FRH7_20250425_omb

Supporting Statement for the
Disclosure Requirements of Subpart H of Regulation H
(Consumer Protection in Sales of Insurance)
(FR H-7; OMB No. 7100-0298)
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 Disclosure Requirements of Subpart H of Regulation H (Consumer
Protection in Sales of Insurance) (FR H-7; OMB No. 7100-0298). The disclosure requirements,
which are codified at 12 CFR 208.81 et seq., apply to the sale of insurance by a state member
bank or by any other person at an office of the bank or on behalf of the bank (collectively,
Covered Persons).
The estimated total annual burden for the FR H-7 is 8,685 hours.
Background and Justification
Subpart H of Regulation H - Membership of State Banking Institutions in the Federal
Reserve System (12 CFR Part 208) was adopted by the Board in 20001 pursuant to section 305 of
the Gramm-Leach-Bliley Act of 1999 (GLBA), which required the federal banking agencies2 to
issue joint regulations governing retail sales practices, solicitations, advertising, and offers of
insurance by, on behalf of, or at the offices of depository institutions.3 Section 305 applies to any
depository institution and any person selling, soliciting, advertising, or offering insurance
products or annuities to a consumer at an office of a depository institution or on behalf of the
institution. The insurance consumer protection rules in Regulation H implement section 305 of
the GLBA and require Covered Persons to prepare and provide certain disclosures in
advertisements of insurance products, to consumers before the completion of the initial purchase
of an insurance product, and at the time a consumer applies for an extension of credit in
connection with the solicitation, offer, or sale of an insurance product or annuity. This
information is not available from other sources.
Description of Information Collection
The insurance consumer protection rules in Regulation H require depository institutions
to prepare and provide certain disclosures to consumers.
Section 208.84(a). Requires Covered Persons to disclose before the completion of the
initial purchase of an insurance product or annuity by a consumer that (1) the insurance product
1

See 65 FR 75822 (December 4, 2000).
The federal banking agencies are the Board, Office of the Comptroller of the Currency (OCC), and Federal Deposit
Insurance Corporation (FDIC).
3
See 12 U.S.C. § 1831x. Section 305 applies to all depository institutions, including national banks, state banks, any
Federal branch and insured branch, and savings associations. The OCC and FDIC have separate regulations
applicable to depository institutions subject to their supervision.
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or annuity is not a deposit or other obligation of, or guaranteed by, the bank or an affiliate of the
bank, (2) the insurance product or annuity is not insured by the FDIC or any other agency of the
United States, the bank, or (if applicable) an affiliate of the bank, and (3) in the case of an
insurance product or annuity that involves an investment risk, there is investment risk associated
with the product, including the possible loss of value.
Section 208.84(b). Requires Covered Persons to disclose at the time a consumer applies
for an extension of credit in connection with which an insurance product or annuity is solicited,
offered, or sold, that the bank may not condition an extension of credit on either (1) the
consumer’s purchase of an insurance product or annuity from the bank or any of its affiliates, or
(2) the consumer’s agreement not to obtain, or a prohibition on the consumer from obtaining, an
insurance product or annuity from an unaffiliated entity.
Section 208.84(d). Requires the disclosures contained in section 208.84(a) to be included
in advertisements and promotional material for insurance products or annuities unless the
advertisements and promotional materials are of a general nature describing or listing the
services or products offered by the bank.
The Board understands that respondents use information technology to comply with these
provisions, including by providing the written disclosure electronically where the consumer has
affirmatively consented to this and the other requirements of section 208.84(c)(4) are met, as
well as by permitting the consumer to acknowledge receipt of certain disclosures electronically
under section 208.84(c)(7).
Respondent Panel
The FR H-7 panel comprises state member banks or any other person who sells, solicits,
advertises, or offers an insurance product or annuity to a consumer at an office of a bank or on
behalf of a bank.
Frequency and Time Schedule
The FR H-7 is event-generated. The FR H-7 contains three disclosure requirements,
which are triggered by the events described above. In connection with the in-person sale of an
insurance product or annuity, both the oral and written disclosures must be made immediately. In
the case of transactions conducted by telephone, oral disclosures must be made at the time of the
sale, and written disclosures must be provided by mail within three business days of the sale of
the insurance product or annuity, beginning on the first business day after the sale, excluding
Sundays and legal public holidays.
Public Availability of Data
There are no data related to this information collection available to the public by the
Board.

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Legal Status
The disclosure requirements of Subpart H of Regulation H are authorized by section 305
of the GLBA, which requires that the Board issue regulations, including disclosure requirements,
applicable to retail sales practices, solicitations, advertising, or offers of insurance by depository
institutions (12 U.S.C. § 1831x). The Board also possesses broad authority to require reports
from state member banks (12 U.S.C. §§ 248(a) and 324). The disclosures required under
Subpart H of Regulation H are mandatory.
Because the FR H-7 disclosures are provided by state member banks to customers,
confidentiality issues should generally not arise. In the event the records are obtained by the
Board through the examination or supervision of a financial institution, this information would
be considered confidential pursuant to exemption 8 of the Freedom of Information Act, which
protects information contained in “examination, operating, or condition reports” obtained in the
bank supervisory process (5 U.S.C. § 552(b)(8)).
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.
Public Comments
On July 31, 2024, the Board published an initial notice in the Federal Register (89 FR
61422) requesting public comment for 60 days on the extension, without revision, of the FR H-7.
The comment period for this notice expired on September 30, 2024. The Board did not receive
any comments. The Board adopted the extension, without revision, of the FR H-7 as originally
proposed. On February 5, 2025, the Board published a final notice in the Federal Register (90
FR 9026).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR H-7 is 8,685
hours. The Board estimates that the total number of respondents is equal to the number of state
member banks who reported positive insurance fees on income reports in the prior calendar year.
The Board estimates that each such state member bank, on average, will make approximately
630 disclosures under 12 CFR 208.84(a) and (b) each year. Related to advertisements (12 CFR
208.84(d), the Board estimates that each such state member bank that engages in such activity
will advertise the products or annuities once per year. The burden estimate was produced using
the standard Board burden calculation methodology. These disclosure requirements represent
less than 1 percent of the Board’s total paperwork burden.

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FR H-7
Disclosure
Sections 208.84(a) and 208.84(b)
Section 208.84(d)
Total

Estimated
number of
respondents4
339
339

Estimated
Estimated
Estimated
annual
average hours annual burden
frequency per response
hours
630
1

0.04
0.42

8,543
142
8,685

The estimated total annual cost to the public for the FR H-7 is $626,623.5
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
Because the Federal Reserve does not collect any information pursuant to FR H-7, any
estimated cost to the Federal Reserve System associated with this information collection is
negligible.

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Of these respondents, 236 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.
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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 $24, 45% Financial
Managers at $87, 15% Lawyers at $88, and 10% Chief Executives at $126). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2024, published April 2, 2025, 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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