FR Y-11 Reporting: Four Quarterly Tests and a 60-Day Deadline

FR Y-11 reporting puts a separate set of financial statements for each qualifying U.S. nonbank subsidiary on file with the Federal Reserve, prepared by the top-tier holding company entity by entity and filed no later than 60 calendar days after the report date. The Board’s instructions for the Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies, effective December 2025, establish quarterly FR Y-11 reporting, annual detailed FR Y-11 reporting and annual abbreviated FR Y-11S reporting, subject to the holding-company and subsidiary-level criteria, exemptions and Federal Reserve Bank discretion. Subsidiaries outside the ordinary thresholds may nevertheless be required to report.

The Board’s February 2025 clearance notice estimated 386 respondents for the quarterly FR Y-11, 211 for the annual FR Y-11 and 286 for the FR Y-11S, at 8.3 hours per detailed response and one hour per abbreviated one. The timeliness test is collective: the instructions treat a holding company as on time only when all of its required subsidiary reports are in by the deadline.

Related reading: FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period

Legal basis: BHC Act section 5(c), HOLA section 10, Dodd-Frank sections 618 and 165, and Regulation YY

Page 1 of both forms states that the report is required by law and cites five provisions: section 5(c) of the Bank Holding Company Act (12 U.S.C. 1844(c)), section 10 of the Home Owners’ Loan Act (12 U.S.C. 1467a(b)), section 618 of the Dodd-Frank Act (12 U.S.C. 1850a(c)(1)), section 165 of the Dodd-Frank Act (12 U.S.C. 5365) and 12 CFR 252.153(b)(2) of Regulation YY. The issuing authority is the Board of Governors of the Federal Reserve System, the completed reports go to the Federal Reserve Bank of the holding company’s district, and the Board’s report page lists participation as mandatory.

The instructions use “holding company” for bank holding companies, U.S. intermediate holding companies, savings and loan holding companies and securities holding companies, and the citations line up with that list. Section 1844(c)(1)(A) lets the Board require reports under oath from a bank holding company and any subsidiary, section 1467a(b)(2) requires reports from savings and loan holding companies and their non-savings-association subsidiaries, section 1850a covers supervised securities holding companies and their affiliates, and section 252.153(b)(2) requires each U.S. intermediate holding company to submit information in the form the Board prescribes. That pairing is my reading; the form lists the citations without mapping them.

The statutes supply the power to collect, while the filing tests, exemptions, schedules and deadline sit in the Board’s instructions and form. Since the 2025 clearance the FR Y-11 and FR Y-11S share OMB control number 7100-0073 with the FR 2314, and the FR Y-11’s own number, 7100-0244, was discontinued; the Board’s notice said the move does not modify the reporting or recordkeeping requirements in any way. The forms print an approval expiry of March 31, 2028.

Who must report the FR Y-11 or FR Y-11S: a holding-company gate, four quarterly tests and two annual bands

The filer is always the top-tier holding company, for each individual nonbank subsidiary domiciled in the United States that it owns or controls. “Subsidiary” takes the Regulation Y definition in section 225.2 for bank holding companies (generally 25 percent or more owned or controlled) and the Regulation LL definition in section 238.2 for savings and loan holding companies (generally more than 25 percent), and it reaches shares a financial holding company acquired under section 4(k)(4) of the BHC Act. The instructions’ examples include commercial finance, leasing and mortgage banking companies, small business investment companies and data processing firms. A subsidiary domiciled outside the United States reports on the FR 2314 or FR 2314S instead, where it meets the reporting thresholds for those reports.

The $500 million gate sits well below the FR Y-9C threshold

Quarterly filing needs two conditions at once: a top-tier holding company with total consolidated assets of $500 million or more as of June 30 of the preceding year, or one that files the FR Y-9C to meet supervisory needs, and a subsidiary that meets at least one of four tests. The $500 million figure is easy to misread as the FR Y-9C cut-off, which the FR Y-9 instructions set at $3 billion. A holding company between the two that files only the parent-only FR Y-9SP still passes the FR Y-11 gate.

Operating revenue is total interest income plus total noninterest income, before expenses. Where the U.S. holding company is itself owned by a foreign banking organization, the U.S. holding company’s operating revenue and equity capital serve as the top-tier figures. Test (4) refers to the subsidiary’s consolidated operating revenue although the report is prepared parent-only; I read that as sizing the subsidiary with its own subsidiaries included, and the instructions say no more.

A subsidiary that qualifies because it was newly formed or came out of a business combination starts quarterly filing with the first quarterly report date after the inception or combination. Once in, the instructions expect complete quarterly reports going forward, but where the holding company still passes the gate and the subsidiary has met none of the other quarterly criteria for four consecutive quarters, the holding company may revert to annual filing from the first upcoming December report date. A Reserve Bank may also ask for quarterly filing from a subsidiary below the thresholds that it has determined has significant risk exposures.

