FR Y-15 Reporting: The Fed’s Systemic Risk Report, Schedule by Schedule
FR Y-15 reporting is the Federal Reserve Board’s quarterly collection of systemic risk indicators from the largest banking organizations operating in the United States. The Systemic Risk Report is filed as of 31 March, 30 June, 30 September and 31 December by top-tier U.S. bank holding companies and covered savings and loan holding companies with $100 billion or more in total consolidated assets, by U.S. GSIBs below that size, and by foreign banking organizations (FBOs) with $100 billion or more in combined U.S. assets. The December report carries the most weight. Under the Board’s GSIB surcharge rule, a top-tier U.S. bank holding company subject to Category I, II or III standards computes its method 1 score each year from the values it reported on its FR Y-15 as of 31 December of the prior year, and a score of 130 basis points or more identifies it as a GSIB.
The same figures travel further. The measures of cross-jurisdictional activity, weighted short-term wholesale funding and off-balance sheet exposure that help sort large firms into Categories II and III under the Board’s 2019 tailoring framework use or include FR Y-15 data, and the Board also uses the report to identify other firms that may present significant systemic risk and to analyse proposed mergers and acquisitions. Preparation sits downstream of other returns too, because dozens of lines are populated automatically from the FR Y-9C, the FFIEC 009, the FFIEC 101 and the FR Y-9LP.
A Board proposal published on 27 March 2026 (91 FR 14908, docket R-1889) would change both the surcharge rule and the form. The current form and instructions continue to govern filings until a final rule is adopted and takes effect.
Related reading: FR 2052a Reporting: Complex Institution Liquidity Monitoring Report
Filing summary
| Item | Current rule and source |
|---|---|
| Reporting population | Top-tier U.S. BHCs and covered SLHCs with total consolidated assets of $100 billion or more (Schedules A to G); U.S.-based GSIBs identified by their most recent method 1 score, even below that threshold (Schedules A to G); FBOs with combined U.S. assets of $100 billion or more (Schedules H to N, for any U.S. intermediate holding company in Column A and for combined U.S. operations in Column B). Entry and exit tests are in the scope section below. Source: FR Y-15 instructions, General Instructions, Who Must Report. |
| Receiving authority | Board of Governors of the Federal Reserve System; submission procedures and questions run through the district Federal Reserve Bank. Source: FR Y-15 form, page 1; instructions, Where to Submit the Report. |
| Frequency and reference period | Quarterly, at the close of business on the last calendar day of March, June, September and December. Some items are quarter averages; flow items cover the last four quarters or the last twelve months. Source: form, page 1; instructions, When to Submit the Report and Schedules A, C and G. |
| Deadline rule | Received by the Federal Reserve within 50 calendar days after the March, June and September as-of dates and 65 calendar days after the December as-of date, by 5:00 p.m. at the district Reserve Bank. A weekend or holiday deadline moves to the next business day. No extensions are granted. Source: instructions, When to Submit the Report. |
| Submission channel and format | Electronic submission is required; the instructions direct filers to their district Reserve Bank and to the Reporting Central pages on frbservices.org. They specify no file format, taxonomy or file-naming convention. The CFO (or equivalent; an authorized officer for FBOs) signs the cover page, and a manually signed printout is kept for three years. Source: instructions, Where to Submit the Report and section F. |
| Governing version, application and finality | Instructions marked “Effective September 2021”, with individual pages revised as late as January 2026; 14-page form under OMB control number 7100-0352. The March 2026 proposal (91 FR 14908) is not final; as proposed, its form and instruction changes would take effect two calendar quarters after adoption of a final rule. Sources: instructions cover and page footers; form page 1; 91 FR 14908, section II.H. |
Legal basis: Dodd-Frank sections 163 and 165, the BHC Act and the GSIB surcharge rule
Page 1 of the form states that the report is required by law under sections 163 and 165 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, section 5 of the Bank Holding Company Act of 1956, section 10(b) of the Home Owners’ Loan Act and section 8 of the International Banking Act of 1978. The March 2026 proposal maps the same authorities to the U.S. Code: 12 U.S.C. 5463 and 5365 for Dodd-Frank, 12 U.S.C. 3106 and 3108 for the International Banking Act, 12 U.S.C. 1844 for the BHC Act and 12 U.S.C. 1467a for the Home Owners’ Loan Act. The issuing authority is the Board, and the collection runs under OMB control number 7100-0352.
The statute authorises the collection. The rules that consume it sit in two places.
