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    FED Proposes to Revise and Extend Form FR Y-9C for Holding Companies

    December 27, 2019

    FED is proposing to revise and extend for three years the FR Y-9 reports on the financial statements of holding companies. The FR Y-9 information collection includes the reporting form FR Y-9C on the consolidated financial statements for holding companies. This proposal to revise FR Y-9C involves implementation of the recently finalized changes to the capital rule of FED. These changes mainly relate to the simplifications rule, the community bank leverage ratio (CBLR) requirements, the standardized approach for counterparty credit risk (SA-CCR) requirements, the High Volatility Commercial Real Estate (HVCRE) rule, and the requirements for reporting of operating leases. The revisions to FR Y-9C would take effect the same quarter as the effective date of the relevant associated revision to the capital rule. Comments must be submitted on or before February 25, 2020. FED also published draft supporting statement, reporting form, and instructions for FR Y-9C.

    FR Y-9C (OMB No. 7100-0128) collects consolidated data from bank holding companies, certain savings and loan holding companies, securities holding companies, and U.S. intermediate holding companies (collectively holding companies). The form is filed quarterly by top-tier holding companies with total consolidated assets of USD 3 billion or more. The proposals include the following:

    • Revisions to the FR Y-9C to implement the final rule to simplify certain aspects of the capital rule (simplifications rule), which made a number of changes to the calculation of common equity tier 1 (CET1) capital, additional tier 1 capital, and tier 2 capital for non-advanced approaches holding companies. 
    • Revisions to the FR Y-9C to implement a simplified alternative measure of capital adequacy, the CBLR, for qualifying holding companies with less than USD 10 billion in total consolidated assets. The proposed revisions would align FR Y-9C with the CBLR final rule, which implemented section 201 of the Economic Growth, Regulatory Relief, and Consumer Protection (EGRRCP) Act. The proposed revisions to the FR Y-9C would become effective for the March 31, 2020, report date, the first report date in respect of which a holding company could elect to opt into the framework established by the CBLR framework.
    • Revisions to the FR Y-9C instructions to implement changes to the capital rule regarding how to calculate the exposure amount of derivative contracts that were implemented by the SA-CCR final rule.
    • Revisions to the FR Y-9C instructions to implement changes to the HVCRE exposure definition in section 2 of the capital rule to conform to the statutory definition of an HVCRE Acquisition, Development, or Construction (ADC) loan (HVCRE final rule). The revisions align the capital rule with section 214 of the EGRRCP Act to exclude from the definition of HVCRE exposure credit facilities that finance the ADC of one- to four-family residential properties.
    • Instructional revisions for the reporting of operating leases on FR Y-9C that would take effect March 31, 2020 as well as a FR Y-9C instructional change for home equity lines of credit that convert from revolving to non-revolving status that would take effect on March 31, 2021.
    • Revisions to the FR Y-9CS to clarify that response to the report is voluntary. 


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    Comment Due Date: February 25, 2020

    Keywords: Americas, US, Banking, Reporting, FR Y-9C, Dodd Frank Act, EGRRCP Act, Capital Rules, CET1, CBLR Framework, HVCRE, SA-CCR, Regulatory Capital, FED

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