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Federal Reserve Bank Moving to a Centralized Online Reporting System
The Federal Reserve Bank has begun a multi-year initiative to transition its reporting system to a centralized, secure, single point of entry called Reporting Central. The change means bank holding companies will stop using the Internet Electronic Submission (IESUB) system and instead submit the majority of their filing requirements through the Reporting Central application.
The migration starts this year with the FR Y-8 report, which should be submitted through the new FedLine Web reporting system for the December 31, 2014 filing period. Per our initial communications with Federal Reserve banking personnel, the anticipated migration for Y-9 report will be the December 31, 2015 filing, although this date is subject to change.
How the transition will work
Bank holding companies will need to go through a four-step process to prepare for the change, which includes identifying organizations and personnel to manage electronic access, establish end-user authorization, and set up subscribers.
Reporting institutions and FedLine End User Authorization Contacts (EUAC) and subscribers will also be issued USB authentication tokens by the Federal Reserve. This will provide a second form of authentication to the reporting process, in addition to a username and password for the new Fedline Web system.
Bank holding companies need to identify:
- The organization and individuals who will manage electronic access to the Federal Reserve. These individuals are critical to the Reporting Central setup process described below.
- Individuals who will need access to Reporting Central for all reporting with the Federal Reserve.
The setup for Reporting Central is a four step process:
1. Establish an official authorization list (OAL) for your bank holding company.
Step one is to identify a list of people to serve as a legal basis for establishing your organization’s authority to engage in business with the Federal Reserve, and to ensure instructions are accepted only from those individuals that you authorize. If your subsidiary bank already has an OAL in place with the Federal Reserve, the bank holding company can leverage that OAL to serve as the holding company agreement, known as the affiliate model.
2. Establish end-user authorization contacts (EUAC).
Individuals on the authorized list will have the authority to designate people (subscribers) who will submit reports via the FedLine Web access solution (Reporting Central). These individuals are critical to the Reporting Central application setup process. (Note that a minimum of two people need to be designated as EUAC’s.) As described in step one, if the subsidiary bank already has EUAC’s in place, the bank holding company can leverage the same agreement.
3. Set up new FedLine subscribers or make changes to existing contacts.
These individuals are approved by EUACs and are required to access the Reporting Central application to satisfy reporting requirements. For example, CliftonLarsonAllen LLP could be setup as a subscriber to allow it privileges to file Y-9SP reports on behalf of a bank holding company.
4. Set up report access.
Organizations that have already authorized individuals, EUAC’s, and FedLine Subscribers, but have not established individuals with report series access, should begin here. Organizations will be contacted by the Federal Reserve and will receive separate instructions to set up access to each report in advance of its transition to Reporting Central. EUAC’s at organizations responsible for submitting reports must give individual report series access to their approved subscribers.
We recommend that bank holding companies and related subsidiary banks use the affiliate model when setting up or modifying their FedLine Web users. (For both OALs and EUAC’s – see steps one and two above.) This will allow the organizations to consolidate agreements with the Federal Reserve, limit required documentation, and avoid receiving multiple tokens for each level in the organization structure.
Your organization may already have completed several of these steps if you have previously submitted forms to the Federal Reserve Bank. To ensure you begin the setup process correctly, contact the Federal Reserve Bank.
How we can help
We can help you with the Reporting Central transition, answer questions on the suggested number of users for each step, or provide guidance on how to set up CliftonLarsonAllen LLP as a subscriber for your entity.