Exemptions that take a subsidiary out of the report

Apart from the $250 million floor in the table above and the exemption for subsidiaries divested or liquidated during the year, the exemptions listed in the General Instructions fall into three groups.

• Another regulator or report covers the entity: a subsidiary whose primary or functional regulator is an organization other than the Federal Reserve, such as the SEC, the CFTC, a state insurance commissioner or a state securities department; U.S. federally insured companies and any subsidiary of a bank or insured company; subsidiaries filing the FR 2886b, the FR 2314 or FR 2314S, or the FR Y-20; and a Federal Reserve member nondepository trust company required to file the Consolidated Reports of Condition and Income, covered in our FFIEC Call Report guide.
• The way the shares are held, or the entity’s purpose: shares held for debts previously contracted under section 4(c)(2), in a fiduciary capacity under section 4(c)(4) or solely as collateral; merchant banking investments under section 4(k)(4)(H); SBIC controlled investments; leasing special purpose vehicles; trust preferred issuers; inactive subsidiaries; and namesavers that have never conducted business.
• The group sits under a qualified foreign banking organization as defined in section 211.23(a) of Regulation K, except where the subsidiary belongs to a U.S. holding company that is itself the qualified FBO’s direct subsidiary.

Two details are easy to invert. SBICs appear among the nonbank subsidiaries that report while the companies an SBIC controls are exempt, so the SBIC can be a reporting subsidiary and its portfolio companies are not. A newly incorporated subsidiary escapes only until it starts a business activity. In the other direction, a subsidiary outside every criterion may still be required to file by the Reserve Bank of the district in which it is registered.

One legal entity per report, prepared parent-only

The reports go in for each legal entity, and consolidation of individual entities, variable interest entities included, is not permitted. A nonbank subsidiary that owns qualifying nonbank subsidiaries reports parent-only, each qualifying lower-level subsidiary gets its own report, and each VIE is tested separately against the definition of subsidiary. The FR Y-11 count therefore follows the legal-entity chart.

What the report contains: Schedules IS through BS-M, the notes and the five FR Y-11S items

The detailed FR Y-11 is a ten-page form: a signed page 1, a Detailed Listing of Subsidiaries kept in the holding company’s files, and for each subsidiary the schedules below plus a notes page. Every amount carries an MDRM code with the BHCS prefix, with BHCT on a few cross-schedule totals.

Income statement and allowance schedules

Schedule IS splits interest income, interest expense, noninterest income and noninterest expense between nonrelated and related organizations. Item 11 picks up the parent subsidiary’s share of its own subsidiaries’ undistributed income, with dividends from them in item 1.b, and item 8.b, the change in net unrealized holding gains (losses) on equity securities not held for trading, is to be completed by every filer because all institutions are now required to have adopted ASU 2016-01.

Item 4 carries the provision for credit losses on all financial assets and off-balance-sheet credit exposures within ASC Topic 326. The IS-B memoranda capture provisions on other financial assets at amortized cost (M.1), the related allowance (M.2), provisions on off-balance-sheet credit exposures (M.3) and expected recoveries of amounts previously written off within the loan allowance (M.4). One sentence under M.1 in the current IS-B instructions still says off-balance-sheet provisions are reported in Schedule IS item 7. The Board’s February 2025 notice stated that they belong in item 4 and are excluded from item 7, and the form footnote and validity edit 175 build item 4 that way, so I read the M.1 sentence as leftover text; the edit is what a submission has to pass.

Balance sheet, off-balance-sheet items and related-institution balances

Schedule BS items 1 to 7 exclude balances with related institutions, item 8 totals claims on nonrelated organizations, and item 9 reports balances due from related institutions gross, with item 16 doing the same for balances due to them. “Related” reaches any organization that controls the reporting subsidiary, any organization it controls, any organization controlled by a holding company that controls it, and all associated companies.

Item 9 also carries investments. The instructions place the subsidiary’s investment in all of its subsidiaries, consolidated or not, and in associated companies, joint ventures and similar significant-influence investees in the same line, less dividends paid or declared. Schedule BS-M breaks that investment out in item 4, while BS-M item 9.c excludes it, and quality edit 800 expects BS-M items 9.a to 9.c plus item 4 to come to no more than BS item 9. A ledger that books equity-method investments outside the intercompany accounts needs that reclassification before the schedules agree.

Items 20 to 30 report unused commitments, letters of credit, foreign exchange commitments, futures, forwards, options and swap notionals, gross for unused commitments, including transactions with related organizations and excluding litigation contingencies. Their sum is the figure the $5 billion quarterly test reads, so these lines are also next year’s scoping input.