The first is subpart H of Regulation Q, 12 CFR 217.400 to 217.406. Section 217.402 identifies a bank holding company as a GSIB if its method 1 score equals or exceeds 130 basis points, and requires the score to be calculated annually by 31 December. Method 1 uses five equally weighted categories: size, interconnectedness, substitutability, complexity and cross-jurisdictional activity. Method 2 keeps four of them, replaces substitutability with a measure of reliance on short-term wholesale funding, and uses fixed coefficients.
Section 217.401 defines several of the systemic indicators directly by reference to the form: payments activity, securities outstanding and the notional amount of OTC derivatives each mean the amount “as reported by the bank holding company on the FR Y-15”. My reading is that an instruction change to those lines moves a surcharge input without any amendment to the regulation text.
The second is the tailoring framework the Board adopted in 2019: 12 CFR 252.5 for bank holding companies, U.S. intermediate holding companies and FBOs, and 12 CFR 238.10 for covered savings and loan holding companies. Section 252.5 requires a covered firm to determine its category at least quarterly. Category II turns on $700 billion in average total consolidated assets (average combined U.S. assets for an FBO) or $75 billion in average cross-jurisdictional activity together with $100 billion in average total consolidated assets (average combined U.S. assets for an FBO). Category III turns on $250 billion, or on $100 billion plus at least $75 billion in average nonbank assets, weighted short-term wholesale funding or off-balance sheet exposure, again measuring assets as combined U.S. assets for an FBO.
The Board’s report page links the collection to section 165 enhanced prudential standards, to the GSIB surcharge established by the August 2015 final rule (80 FR 49082) and to the November 2019 tailoring rule, which set the current respondent scope. Firms subject to Category IV standards therefore file the full domestic schedule set even though no GSIB surcharge applies to them: the respondent test is size, and systemic designation only adds GSIBs below it.
Who must report the FR Y-15: the $100 billion holding company test, GSIBs and FBOs
The instructions set three reporting criteria and one consolidation rule that decides which entity in a group files.
U.S. holding companies and U.S. GSIBs
U.S. bank holding companies and U.S. covered savings and loan holding companies with total consolidated assets of $100 billion or more file Schedules A through G, subject to applicable phase-in arrangements. Covered SLHCs are those not substantially engaged in insurance or commercial activities, as defined in 12 CFR 238.2, so an insurance-led or commercial SLHC group sits outside the panel at any size. Only the top tier of a multi-tiered holding company that meets the criteria files; a mid-tier holding company does not produce its own report.
Any BHC organised under U.S. law that was identified as a GSIB based on its most recent method 1 score also files Schedules A through G, even if it does not meet the asset threshold.
Foreign banking organizations and their IHCs
FBOs with combined U.S. assets of $100 billion or more file Schedules H through N. Each FBO schedule has two columns: Column A for the U.S. intermediate holding company (IHC), if there is one, and Column B for the combined U.S. operations. The instructions add that a separate FR Y-15 report must be completed for each of the FBO’s IHCs and for the combined U.S. operations.
Combined U.S. operations means the FBO’s U.S. branches and agencies and its U.S. subsidiaries, including any IHC and its subsidiaries, consolidated line by line with intercompany balances eliminated. Two boundary rules change the numbers. Section 2(h)(2) companies under the BHC Act (12 U.S.C. 1841(h)(2)) are excluded from combined U.S. operations, and the parent FBO itself is treated as a non-U.S. affiliate, consistent with 12 CFR 252.2. Positions with head office and non-U.S. sister entities therefore sit outside the U.S. reporting group.
Entering and leaving the panel
The organic entry test is a single date. A top-tier U.S. BHC or U.S. SLHC that reaches $100 billion in total consolidated assets as of 30 June begins reporting in December of the same year; an FBO that reaches $100 billion in combined U.S. assets as of 30 June does the same. Exit takes longer: a filer whose total consolidated assets (or combined U.S. assets) fall below $100 billion for four consecutive quarters stops reporting starting with the fifth quarter.
That 30 June test sits beside a different measurement. The tailoring categories in 12 CFR 252.5 use averages over the four most recent quarters, so a firm can enter the FR Y-15 panel on one 30 June balance sheet while its category, which depends on averaged indicators, has not yet moved. The two determinations are worth documenting separately.
A new reporting organization without 12 months of data uses a pro-rata approach for flow variables, applying an annualised factor until it has four full quarters. For institutions filing for the first time, reasonable estimates are permitted.
