May 15, 2019

FED published the proposed rule and the supporting statement on recordkeeping provisions associated with the Interagency Statement on complex structured finance activities. Under this consultation, FED proposed to extend for three years, without revision, the information collection on the complex structured finance activities (FR 4022). No required reporting forms are associated with the information collection FR 4022. Comments must be submitted by July 15, 2019.

This annual information collection is relevant for state member banks, bank holding companies (other than foreign banking organizations), savings and loan holding companies, and U.S. branches and agencies of foreign banks, with the estimated number of respondents being 18. The guidance associated with these recordkeeping provisions provides that these FED-supervised institutions should establish and maintain policies and procedures for identifying, evaluating, assessing, documenting, and controlling risks associated with certain complex structured finance transactions. The guidance states that supervised entities should provide sufficient information and convey reports to the institution's management and board of directors concerning elevated risks from the complex structured finance transactions.

FED is inviting public comments on the following:

  • Whether the proposed collection of information is necessary for the proper performance of the Board's functions, including whether the information has practical utility
  • The accuracy of the estimate of the burden of the proposed information collection, including the validity of the methodology and assumptions used
  • Ways to enhance the quality, utility, and clarity of the information to be collected
  • Ways to minimize the burden of information collection on respondents, including through the use of automated collection techniques or other forms of information technology
  • Estimates of capital or startup costs and costs of operation, maintenance, and purchase of services to provide information


Related Links

Comment Due Date: July 15, 2019

Keywords: Americas, US, Banking, Information Collection, Structured Finance, FR 4022, FED

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