The Institute of International Bankers (the “IIB”) and the Bank Policy Institute (the “BPI”, and together with IIB, the “Associations”) appreciate this opportunity to comment on the proposal (the “Proposal”) of the Board of Governors of the Federal Reserve System (the “Board”) to revise the Capital and Asset Report for Foreign Banking Organizations (“FBOs”) on Form FR Y-7Q (the “FR Y-7Q”). The IIB’s members are internationally headquartered banking and financial institutions that are subject to these reporting requirements because they conduct banking operations in the United States. The BPI is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Its members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.
The Associations generally support the Board’s efforts to improve its reporting forms. However, we have concerns regarding three of the Board’s proposed changes to the FR Y-7Q:
- The proposal to shorten the filing deadline for the FR Y-7Q from 90 days after year-end or quarter-end, as applicable, to 30 days after quarter-end for quarterly filers and 45 days after year-end for annual filers.[1]
- The proposal to remove the long-standing option to file the FR Y-7Q on a non-calendar year fiscal year basis.[2]
- The addition of a new requirement to calculate and report the quarterly average of an FBO’s combined U.S. operations (“CUSO”) assets, calculated on a daily or weekly basis (new Line Item 6(b)).[3]
The Associations urge the Board to reconsider each of these changes in light of the severe challenges they pose to the Associations’ members.
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[1] 87 Fed. Reg. 32164, 32165 (May 27, 2022).
[2] Id. at 32165.
[3] Id.; Draft FR Y-7Q Instructions.