What the report contains: Schedules A to G, their FBO mirrors and the averaging rules
The form runs to 14 pages: a signed cover page, seven domestic schedules, seven FBO schedules and an optional narrative statement. Every dollar line is in thousands of U.S. dollars, and each cell carries an MDRM code: the RISK prefix on the domestic schedules, RISI for the IHC column and RISO for the combined U.S. operations column on the FBO schedules.
| Domestic schedule | FBO schedule | What it measures |
|---|---|---|
| A: Size Indicator | H: FBO Size Indicator | Total exposures (derivatives, securities financing transactions, other on-balance sheet assets, off-balance sheet items by credit conversion factor), plus memoranda for total consolidated assets, off-balance sheet exposures and nonbank assets |
| B: Interconnectedness Indicators | I: FBO Interconnectedness Indicators | Intra-financial system assets and liabilities, and securities outstanding |
| C: Substitutability Indicators | J: FBO Substitutability Indicators | Payments by currency over four quarters, assets under custody, equity and debt underwriting |
| D: Complexity Indicators | K: FBO Complexity Indicators | OTC derivative notionals, trading and AFS securities net of HQLA adjustments, Level 3 assets |
| E: Cross-Jurisdictional Activity Indicators | L: FBO Cross-Jurisdictional Activity Indicators | Foreign claims on an ultimate-risk basis and cross-jurisdictional liabilities |
| F: Ancillary Indicators | M: FBO Ancillary Indicators | Total liabilities, retail funding, revenue measures, SFT legs, gross OTC fair values, number of jurisdictions |
| G: Short-Term Wholesale Funding Indicator | N: FBO Short-Term Wholesale Funding Indicator (Parts I and II) | Short-term wholesale funding by liquidity tier and remaining maturity, weighted, with the metric against average risk-weighted assets |
Schedule A and the averaging convention
Schedule A tracks the supplementary leverage ratio disclosure table: the line instructions point most items to the equivalent line in Part 2 of Table 13 in 12 CFR 217.173. Item 5 is total exposures prior to regulatory deductions. Memorandum item M4 (total consolidated assets) is prepopulated from FR Y-9C Schedule HC-K, item 5; M5 is item 5 minus M4, which gives the off-balance sheet exposure figure; and M6 (total nonbank assets) is prepopulated from FR Y-9LP Schedule PC-B, line 17.
Domestic Category I, II and III banking organizations must report Schedule A as quarter averages: daily data for on-balance sheet items, and the average of the three month-end balances for off-balance sheet items. Other respondents must report the whole schedule either as averages or as point-in-time values, and item 6 records which (1 for averages, 0 for point-in-time). Some items stay point-in-time for everyone, Category I to III firms included: item 3(b) regulatory adjustments and memoranda M1 to M3. Schedule H applies the same rule to Category II and III FBOs. A filer that converts regulatory adjustments into a quarter average along with the rest of the schedule has misread the line instruction.
The indicator schedules
Schedule B defines a financial institution for this report as a depository institution, bank holding company, securities broker or dealer, insurance company, mutual fund, hedge fund, pension fund, investment bank or central counterparty. Central banks and other public sector bodies such as multilateral development banks and the Federal Home Loan Banks are excluded; state-owned commercial banks are included. The instructions warn that this definition differs from the one in the FR Y-9C and the FFIEC 002, which among other things includes finance companies, and they rule out a look-through: counterparty status follows the immediate counterparty.
Schedule C collects payments sent through large-value payment systems or through an agent or correspondent, outgoing only, in 13 currencies (AUD, BRL, CAD, CHF, CNY, EUR, GBP, HKD, INR, JPY, MXN, SEK and USD), with New Zealand dollars, Russian rubles and all other currencies as memoranda outside the item 2 total. The tolerance is stated by magnitude: the leading two digits must be accurate for totals at or above $10 trillion and the leading digit below that, and known overestimates may be reported where precise totals are unavailable. Assets under custody and underwriting volumes complete the schedule, with unsecured settlement and clearing lines, securities traded and trading volumes as memoranda.
Schedule E draws on the definitions of the FFIEC 009 and, for liabilities, the Treasury International Capital B reports. The main items exclude derivatives; derivative claims and liabilities appear only in the memoranda (M1 and M3, with totals in M2 and M5). Schedule F item 10 counts jurisdictions in single units, determined by the physical address of each branch, subsidiary or other consolidated entity, and counts offshore centres such as the Cayman Islands and Hong Kong SAR separately.