Loans, memoranda and the notes page

Schedule BS-A excludes transactions with related institutions and breaks the remaining loans into five categories, then reports balances 30 to 89 days past due and still accruing, 90 days or more past due and still accruing, and nonaccrual. Item 7.d isolates, within those balances, loan modifications to borrowers experiencing financial difficulty under ASU 2022-02 that are past due 30 days or more and still accruing or in nonaccrual status on the report date, counting only modifications in the previous 12 months that involve principal forgiveness, an interest rate reduction, an other-than-insignificant payment delay or a term extension. Memoranda item 1.a on closed-end 1-4 family loans with negative amortization applies to every subsidiary, items 1.b and 1.c only where such loans exceeded 5 percent of total loans and leases at the previous December 31.

BS-M item 2.a is the one count in the financial schedules, the actual number of loans and other assets in the servicing portfolio. The notes page takes up to ten entries, each with a schedule and item reference, a description and an amount in thousands, for material transactions no existing line can show; quality edits 8000 to 8009 expect a description wherever a note amount is entered.

The FR Y-11S: five items

The FR Y-11S is a three-page form whose data page holds five items: net income, total assets, equity capital, total off-balance-sheet items, and a yes-or-no answer on whether the subsidiary has elected a fair value option with changes in fair value recognised in earnings. The first three use the FR Y-11 MDRM codes (BHCS4340, BHCS2170 and BHCS3210), and the report is as of the close of business on the last calendar day in December only.

Units, signs and rounding

All financial items are reported in thousands of U.S. dollars, rounded to the nearest thousand, with items under $500 reported as zero. Foreign-currency amounts are converted at report-date exchange rates unless GAAP requires otherwise, and trade-date accounting is preferred, with settlement-date accounting acceptable where amounts are not materially different. Negative entries are generally not appropriate unless a line item allows them, so an asset with a credit balance goes to a liability item; where negatives are allowed, electronic filers use a minus sign. Where the Federal Reserve’s interpretation of GAAP or the instructions for a transaction differs from the filer’s, it may require the filer to report the transaction its way and amend previously submitted reports.

Every item takes an entry, an amount, a zero or “N/A”, and the instructions draw the line between the last two precisely: “N/A” where the subsidiary cannot be involved in the activity because of the nature of the organization, zero where it can participate but has no outstanding balance on the report date.

FR Y-11 reporting deadlines: report dates and the 60-day submission clock

Quarterly filers report as of the last calendar day of March, June, September and December; annual FR Y-11 and FR Y-11S filers report as of December 31 only. For every report date the holding company must file no later than 60 calendar days after the report date.

The right-hand column is my arithmetic from the 60-day rule, before any weekend or holiday roll. The New York Fed’s notice for the June 30, 2024 report date confirms the June result, with an FR Y-11 and FR 2314 deadline of August 29, 2024, and set the FR Y-9C deadline twenty days earlier, on August 9, 2024, so an internal timetable built around the FR Y-11 deadline would miss the FR Y-9C.

When the deadline falls on a weekend or holiday, the report must be received by 5:00 P.M. on the first business day after it. Mail is timely if sent first class and postmarked no later than the third calendar day before the deadline, with a Postal Service Certificate of Mailing (form 3817) as proof where there is no postmark; an overnight service is timely if the completed originals enter its system the day before the deadline; and hand delivery to the mailing address on or before the deadline is acceptable. In the weekend or holiday case, a report received after 5:00 P.M. on that next business day is late unless it was postmarked three calendar days before the original deadline or the institution has a record of sending it by overnight service one day before the original deadline.

A company that cannot obtain the required officers’ signatures in time may contact its Reserve Bank to arrange timely submission of the data, with the signed reports to follow. The first applicable report date follows the scoping rules above: March 31 after a qualifying June 30 for quarterly filers, the first quarter-end after a formation or combination, or the December 31 at which an annual band is met. After that, the next applicable date is the next quarter-end or the next December 31.

Submission: Reserve Bank filing, Reporting Central files, signatures and amended reports

Reports go to the Federal Reserve Bank where the holding company submits its FR Y-9C or FR Y-9SP, on the Reserve Bank’s forms with no caption changed. The General Instructions still treat paper as the base case, typed or in ink, with matching computer printouts acceptable and pencil rejected, and tell a holding company interested in electronic submission to contact its Reserve Bank. The electronic channel is Reporting Central, which the New York Fed describes as a single point of entry for electronic submission and file uploads, reached through FedLine Web Access Solutions.

Reporting Central file layouts

The Reporting Central user guide for the FR Y-11 and FR Y-11S, dated August 2026, allows two text layouts keyed by the eight-character MDRM code. In the Reporting Central format each item starts with “L”, then the MDRM and as many “+” signs as the form’s maximum number of data columns, with values after each “+” and text values wrapped in two underscore characters on each side. The CIPS format separates items with commas and writes a positive value with a plus sign, a zero as “+0” and a null as “-0”.

