Federal Reserve Clarifies Bank Questions Concerning FR Y-9 Reporting
The Federal Reserve has published an Interim Final Rule and the Notice of Proposed Rulemaking to clarify many of the questions financial institutions have been asking since FR Y-9 reporting changes were announced in late January. Those initial changes were the result of revisions to the Small Bank Holding Company Policy Statement, which alters the total consolidated asset limit for banks from $500 million to $1 billion.
FR Y-9 reporting changes take effect in 2015.
Effective immediately, the following revisions have been implemented:
- Holding companies with consolidated assets of less than $1 billion are no longer required to file the FR Y-9C/LP report as of March 31, 2015.*
- Holding companies with consolidated assets of less than $1 billion will begin filing the FR Y-9SP report effective June 30, 2015.
Major concerns have been addressed
The January revisions put 677 U.S. banks with assets between $500 million and $1 billion in a state of limbo, with many asking:
- What are my new reporting requirements?
- Am I still considered a large holding company and need to file the FR Y-9LP?
- Do I still need to file the consolidated holding company financial statements and the FR Y-9C?
These concerns were addressed by the Federal Reserve’s February 3, 2015, statement.
FR Y-9C/LP reporting is unchanged
As was previously in place, holding companies with consolidated assets greater than $1 billion will continue to file the FR Y-9C/LP report. The Federal Reserve may require holding companies with consolidated assets of less than $1 billion to submit the FR Y-9C/LP to meet supervisory needs. Institutions may still elect to file the FR Y-9C/LP even if they have consolidated assets of less than $1 billion.
How we can help
CliftonLarsonAllen’s financial institutions professionals will continue to monitor Federal Reserve actions, keep you up-to-date on any new developments, and assist you with fulfilling all of your bank’s reporting requirements.