Schedule G weights
Schedule G splits short-term wholesale funding into first, second and third tiers plus all other components, each across four remaining-maturity columns. Funding with no maturity date goes in the 30-days-or-less column. Item 5 applies the following weights, item 6 sums the four columns, item 7 is average risk-weighted assets over the previous four quarters (taking each quarter’s amount associated with the lower of the two risk-based capital ratios), and item 8 divides item 6 by item 7.
| Funding tier (Schedule G line) | 30 days or less | 31 to 90 days | 91 to 180 days | 181 to 365 days |
|---|---|---|---|---|
| First tier total, item 1(e) | 25% | 10% | 0% | 0% |
| Second tier total, item 2(c) | 50% | 25% | 10% | 0% |
| Third tier total, item 3(d) | 75% | 50% | 25% | 10% |
| All other components, item 4 | 100% | 75% | 50% | 25% |
Source: FR Y-15 instructions, Schedule G, line item 5. Schedule N carries the same weights for FBOs across eight columns, two per maturity bucket (IHC and combined U.S. operations), applies the netting instructions and rules of consolidation of the FR 2052a, and reports average risk-weighted assets for the IHC column only.
Conventions that apply across the form
Filers may round to the nearest million, reporting zeros in the thousands column; amounts below $500,000 are then reported as zero, and rounded detail must be adjusted so that totals equal the sum of their components. Negative entries are generally not permitted. The exceptions are Schedule A item 3(b), Schedule F items 4 and 5, Schedule H item 3(b) and Schedule M items 4 and 5, and a negative entry carries a minus sign, never parentheses. Assets with credit balances go in liability items and liabilities with debit balances in asset items. An amount or a zero is entered for every item except those calculated automatically or retrieved from another report.
The optional narrative statement is public and may not exceed 750 characters; longer text is truncated without notice. It must contain no confidential information and must not be misleading, and its publication does not signify that a federal supervisory agency has verified it. A respondent that makes no statement leaves the item blank and enters no placeholder such as “N/A” or “None”.
FR Y-15 reporting deadlines: quarter-end as-of dates and the 50- and 65-day clock
The report is due as of 31 March, 30 June, 30 September and 31 December. The submission date is the date by which the Federal Reserve must receive the report: 50 calendar days after the March, June and September as-of dates and 65 calendar days after the December as-of date, by the end of the reporting day (5:00 p.m. at each district Reserve Bank). The quarterly frequency has applied since the 30 June 2016 as-of date.
- 31 March report: due 20 May.
- 30 June report: due 19 August.
- 30 September report: due 19 November.
- 31 December report: due 6 March, or 5 March when February has 29 days.
Those dates are my own count of the calendar-day rule. Where the deadline falls on a Saturday, Sunday or holiday, the report must be received on the first business day afterwards. Earlier submission is encouraged and no extensions of time are granted, so the quarter now closing is due on its fixed day whatever happens to the source reports.
Two windows need separate handling. Flow items run on a twelve-month window: payments in Schedule C cover the last twelve months. Schedule G uses a twelve-month average, and the instructions supply their own worked example: data reported as of March include observations from 1 April of the previous year through 31 March of the current year. Filers that have reported the FR 2052a daily for the last twelve months average daily data; all others average the twelve month-end balances within the last four quarters.
The first applicable reference date for a U.S. holding company that crosses $100 billion organically is the 31 December report of the year in which its 30 June total consolidated assets reached the threshold, which falls due in March of the following year.
Submission through the district Reserve Bank: electronic filing, signatures and resubmissions
All banking organizations must submit the completed report electronically. The instructions tell filers to contact their district Reserve Bank or consult the Reporting Central procedures for electronic submission. They are silent on file format, taxonomy, schema version and file naming, so those mechanics come from the Reserve Bank and the Reporting Central materials.
The CFO of the banking organization, or the individual performing the equivalent function, signs the report; for FBOs an authorized officer signs. By signing the cover page, the officer acknowledges that any knowing and willful misrepresentation or omission of a material fact constitutes fraud in the inducement and may lead to sanctions under 18 U.S.C. 1001 and 1007. The filer keeps a manually signed and attested printout of the data submitted, with the cover page attached, for three years. No caption on the form may be changed.
Resubmission arises in three situations the instructions name:
- Automatically retrieved items. Where the FR Y-15 is due before the source report, the respondent may submit with the retrieved items blank and must resubmit after the source report is filed so the missing data populate.
- Amended reports. The Federal Reserve may require an amended report for significant errors or where its interpretation of GAAP or the instructions differs from the filer’s, and a filer must amend when internal or external auditors make adjustments that restate financial statements previously submitted.
- Restatements after an acquisition. The Federal Reserve requests revised reports for prior year-ends from organizations that restate prior-period financial statements as a result of an acquisition.
Before submission, totals and subtotals should be cross-checked and every amount compared with the previous report. Unusual changes that are not attributable to organic growth or ordinary business-cycle fluctuation call for a brief explanation to the Reserve Bank. Questions and requests for interpretation go to the Reserve Bank in the district where the organization submits the report.
