FED Temporarily Revises FR Y-9C With Respect to PPPLF and CARES Act
FED has temporarily revised the reporting form on consolidated financial statements for holding companies (FR Y-9C; OMB No. 7100-0128). The form has been revised to collect four new data items related to the Paycheck Protection Payment (PPP) loans and the Paycheck Protection Program Liquidity Facility (PPPLF). The form has also been revised to collect two new items related to Section 4013 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Section 4013 of the CARES Act allows holding companies the flexibility to modify loans related to the COVID-19 pandemic. Additionally, FED invites comments on a proposal to extend the FR Y-9 family of reports for three years, with these revisions to the FR Y-9C. Comments must be submitted on or before 60 days after publication in the Federal Register. FED published a draft reporting form for FR Y-9C and a draft supporting statement for FR Y-9 reports.
The temporary revisions to FR Y-9C include the following:
- New Data Items related to the PPP loans and PPPLF—Starting with the June 30, 2020 reporting period, a holding company will be required to report the total number of PPP loans outstanding and the outstanding balance of PPP loans. A holding company will also be required to report the outstanding balance of PPP loans pledged to the liquidity facility of FED and the quarterly average amount of PPP loans pledged to the liquidity facility and excluded from average total assets in the calculation of the leverage ratio. These items have been added to Schedule HC-M, as items 25.a, 25.b, 25.c, and 25.d, and would enable supervisory staff to monitor credit and liquidity risk, aggregate industry trends, and individual institutions’ use of the PPPLF. Therefore, FED temporarily approved the addition of four new data items to collect this information, with the collection of these items expected to be time-limited.
- New Data Items related to Section 4013 of the CARES Act—Consistent with section 4013(d)(2) of the CARES Act, FED has added two new data items for section 4013 loans to the FR Y-9C. These would be collected quarterly beginning with the June 30, 2020, report date. These new items, Memorandum item 16.a, “Number of Section 4013 loans outstanding,” and Memorandum item 16.b, “Outstanding balance of Section 4013 loans,” have been added to Schedule HC-C, Part I, Loans and Leases. These items would enable supervisory staff to monitor credit risk, aggregate industry trends, and individual institutions’ use of the temporary relief provided by section 4013. FED will collect institution-level section 4013 loan information on a confidential basis.
FED would collect these items through the December 31, 2021, as-of date. If FED subsequently determines that there is a supervisory need for this information beyond December 31, 2021, an extension of these items would be published for comment in a separate Federal Register notice.
- Notice (PDF)
- Draft Reporting Form for FR Y-9C (PDF)
- Supporting Statement for FR Y-9 Reports (PDF)
- Reporting Form Updates
Comment Due Date: FR+60 days
Keywords: Americas, US, Banking, COVID-19, Paycheck Protection Program, Reporting, CARES Act, PPPLF, FR Y-9C, Liquidity Facility, Credit Risk, Liquidity Risk, FED
Scott is a Director in the Regulatory and Accounting Solutions team responsible for providing accounting expertise across solutions, products, and services offered by Moody’s Analytics in the US. He has over 15 years of experience leading auditing, consulting and accounting policy initiatives for financial institutions.
Senior practitioner in asset and liability management (ALM) and liquidity risk who assists banking clients in advancing their treasury and balance sheet management objectives
Advises U.S. and Canadian financial institutions on risk and finance integration, CCAR/DFAST stress testing, IFRS9 and CECL credit loss reserving, and credit risk practices.
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