September 12, 2018

FED has temporarily approved revisions to the mandatory Consolidated Financial Statements for Holding Companies (FR Y-9C) pursuant to the authority delegated to FED by the Office of Management and Budget (OMB). The temporary approval is valid until March 31, 2019. The revisions are applicable as of June 30, 2018. FED also published the OMB supporting statement for the FR Y-9 family of reports on financial statements for holding companies.

The Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act of May 24, 2018 amended various provisions of banking law to eliminate or reduce statutory and regulatory requirements for certain banking organizations. EGRRCP Act, among other things, provides that state member banks and other depository institutions may only be required to assign a heightened risk-weight to a high volatility commercial real estate (HVCRE) exposure if such exposure is an HVCRE acquisition, development, or construction Loan, as defined in section 214 of EGRRCP Act. Section 202 of EGRRCP Act also amended the statutory definition of brokered deposits. The current instructions for reporting HVCRE and brokered deposits in the FR Y-9C are inconsistent with these provisions of EGRRCP Act.

To avoid the regulatory burden associated with different definitions for HVCRE exposures and brokered deposits within a single organization, FED has amended the FR Y-9C instructions to permit bank holding companies, savings and loan holding companies, and intermediate holding companies of foreign banks to report HVCRE and brokered deposits on the FR Y-9C report in a manner consistent with their subsidiary depository institution(s). The FR Y-9 family of reporting forms continues to be the primary source of financial data on holding companies that examiners rely on between on-site inspections. Financial data from these reporting forms is used to detect emerging financial problems, review performance, conduct pre-inspection analysis, monitor and evaluate capital adequacy, evaluate holding company mergers and acquisitions, and analyze a holding company's overall financial condition to ensure the safety and soundness of its operations.

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Keywords: Americas, US, Banking, Accounting, Reporting, FR Y-9C, Dodd-Frank Act, HVCRE, Commercial Real Estate, EGRRCP Act, FED