Official filing resources
| Resource | Version or status |
|---|---|
| FR Y-15 instructions (PDF) | Cover marked “Effective September 2021”; page footers range from December 2015 to January 2026. Contains the general instructions, line-item instructions, glossary, Quality (Q) edits and Validity (V) edits. |
| FR Y-15 reporting form (PDF) | 14 pages, OMB control number 7100-0352, with MDRM codes printed beside each cell. |
| FR Y-15 report page, federalreserve.gov | Current form and instructions, background, and historical versions back to December 2012. |
| Reporting Central resources, frbservices.org | The instructions point filers to frbservices.org for Reporting Central submission procedures; this is the current resources page, and procedures are confirmed with the district Reserve Bank. |
| Taxonomy, schema or calendar | The FR Y-15 instructions do not specify a taxonomy, schema or filing calendar beyond the deadline rule and printed edits; filers should confirm current electronic-submission specifications with their district Reserve Bank and Reporting Central. |
| Proposed changes, 91 FR 14908 | Proposal published 27 March 2026; does not govern current filings. |
Validation: quality edits, validity edits and the FR Y-9C cross-checks
The instructions print two edit sets. The Quality (Q) edits, which carry an effective date of 31 December 2019, open with a blunt header: each edit must balance, and rounding errors are not allowed. The Validity (V) edits, effective from September 2021, test whether required cells are populated and whether the cover-page fields are internally consistent. Each edit row gives an effective start and end date, the schedule, the edit number, the MDRM target and both a plain-English and an algebraic test.
| Edit | Type | Test as printed |
|---|---|---|
| 3000, 3010, 3020 | Interseries | Schedule F item 1 (total liabilities), Schedule B item 6 and Schedule B item 12 should each be less than FR Y-9C Schedule HC, item 12 (total assets). |
| 3030 | Interseries | If Schedule A item 6 equals zero (point-in-time reporting), item 2(a) gross SFT assets should be at least FR Y-9C Schedule HC, item 3(b). |
| 3055, 3095 | Quality | Schedule D item 7 should be less than Schedule A item 5; items 8 and 9 together should not exceed item 7. |
| 3060, 3063, 3067, 3070 | Quality | Short positions in B3(f) should not exceed equity holdings in B3(e); SFT legs in F6 and F7 should be at least the net SFT exposures in B4 and B10; F1 should be at least B12. |
| 3150 to 3180, 9060 | Quality | Gross revenue above net revenue, foreign net revenue no higher than net revenue, both revenue lines under the edit’s 100 trillion ceiling; number of jurisdictions in F10 not zero. |
| 0100 to 0125, 0021 to 0024 | Validity | CFO name, signature date and contact fields must not be null; the confidentiality answer must be 0 or 1, and the letter indicator must be null when no confidentiality is requested. |
| Schedule N run (for example 0725 to 0777) | Validity | Schedule N detail cells must be populated by a respondent that has filed the FR 2052a for at least 12 months; for a respondent that has not, the edits require specified Schedule N cells to be null. |
Most of the remaining quality edits are non-negativity tests, one per line. They catch sign errors that the negative-entry rule already forbids, which makes them a cheap first check in a pre-submission control.
The rounding interaction deserves a specific test. A filer exercising the option to round to millions still has to land every edit to the unit, because the quality edits do not tolerate rounding differences and the instructions require rounded detail to be adjusted until totals match. The instructions do not publish rejection statistics or a list of common rejection causes, so the edits themselves are the best evidence of what the Federal Reserve tests.
Caveats and interactions: confidentiality, tailoring categories and companion reports
Public by default
Except as otherwise noted, FR Y-15 data are made public. The instructions state that Schedule G items 1 through 4 were to be kept confidential until the first reporting date after implementation of the final liquidity coverage ratio disclosure standard. The instructions do not identify the standard or say when the condition was met, and the Board’s 23 November 2022 notice extending the FR Y-15 repeats the same conditional wording. The Board’s March 2026 proposal states the current position in its Paperwork Reduction Act section: items 1 through 4 of Schedule G were previously treated as confidential automatically until the first reporting date after implementation of the final liquidity coverage ratio disclosure standard, and there are currently no reporting entities whose items 1 through 4 are kept confidential (91 FR 14946, footnote 179). That footnote does not cite the standard, and the Board’s separate final LCR public-disclosure rule (81 FR 94922), effective 1 April 2017 with compliance dates running from April 2017 to October 2018, does not mention the FR Y-15.
Any other confidentiality is by request: a written request, submitted before or with the electronic filing, that shows the specific competitive or privacy harm. A bare statement that competitive harm would result is insufficient. The page-1 check box must be completed, and a filer that fails either requirement will not have its request considered. The answers to the confidentiality questions are themselves public.
