FRY8_20250326_omb

Supporting Statement for the
Holding Company Report of Insured Depository Institutions’
Section 23A Transactions with Affiliates
(FR Y-8; OMB No. 7100-0126)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years,
without revision, the Holding Company Report of Insured Depository Institutions’ Section 23A
Transactions with Affiliates (FR Y-8; OMB No. 7100-0126). This reporting form collects
information on covered transactions between an insured depository institution and its affiliates
that are subject to the quantitative limits and other requirements of section 23A of the Federal
Reserve Act (12 U.S.C. § 371c) and the Board’s Regulation W - Transactions Between Member
Banks and Their Affiliates (12 CFR Part 223). The FR Y-8 is filed quarterly by all U.S. top-tier
bank holding companies (BHCs), intermediate holding companies (IHCs), and savings and loan
holding companies (SLHCs) that control an insured depository institution that has had any
section 23A transactions with affiliates in a given quarter. It is also filed quarterly by foreign
banking organizations (FBOs, and together with top-tier U.S. BHCs, SLHCs, and IHCs (holding
companies)) that directly own or control such a U.S. subsidiary insured depository institution. If
an FBO indirectly controls such a U.S. insured depository institution through a domestic U.S.
holding company, the domestic U.S. holding company must file the FR Y-8. A respondent must
file a separate FR Y-8 report for each U.S. insured depository institution it controls that has had
section 23A transactions with affiliates. If an insured depository institution does not conduct any
section 23A covered transactions with an affiliate in a particular quarter, its parent holding
company is not required to submit an FR Y-8 report for that quarter with respect to that
subsidiary.
The estimated total annual burden for the FR Y-8 is 12,178 hours. The form and
instructions are available on the Board’s public website at
https://www.federalreserve.gov/apps/reportingforms.
Background and Justification
Section 23A of the Federal Reserve Act is a statutory provision designed to protect a
depository institution from suffering losses in transactions with affiliates. Section 23A, which is
implemented by Regulation W, also limits the ability of a depository institution to transfer to its
affiliates the subsidy arising from the institution’s access to the federal safety net.
The FR Y-8 report collects information from holding companies in order to monitor
covered transactions between a subsidiary depository institution and its parent holding company
or other affiliates. The data collected by the FR Y-8 is used to monitor bank exposures to
affiliates and to assess insured depository institutions’ compliance with section 23A of the
Federal Reserve Act and the Board’s Regulation W. This information collected by the FR Y-8 is
not available from other sources. If the collection were not conducted, the Board would be less

able to monitor the effect of transactions between insured depository institutions and their
affiliates.
Description of Information Collection
The FR Y-8 is filed by holding companies for each insured depository institution they
control that has any section 23A transactions with affiliates in a given quarter. This report
collects data on covered transactions for each of their insured depository institutions. The data to
be reported vary based on the activities and subsidiaries of the insured depository institution.
There are four data items for insured depository institutions that have covered transactions with
affiliates other than financial subsidiaries. There are ten data items on covered transactions
between insured depository institutions and their financial subsidiaries. There is also a data item
on the maximum aggregate amount of all covered transactions for any single day during the
calendar quarter. Lastly, there are three data items concerning derivative transactions with
affiliates.
The FR Y-8 is submitted to the appropriate Federal Reserve Bank to which a holding
company submits its Consolidated Financial Statements for Holding Companies (FR Y-9C;
OMB No. 7100-0128), Parent Company Only Financial Statements for Small Holding
Companies (FR Y-9SP; OMB No. 7100-0128), or Annual Report of Foreign Banking
Organizations (FR Y-7; OMB No. 7100-0297).
The Board understands that respondents use information technology to comply with these
provisions, including submitting the FR Y-8 electronically. Holding companies must maintain in
their files a physical copy of the manually signed FR Y-8 submission for a period of three years
following submission. A signature is not submitted as part of the electronic submission.
Respondent Panel
The FR Y-8 panel comprises all top-tier U.S. BHCs, IHCs, and SLHCs that control a
depository institution that has any section 23A transactions with affiliates in a given quarter. In
addition, all FBOs or their U.S. holding company that directly own a U.S. subsidiary bank also
must file this report, if that U.S. subsidiary bank has any section 23A transactions with affiliates
in a given quarter.
Frequency and Time Schedule
The FR Y-8 is submitted quarterly as of the last day of March, June, September, and
December. It is submitted within 30 calendar days after the as of date. A 15-day extension of
time to submit the FR Y-8 may be granted to respondents that own banks with more than one
foreign office. A holding company is not required to submit an FR Y-8 report in a given quarter
with respect to a depository institution subsidiary that did not conduct any section 23A covered
transactions with an affiliate in that quarter. The time schedule for FR Y-8 recordkeeping is three
years after submission.

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Public Availability of Data
No data collected by this information collection are published.
Legal Status
Section 5(c) of the Bank Holding Company Act of 1956 (BHC Act) (12 U.S.C. §
1844(c)) authorizes the Board to require BHCs, including IHCs that control a U.S. bank, to file
the FR Y-8. Section 10(b)(2) of the Home Owners’ Loan Act (12 U.S.C. § 1467a(b)(2))
authorizes the Board to require SLHCs to file the FR Y-8. Section 8(a) of the International
Banking Act of 1978 (12 U.S.C. § 3106(a)) and section 5(c) of the BHC Act authorize the Board
to require FBOs that directly own or control a U.S. subsidiary insured depository institution to
file the FR Y-8. The FR Y-8 report is mandatory for respondents that control an insured
depository institution that has engaged in covered transactions with an affiliate during the
reporting period.
Information provided on the FR Y-8 is kept confidential under exemption 4 of the
Freedom of Information Act (FOIA) as confidential commercial or financial information that is
both customarily and actually treated as private (5 U.S.C. § 552(b)(4)). Information collected on
the FR Y-8 may also be considered confidential under FOIA exemption 8 if it is obtained as part
of an examination or supervision of a financial institution (5 U.S.C. § 552(b)(8)).
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On October 2, 2024, the Board published an initial notice in the Federal Register (89 FR
80241) requesting public comment for 60 days on the extension, without revision, of the FR Y-8.
The comment period for this notice expired on December 2, 2024. The Board did not receive any
comments. The Board adopted the extension, without revision, of the FR Y-8 as originally
proposed. On February 7, 2025, the Board published a final notice in the Federal Register (90
FR 9158).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR Y-8 is 12,178
hours. The estimated number of respondents is based on the number of FR Y-8 reporting forms
filed as of December 31, 2023. The burden estimate was calculated using the standard Board
burden calculation methodology. These reporting and recordkeeping requirements represent less
than 1 percent of the Board’s total paperwork burden.

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Estimated
number of
respondents1

FR Y-8
Reporting
Recordkeeping

590
590

Estimated
Estimated
Estimated
annual
average hours annual burden
frequency per response
hours
4
4

4.66
0.50

Total

10,998
1,180
12,178

The estimated total annual cost to the public for the FR Y-8 is $850,633.2
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
report is $182,900.

1

Of these respondents, 269 are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $850 million in total assets). Size standards effective March 17, 2023. See
https://www.sba.gov/document/support-table-size-standards. There are no special accommodations given to mitigate
the burden on small institutions.
2
Total cost to the responding public is estimated using the following formula: total burden hours, multiplied by the
cost of staffing, where the cost of staffing is calculated as a percent of time for each occupational group multiplied
by the group’s hourly rate and then summed (30% Office & Administrative Support at $23, 45% Financial
Managers at $84, 15% Lawyers at $85, and 10% Chief Executives at $124). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2023, published April 3, 2024, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

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