On Feb. 5, 2025, Fed published approval of revised collection, effective Mar. 31, 2025.
Foreign subsidiaries that report $2bn/more in assets in Schedule BS, item 10, and $10mn/more in deposits in Schedule BS-M, item 6, must complete new Schedule BS-Q
Must be located in UK/Caribbean with banking charter and engage in bank business.
Foreign subsidiaries that file FR 2314 annually would not report the new items.
Delayed the requirement to complete FR 1314 Schedule BS-Q until Mar. 31, 2025.
Provisions for credit losses on off-balance sheet and for allocated transfer risk should be reflected in FR 2314, FR Y-11 Schedule IS, item 4, and excluded from Schedule IS.
Clarification also applies to FR Y-7N Schedule IS, items 4, Provisions for Credit Losses and 7, Noninterest expense; will update FR 2314, Y-11, Y-7N instructions accordingly.
Instructions clarified balances with related institutions excluded from Schedule BS-Q.
Draft FR 2314 and FR Y-11 report forms updated to remove reference to FN6.
On Jun. 7, Fed proposed to revise financial statements data collection.
Fed proposed to extend for three years, with revision, the information collection titled, Financial statements of foreign subsidiaries of US banking organizations (FR 2314).
Also, Financial statements of US nonbank subsidiaries of US holding companies (Y-11).
Follows Apr. 2022 Fed updates to the financial information forms, see rule #136072.
Overview of Collections
FR 2314 collects data for non-functionally regulated direct/indirect foreign subsidiaries of US State member banks, Edge and agreement corporations, holding companies.
Used to identify current, potential problems at foreign subsidiaries of US parent firms.
As well as to monitor the activities of US banking organizations in specific countries.
The FR Y-11 reporting forms collect financial information for individual non-functionally regulated US nonbank subsidiaries of domestic holding companies (HCs).
Essential for monitoring subsidiaries' potential impact on condition of HC or subsidiary.
Proposed Revisions
Consistent with changes to US generally accepted accounting principles re troubled debt restructurings, provisions for credit losses on off-balance sheet credit exposures.
Also, expected recoveries of amounts charged off included within allowances for losses.
Revise, clarify instructions re recordkeeping requirements related to submitted form.
Incorporate six line items from FR 2502q, Quarterly report of assets and liabilities of large foreign offices of US banks (OMB Control No. 7100-0079), into the FR 2314.
These revisions are proposed to take effect for the Dec. 31, 2024, as-of date.
Move forms Financial statements of US nonbank subsidiaries held by foreign banking organizations (FR Y-7N), Abbreviated financial statements of US Nonbank subsidiaries held by foreign banking organizations (Y-7NS) from OMB 7100-0125, to FR2314, Y-11.
Consultation
Comments on the proposed revisions must be submitted on or before Aug. 6, 2024.
In Aug. 2024, BPI issued comments on subsidiary reporting changes, see #222412.
Feb. 2025 Fed Adoption
On Feb. 5, 2025, Fed published approval of revised collection, effective Mar. 31, 2025.
Foreign subsidiaries that report $2bn/more in assets in Schedule BS, item 10, and $10mn/more in deposits in Schedule BS-M, item 6, must complete new Schedule BS-Q
Must be located in UK/Caribbean with banking charter and engage in bank business.
Foreign subsidiaries that file FR 2314 annually would not report the new items.
Delayed the requirement to complete FR 1314 Schedule BS-Q until Mar. 31, 2025.
Provisions for credit losses on off-balance sheet and for allocated transfer risk should be reflected in FR 2314, FR Y-11 Schedule IS, item 4, and excluded from Schedule IS.
Clarification also applies to FR Y-7N Schedule IS, items 4, Provisions for Credit Losses and 7, Noninterest expense; will update FR 2314, Y-11, Y-7N instructions accordingly.
Instructions clarified balances with related institutions excluded from Schedule BS-Q.
Draft FR 2314 and FR Y-11 report forms updated to remove reference to FN6.