Items retrieved from the FR Y-9C follow a different route. Confidentiality for those lines must be requested in the context of the FR Y-9C, and if granted it extends to the FR Y-15 item and to automatically calculated FR Y-15 items that would reveal it. Our guide to FR Y-9C reporting covers that source report.
Prepopulation depends on matching methods
The instructions list 20 items sourced from the FR Y-9C, four from the FFIEC 009, 26 from the FFIEC 101 and two from the FR Y-9LP, across the domestic and FBO schedules. The FR Y-9C items populate only where the holding company or the FBO’s IHC files the FR Y-9C for the same period using the same calculation method, point-in-time or period average. A filer that changes its averaging basis should check which FR Y-9C-sourced lines still populate.
Links to liquidity and FBO reporting
Schedule G is built on FR 2052a and Regulation WW concepts. The tier definitions cite 12 CFR 249, and the Schedule G maturity buckets currently differ by one day from those in the FR 2052a and the net stable funding ratio rule, a mismatch the March 2026 proposal would remove. Our FR 2052a reporting guide sets out the liquidity side.
FBOs face a further cross-reference. The FR Y-7Q instructions point FBOs that also file the FR Y-15 to the Schedule H general instructions for averaging combined U.S. assets, and they require Category II and III FBOs to use quarter averages for that item. Our FR Y-7Q reporting guide covers that report. Schedule L also contains a line Schedule E lacks: item 1(a), adjusted foreign claims on an ultimate-risk basis. The March 2026 proposal cites its instructions as the route by which an FBO may exclude, for tailoring purposes, claims on affiliates outside the reporting group to the extent they are secured by financial collateral.
Categories drive scope elsewhere
Category assignment under 12 CFR 252.5 changes the scope of other collections. The FR Y-14A instructions, for example, assign the trading and counterparty sub-schedules to BHCs, SLHCs and IHCs subject to Category I, II or III standards that meet a trading-activity test, and list a separate schedule set for SLHCs subject to Category IV standards. Our FR Y-14 reporting article covers those schedules. A reclassification of an FR Y-15 line that moves cross-jurisdictional activity, weighted short-term wholesale funding or off-balance sheet exposure across $75 billion can therefore reach beyond this report.
On proportionality, the instructions offer the averaging choice for respondents outside Categories I to III, and for new reporters the pro-rata approach for flow variables and reasonable estimates for first-time filers. The general instructions describe no waiver procedure, and as a U.S. federal collection the report has no national discretions to track.
Recent and upcoming changes: the March 2026 GSIB proposal and the form’s clearance history
The Board published the proposal “Regulatory Capital Rule (Regulation Q): Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; Systemic Risk Report (FR Y-15)” on 27 March 2026 (91 FR 14908, docket R-1889, RIN 7100-AH22). Comments were due by 18 June 2026. The same notice rescinds the Board’s 2023 GSIB proposal (88 FR 60385, 1 September 2023). As proposed, the capital rule, form and instruction changes would take effect two calendar quarters after the date a final rule is adopted. For the first three quarters after that, four-quarter averages or sums could mix data prepared under old and new instructions, and prior quarters would not need restating.
For the form, the proposal would:
- Remove Schedules H through N. FBOs would file Schedules A through G for their combined U.S. operations and separately for any IHC required under Regulation YY; the Board states this reorganizes reporting without changing the information collected.
- Introduce averaging for GSIBs only: daily averages over the quarter for intra-financial system assets and liabilities (month-end averages for their off-balance sheet items), OTC derivative notionals and trading and AFS securities, and month-end averages for securities outstanding, assets under custody, Level 3 assets and cross-jurisdictional claims and liabilities. Category II and III firms would compute method 1 from the average of their four quarterly reported values.
- Report weighted short-term wholesale funding, like payments activity and underwriting, as a value for the reporting quarter with a separate line item for the twelve-month average or sum, to align these items with the other indicators; the notice states that their current reporting methodology would not change (91 FR 14920, footnote 64). Table 1 of the notice, which covers GSIBs only, gives the GSIB funding measure as an average of daily values over the preceding quarter. The proposal would also drop the risk-weighted assets denominator from the method 2 score and realign the maturity buckets to 91 to 179 days and 180 to 364 days to match the FR 2052a.
- Move the trading volume memoranda into the main section of Schedule C as two new indicators, add the Singapore dollar to the payments indicator, remove the Brazilian real, Mexican peso and Swedish krona from it (keeping the peso and krona as memoranda), add the South Korean won as a memorandum currency, and stop collecting rubles and reals.
- Add derivative exposures to cross-jurisdictional claims and liabilities, apply FFIEC 009 definitions to cross-jurisdictional liabilities and drop the Treasury International Capital references.
