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OMB Control No: 7100-0319	ICR Reference No: 201807-7100-017
Status: Historical Active	Previous ICR Reference No: 201705-7100-013
Agency/Subagency: FRS	Agency Tracking No: FFIEC 101
Title: Regulatory Capital Reporting for Institutions Subject to the Advanced Capital Adequacy Framework
Type of Information Collection: Revision of a currently approved collection	Common Form ICR: No
Type of Review Request: Emergency	Approval Requested By: 08/03/2018
OIRA Conclusion Action: Approved without change	Conclusion Date: 08/14/2018
	Date Received in OIRA: 07/31/2018
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	02/28/2019	6 Months From Approved	08/31/2020
Responses	112	0	112
Time Burden (Hours)	59,576	0	59,576
Cost Burden (Dollars)	0	0	0

Abstract: The FFIEC 101 must be filed quarterly by certain large or internationally active state member banks, bank holding companies (BHCs), savings and loan holding companies (SLHCs), intermediate holding companies (IHCs), and also for those institutions that adopt the framework on a voluntary basis. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), the Federal Deposit Insurance Act (FDI Act) and the International Lending Supervision Act of 1983 (ILSA) require the agencies to have risk-based capital requirements and to ensure that banks maintain adequate capital. The Board uses these data to assess and monitor the levels and components of each reporting entity’s risk-based capital requirements and the adequacy of the entity’s capital under the framework. These data also allow the Board to evaluate the quantitative impact and competitive implications of the framework on individual respondents and on the financial industry. The reporting schedules also assist banks in understanding expectations surrounding the system development necessary for implementation and validation of the framework. The submitted data that is released publicly also provide other interested parties with information about banks’ risk-based capital. Finally, the submitted data supplement on-site examination processes.

Emergency Justfication: The agencies propose under the emergency clearance provisions of OMB’s regulations to revise the FFIEC 101 for the June 30, 2018, report date. The agencies have determined that (1) the collection of information within the scope of this request is needed prior to the expiration of time periods established under 5 CFR 1320.10, (2) this collection of information is essential to the mission of the agencies, and (3) the agencies cannot reasonably comply with the normal clearance procedures because an unanticipated event has occurred and the use of normal clearance procedures is reasonably likely to prevent or disrupt the collection of information. These revisions arise from Congressional enactment of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). Section 214 of EGRRCPA requires the agencies to revise the definition of high volatility commercial real estate (HVCRE) exposures that institutions use to calculate risk-weighted assests and, hence, risk-based capital ratios. This provision became effective automatically when the law was signed on May 24, 2018. The agencies must receive data from the quarterly FFIEC 101 report to assess and monitor the levels and components of each reporting entity’s risk-based capital requirements and the adequacy of the entity’s capital under the framework. The next reports are due at the end of August 2018, based on information available as of June 30, 2018. In order for the agencies to implement section 214 as required by law, the agencies cannot comply with the normal clearance process and still receive the June 30, 2018, financial data in a timely manner.

Authorizing Statute(s): US Code: 12 USC 324 Name of Law: Federal Reserve Act
   US Code: 12 USC 1844(c) Name of Law: Bank Holding Company Act
   US Code: 12 USC 1467a(b)(2) Name of Law: Homeowners’ Loan Act
   US Code: 12 USC 5365 Name of Law: Dodd-Frank Act

Citations for New Statutory Requirements: None

Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

Federal Register Notices & Comments
Did the Agency receive public comments on this ICR? No

Number of Information Collection (IC) in this ICR: 3

IC Title	Form No.	Form Name
BHCs and SLHCs	FFIEC 101
IHCs	FFIEC 101
SMBs	FFIEC 101

ICR Summary of Burden

	Total Approved	Previously Approved
Annual Number of Responses	112	112
Annual Time Burden (Hours)	59,576	59,576
Annual Cost Burden (Dollars)	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement:

Annual Cost to Federal Government: $157,700

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination. Yes

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination. No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Yes

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Uncollected

Agency Contact: Robert Dahl 202 622-3119 Robert.Dahl@do.treas.gov

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