CECL information and items on the FR
Y-14A, Summary sub-schedules. Finally, the commenter pointed out that
the instructions for item 6 (``Total allowance for credit losses'')
refer to sub-items 5.a and 5.b, which do not exist.
The Board notes that it intends to collect information of the day 1
unstressed impact; that is, the effect of the change in accounting
principles on the effective date of CECL (i.e., not the impact over the
entire projection horizon). The Board also notes that because this
collection is a pro-forma estimate of the effect of the change in
accounting principles, there is no relationship between items on this
schedule and other FR Y-14A items corresponding to prior quarter end
financial statement data. The Board believes that it will have
sufficient data under the collection to reflect the impact of stress
losses under CECL accounting. Therefore, the Board has adopted this
revision as proposed, except that it is revising the heading on the
form to make it clear that the Board is asking for the effect of
changes in accounting principles, and it is revising the instructions
for item 6 to refer to the sub-items of item 6. For clarification
purposes, the Board is also updating the FR Y-14A instructions to
include language about when this schedule should be filed and which
items need to be reported for certain firms.
FR Y-14Q
Schedule B (Securities)
The Board proposed to add two items to Schedule B that would only
be completed by firms that have adopted CECL (``Amount of allowance for
credit losses'' and ``Writeoffs''). One commenter asked whether the
Board will specify that reporting debt securities on a trade-lot level
will continue to apply to firms that have adopted CECL if they
calculate their credit loss allowances for AFS debt securities on
security-level basis or for HTM debt securities on either a security-
level or pool-level basis. The Board is revising the instructions for
these two items to instruct firms that if a given allowance measurement
or specific writeoff applies to more than one row on the reporting
form, to allocate the allowances across the relevant investments on a
pro rata basis, based on amortized cost.
The Board proposed instructions for ``Writeoffs'' to require firms
to report any writeoffs of the security during the quarter. One
commenter asked the Board to clarify whether that means on a quarter-
to-date, year-to-date, or lifetime-to-date basis. The Board is revising
the instructions to clarify that this item should be reported on a
quarter-to-date basis.
Schedule D (Regulatory Capital)
The Board proposed minor revisions to Schedule D in the CECL
proposal, but substantial revisions to the schedule in the non-CECL
proposal. Two firms commented as to how to reconcile revisions in the
event that certain text and items were eliminated in one proposal but
not the other. Since the Board has adopted both proposals at the same
time, the combined instructions document should clear up any ambiguity.
Further, the Board clarifies that Schedule D should be reported by all
firms that file the FR Y-14Q, and not just advanced approaches firms.
Schedule H (Wholesale)
The Board proposed to revise the instructions to Schedule H.1, item
24 (``Committed Exposure Global'') to require firms to report the total
commitment amount as the sum of loan and lease financing receivables
recorded in FR Y-9C, Schedule HC-C (reported in field 25--``Utilized
Exposure Global'') and any unused portion of the commitment recorded in
Schedules HC-F (Other Assets), HC-G (Other Liabilities), and HC-L
(Derivatives and Off-Balance Sheet Items). One commenter said that this
revision made it unclear what to report in this item, and recommended
the Board clarify the types of unused loan commitments that should be
reported instead of referencing other FR Y-14Q or FR Y-9C items. The
Board does not believe further clarification is necessary for two
reasons. First, the Schedule H instructions already define the
reportable facilities. Second, the Board believes it is better to
leverage existing instructions within or across reports in order to
reduce burden and improve data accuracy. The Board has adopted the
revision as proposed.
The Board proposed to add additional items to Schedules H.1 and H.2
that are only reported by firms that have adopted CECL. Two of these
items, ``ASC326-20'' and ``Purchased Credit Deteriorated Noncredit
Discount'' (Schedule H.1--items 102 and 103;
[[Page 70540]]
Schedule H.2--items 63 and 64, respectively), require firms to report
the information at the credit facility level, if available, or if not,
at a pro-rated allocation from the collective (pool) basis. One
commenter stated it was unclear which basis should be used for the
proposed allocation. Further, the commenter is concerned that without a
prescribed allocation methodology, methods could vary broadly across
firms. Per the comment, this inconsistency would weaken comparability
and reduce the value of this schedule. Finally, the commenter requested
the Board remove the requirements proposed in these two items, and
instead prescribe a clear allocation methodology. The Board believes
that the reporting firm is in the best position to determine the
appropriate allocation methodology, and does not want to impose
additional burden by prescribing a single allocation methodology. The
Board has adopted the revision as proposed.
FR Y-14M
Generally, institutions subject to filing the FR Y-14 reports would
reflect the CECL standard in data reported on the FR Y-14A, FR Y-14Q,
and FR Y-14M, with as-of dates following the start of the firm's fiscal
year and the adoption of the standard, beginning with the FR Y-14
reports as of December 31, 2019. In the initial proposal, the Board
instructed firms to refer the final CECL rule for specifics surrounding
inclusion of credit losses in a given stress test cycle. One commenter
asked if a firm that adopts CECL January 1, 2020, could report CECL-
related FR Y-14M items on a best effort basis for its January and
February 2020 FR Y-14M submissions. The rationale for this request is
that a firm will be required to file other regulatory reports
reflecting CECL for the first time as of March 31, 2020 (FR Y-9C, FR Y-
14Q, Securities and Exchange Commission (SEC) reports, etc.). In light
of the concerns posed in this comment, the Board is allowing CECL-
related FR Y-14M items to be reported on a best effort basis for the
January and February 2020 submissions.
Board of Governors of the Federal Reserve System, December 18,
2019.
Michele Taylor Fennell,
Assistant Secretary of the Board.
[FR Doc. 2019-27655 Filed 12-20-19; 8:45 am]
BILLING CODE 6210-01-P