- Widen the definition of financial institution to include savings and loan holding companies, private equity funds, asset management companies and exchange-traded funds, and move the interconnectedness derivative lines from the current exposure method to SA-CCR for firms that use SA-CCR.
The notice also flags a further step that is not yet in proposed form text. In connection with the separate capital proposals, the Board plans to propose a Schedule A line for off-balance sheet exposures with a 40 percent conversion factor and to remove the 20 and 50 percent lines.
The current Federal Reserve report page continues to identify OMB control number 7100-0352 and lists the present FR Y-15 form and instructions as current. The instructions include pages revised through January 2026.
Earlier milestones explain the current shape. The 2019 tailoring rule added Schedules H through N and set the $100 billion scope, and the September 2021 validity edits added the confidentiality check-box tests.
Frequently Asked Questions
Our holding company crosses $100 billion through an acquisition in the third quarter. When is the first FR Y-15 due?
The 30 June test covers organic growth. Where a top-tier U.S. BHC or U.S. SLHC reaches $100 billion because of a business combination, a reorganization, or a branch acquisition that is not a business combination, it begins reporting with the first quarterly report date following the effective date of that transaction. FBOs follow the same rule for combined U.S. assets. Flow items then use the pro-rata approach until four full quarters of data exist.
Does a state member bank with no holding company file the FR Y-15?
The instructions name holding companies and FBOs as respondents. The capital rule still reaches for the form’s definitions: in 12 CFR 217.2, the Category II and III definitions for a depository institution that is not a subsidiary of a holding company measure cross-jurisdictional activity, off-balance sheet exposure and weighted short-term wholesale funding in accordance with the instructions to the FR Y-15 or an equivalent reporting form. The methodology applies to that bank even though the report itself does not.
Can a Category IV filer report Schedule A as averages one quarter and point-in-time the next?
The Schedule A instructions require respondents outside Categories I to III to choose averages or point-in-time values for the whole schedule, and the general instructions require the report to be prepared in a consistent manner. They do not expressly address a change of method between quarters. A filer considering a switch should agree it with its Reserve Bank first, because the item 6 flag and the FR Y-9C prepopulation both depend on the method chosen.
Our FBO has filed the FR 2052a daily for only eight months. How do we complete the short-term wholesale funding schedule?
Two different tests apply. The averaging rule turns on daily filing: until the FBO has reported the FR 2052a daily for the last twelve months, the Schedule N lines are averaged from the twelve month-end balances within the last four quarters. The Schedule N validity edits turn on how long the respondent has filed the FR 2052a, with no daily-filing condition: after at least 12 months the detail cells must be populated, while a respondent that does not report the FR 2052a or has reported it for less than 12 months must leave specified cells null. An FBO that has filed the FR 2052a for at least 12 months but moved from monthly to daily filing only eight months ago therefore averages month-end balances and populates the cells, while one that began filing the FR 2052a eight months ago is subject to the null-cell edits instead.
Customers send some payments through us using their own BIC as direct members of the payment system. Do those count in Schedule C, and can netted flows be reported net?
Payment facilitation is excluded where the customer is a direct member of the large-value payment system and completes the transaction with its own BIC. Payments into Continuous Linked Settlement are included. Apart from CLS payments, outgoing wholesale payments are reported gross even when settled on a net basis; retail payments sent through a large-value system or a correspondent may be reported net only if they were settled net. Internal book transfers and intragroup payments are excluded even when routed through an external agent.
Do exchange-traded derivatives belong in the Schedule B lines for OTC derivatives with financial institutions?
Contracts initiated on an exchange such as ICE, CME or Eurex are excluded from those lines. Where the filer acts as a financial intermediary in client clearing, facing both the client and the CCP, it reports the exposure to the CCP, and reports exposures to the client only if the client meets the report’s definition of a financial institution. A clearing member that guarantees a CCP’s performance to a client reports the associated exposure to the client.
We use a sub-custodian for part of our custody book. Who reports those assets in Schedule C?
Both. Where assets are held by a sub-custodian, the instructions require the primary custodian and the sub-custodian to report them. All assets held as custodian on behalf of customers are included, cross-border assets and assets that are also under management among them, even when an unaffiliated institution such as a central securities depository holds them.
Related Articles
- FR 2052a Reporting: Complex Institution Liquidity Monitoring Report: who files the Fed’s liquidity monitoring report, its tables and its daily and monthly cadence.
- FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period: the consolidated holding company financial statements that supply several FR Y-15 lines.
- FR Y-7Q Reporting: The Fed’s Capital and Asset Report for FBOs: the FBO capital report whose combined U.S. assets item points back to FR Y-15 Schedule H.
