BPI Comments on Federal Reserve FR Y-11 and FR 2314 Reporting Requirements

To Whom It May Concern:

The Bank Policy Institute^[1] appreciates the opportunity to provide comments to the Board of Governors of the Federal Reserve System regarding the reporting of the financial statements of certain subsidiaries of U.S. organizations on the FR Y-11 and the FR 2314.

The FR Y-11 and FR 2314 provide the Federal Reserve with detailed financial data to monitor the risk exposures, activities and overall condition of domestic nonbank and foreign subsidiaries of bank holding companies. While we are supportive of the purpose of these reporting forms, a review of the scope of these reports is warranted given the dependence on certain outdated, static thresholds that have not been recalibrated in more than twenty years, as well as ambiguity around the definition of subsidiary in the FR 2314 instructions. Conducting this review will ensure the reporting population continues to focus on entities of genuine supervisory significance and that the reporting burden on institutions is commensurate with the supervisory value of the information collected.

We respectfully urge the Federal Reserve to (i) update the dollar-denominated reporting thresholds applicable to both the FR Y-11 and FR 2314 to reflect the effects of inflation and economic growth, and (ii) clarify the definition of "subsidiary" in the FR 2314 instructions, which currently references multiple statutory and regulatory frameworks with differing control standards, creating ambiguity for reporting institutions and resulting in inconsistency across the industry.

1. The thresholds that define the scope of reporting have remained stagnant for significant periods of time and should be updated for economic growth.

The instructions for the FR Y-11 and the FR 2314 define the scope of entities required to submit the reports along with the required reporting frequency based on the assets of the parent company and the subsidiary. The criteria that establish quarterly reporting requirements include dollar-denominated thresholds based on the subsidiary's assets and activity that have been in place since at least 2002.^[2] While the criteria that establish annual and annual abbreviated reporting requirements were updated in 2013, they remain unadjusted for economic growth for over a decade.^[3] When thresholds are set in nominal dollar terms and unadjusted for long periods, inflation and economic growth can cause more firms to breach those static thresholds without a corresponding increase in complexity or risk profile. Last year, the FDIC adopted a final rule to adjust and index certain of its regulatory thresholds to reflect inflation.^[4] More recently, the joint agency proposals to modernize the regulatory capital framework include an indexing methodology for certain static, dollar-based thresholds contained in the rule that would adjust these thresholds every two years to preserve their real value over time.^[5] We appreciate the agencies' attention to this genuine issue and encourage rulemaking across all the federal banking agencies to ensure that regulatory thresholds remain current, empirically grounded and effective at differentiating institutions with varying risk profiles. We support reviews of these static thresholds across all regulatory reporting forms and believe such an effort should be undertaken regarding the thresholds that define the scope of reporting on the FR Y-11 and FR 2314 to ensure that they remain appropriate in light of the broader economic environment.

Currently, the FR Y-11 and the FR 2314 must be submitted quarterly for a subsidiary where the top-tier holding company or U.S. holding company, respectively, has consolidated assets of $500 million or more and the subsidiary meets one of the following criteria:

• Total assets of the nonbank/foreign subsidiary are equal to or greater than $1 billion;

• The nonbank/foreign subsidiary's off-balance-sheet activities are equal to or greater than $5 billion;
• The nonbank/foreign subsidiary's equity capital is equal to or greater than 5 percent of the top-tier holding company's/organization's consolidated equity capital; or
• The nonbank/foreign subsidiary's operating revenue is equal to or greater than 5 percent of the top-tier holding company's/organization's consolidated operating revenue.

Subsidiaries that do not meet any of the criteria for quarterly reporting but have total assets greater than or equal to $500 million and less than $1 billion must file the FR Y-11 or FR 2314 annually. Finally, subsidiaries that do not meet the criteria for quarterly or annual reporting but have total assets greater than or equal to $250 million and less than $500 million must file an abbreviated version of the reports on an annual basis.

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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.

[2] 90 Fed. Reg. 55240.

[3] Speech by Federal Reserve Vice Chair for Supervision Michelle W. Bowman at the California Bankers Association Bank Presidents Seminar, re: Modernizing Supervision and Regulation: 2025 and the Path Ahead (Jan. 7, 2026), available at: https://www.federalreserve.gov/newsevents/speech/bowman20260107a.htm.

[4] Speech by Federal Reserve Vice Chair for Supervision Michelle W. Bowman at Outlook 26: The New England Economic Forum (Jan. 16, 2026), available at: https://www.federalreserve.gov/newsevents/speech/bowman20260116a.htm.

[5] Mary Aiken (Acting Director) and Julie Williams (Acting Deputy Director), Board of Governors of the Federal Reserve System, Division of Supervision and Regulation, re: Statement of Supervisory Operating Principles (Oct. 29, 2025), available at: https://www.federalreserve.gov/newsevents/pressreleases/files/bcreg20251118a1.pdf.

[6] 90 Fed. Reg. 48835. (OCC and FDIC notice of proposed rulemaking to define the term "unsafe or unsound practice" and revise the supervisory framework for the issuance of matters requiring attention and other supervisory communications.)