- FR Y-14 Reporting: April 30 Deadline, New Fields and a 2027 Proposal: the stress testing collections whose schedule scope follows the tailoring categories.
- FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026: the bank-level return behind depository institution thresholds in the category definitions.
Key Takeaways
- Scope check: run the $100 billion organic-growth test at 30 June to determine whether reporting begins with the December report, and separately monitor business combinations, reorganizations and qualifying branch acquisitions because those transactions can trigger reporting from the first quarterly report date following their effective date.
- Method choice: outside Categories I to III, choose averages or point-in-time values for the whole of Schedule A (Schedule H for FBOs), align it with the FR Y-9C basis so prepopulation works, and record it in item 6.
- Schedule G and N basis: plan the move to daily averaging for the first as-of date whose preceding twelve months were all filed daily on the FR 2052a, and track separately when the firm reaches 12 months of FR 2052a filing, the test the Schedule G and N validity edits apply with no daily-filing condition.
- Edit tolerance: reconcile to the unit even when reporting in millions; the quality edits reject rounding differences.
- Confidentiality: lodge the written justification with or before the filing, and put requests for FR Y-9C-derived lines on the FR Y-9C.
- Category spillover: any reclassification that moves cross-jurisdictional activity, weighted short-term wholesale funding or off-balance sheet exposure near $75 billion needs a check of category-driven scope in other reports.
- Proposal watch: docket R-1889 would retire Schedules H to N, moving FBOs onto Schedules A to G, and add GSIB averaging; none of it applies before a final rule takes effect.
Sources and References
- Board of Governors of the Federal Reserve System, Instructions for the Preparation of Systemic Risk Report, Reporting Form FR Y-15 (Effective September 2021, pages revised to January 2026): FR Y-15 instructions (PDF)
- Board of Governors of the Federal Reserve System, Systemic Risk Report, FR Y-15 reporting form, OMB No. 7100-0352: FR Y-15 form (PDF)
- Board of Governors of the Federal Reserve System, FR Y-15 report page (description, current and historical versions): federalreserve.gov FR Y-15
- Board of Governors of the Federal Reserve System, Regulatory Capital Rule (Regulation Q): Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; Systemic Risk Report (FR Y-15), notice of proposed rulemaking, 91 FR 14908 (27 March 2026): govinfo PDF
- Board of Governors of the Federal Reserve System, proposal docket R-1889: federalreserve.gov proposals
- 12 CFR part 217 (Regulation Q), including subpart H, sections 217.400 to 217.406, and section 217.2 definitions (2026 edition): govinfo CFR PDF
- 12 CFR part 252 (Regulation YY), section 252.5 categorization of banking organizations (2025 edition): govinfo CFR PDF
- Board of Governors of the Federal Reserve System, Regulatory Capital Rules: Implementation of Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies, final rule, 80 FR 49082 (14 August 2015): govinfo
- 12 CFR part 238 (Regulation LL), section 238.2 definition of covered savings and loan holding company: eCFR
- 12 CFR part 238 (Regulation LL), section 238.10 categorization of covered savings and loan holding companies: eCFR
- Board of Governors of the Federal Reserve System, Systemic Risk Report (FR Y-15), final approval of extension without revision, Federal Register notice of 23 November 2022 (document 2022-25494): govinfo PDF
- 12 CFR part 249 (Regulation WW), section 249.3 definitions (2025 edition): govinfo CFR PDF
- Board of Governors of the Federal Reserve System, Instructions for the Preparation of the Capital and Asset Report for Foreign Banking Organizations, FR Y-7Q: FR Y-7Q instructions (PDF)
- Board of Governors of the Federal Reserve System, Instructions for the Capital Assessments and Stress Testing Reports, FR Y-14A: FR Y-14A instructions (PDF)
- Board of Governors of the Federal Reserve System, Liquidity Coverage Ratio: Public Disclosure Requirements; Extension of Compliance Period for Certain Companies To Meet the Liquidity Coverage Ratio Requirements, final rule, 81 FR 94922 (27 December 2016): govinfo PDF
- Federal Reserve Financial Services, Reporting Central resources: frbservices.org
Preparing the next FR Y-15 submission
Each cycle runs on the same sequence: confirm scope, settle the Schedule A averaging method and the Schedule G daily-or-monthly basis, line up the FR Y-9C, FFIEC 009, FFIEC 101 and FR Y-9LP figures that will prepopulate, run the quality and validity edits to the unit, and lodge any confidentiality letter with the filing. The 31 December report is the one that feeds the next method 1 scores. Until a final rule on docket R-1889 is adopted and takes effect, the September 2021 instructions with their later page revisions are the version to file against.
Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.