A Reporting Central header holds the RSSD ID padded to ten characters with leading zeros, the series name “FRY11” plus five spaces (or “FRY11S” plus four) and the as-of date as MM-DD-YYYY. A CIPS header holds an eight-character series password from the Reserve Bank analyst, the series name, the as-of date as YYMMDD, the ten-digit RSSD ID, a date stamp and a time stamp with two zeros added, and the whole CIPS file sits inside parentheses. Only one file upload can be submitted per respondent and as-of date, and BHCS9999, the date-of-report item, should no longer be included after the Cloud migration.

Two cautions apply. The guide’s upload step refers to selecting a stored XML file, yet every layout it specifies is a text file and it gives no XML structure for this series; the instructions and form say nothing about XBRL or any other taxonomy. More consequential, Appendix A lists the IS-B column B and C codes in a different order from the form. The form and validity edits 175, 255 and 260 put the provision in BHCSJH90 and BHCSJH96, adjustments in JH91 and JH97 and charge-offs in JH92 and JH98, while the appendix pairs charge-offs with JH90 and JH96, so a file mapped from the appendix would load charge-offs into the provision fields.

Signatures, records and the detailed listing

A duly authorized officer of the holding company signs page 1, acknowledging that a knowing and willful misrepresentation or omission of a material fact constitutes fraud in the inducement and may bring sanctions under 18 U.S.C. 1001 and 1007; a top-tier holding company domiciled outside the United States may authorize an officer of the nonbank subsidiary to sign. Where one signature covers several subsidiaries, the holding company submits one signed page 1 per report type (FR Y-11 quarterly, FR Y-11 annual, FR Y-11S), states the number of reports attested and, on the December FR Y-11, enters filing code “1” for annual or “2” for quarterly filers.

The Detailed Listing of Subsidiaries gives the legal name, address and subsidiary ID of every report attested, using the legal name on the formation documents, which must match the Report of Changes in Organizational Structure (FR Y-10). It stays in the holding company’s records and should not be submitted. Paper and electronic filers keep a physical or scanned copy of the manually signed page 1, the listing and a printout of the data submitted for three years.

Amended reports

The Federal Reserve may require amended reports where submitted ones contain significant errors, and a holding company should file one when internal or external auditors make adjustments that restate the financial statements behind earlier reports. An amendment needs a newly signed page 1 and separate financial statements for each subsidiary whose data change, with a completed listing kept on file. Where required data are unavailable, the instructions send the respondent to the Reserve Bank.

Validation: validity edits, quality edits and the year-to-date intraseries checks

The instructions book prints the validity edits and the essential quality edits, each table last updated December 31, 2025, with effective dates, target items, MDRMs and both plain-language and algorithmic tests. Validity edits are “must” tests, quality edits “should” tests, and intraseries edits compare the report with an earlier one; the instructions note that many reporting errors can be screened through the validity checks.

The validity edits are mostly identities: the Schedule IS subtotals, IS-A item 2 against IS item 12 (edit 230), IS-A item 7 against BS item 18.g (350), BS-A item 6 against BS item 3.a (270), IS-B item 6 column A against BS item 3.b (280), total liabilities and equity capital against total assets (370), and edit 175 on IS item 4. Page 1 is where an internally consistent file can still fail: edit 100 requires a December filing code of “1” or “2”, edit 101 requires it to be empty in March, June and September, edit 120 requires at least one report attested, and edits 8010 to 8020 require the officer’s name, title and signature date (MM/DD/YYYY), the contact’s name, phone and e-mail, and a consistent pair of confidentiality answers.

The intraseries edits encode the year-to-date basis. For quarterly filers, edits 551 to 558 and 640 expect cumulative interest income and expense, fiduciary income, deposit service charges, investment banking fees, insurance commissions and dividends declared in June, September and a December report with filing code “2” to be no lower than the previous quarter’s figure.

Intraseries edit 600 compares IS-A item 1 with the previous December’s BS item 18.g, allowing a difference of up to $1 million (1,000 in thousands) for quarterly filings. A separate quality edit 600 requires exact equality for December annual filers with filing code “1”, where the prior-year balance is available. Edit 670 compares IS-B item 1 column A with the previous December’s BS item 3.b under its specified conditions. Because IS-A item 1 must also include, net of tax, corrections of material prior-year errors never corrected by an amended report, an unamended correction above $1 million would trip edit 600.

The quality edits test reasonableness: fiduciary income and deposit service charges should not be negative, realized securities gains or losses imply held-to-maturity or available-for-sale holdings (580), and the BS-M breakdowns of balances due to related institutions should not exceed BS item 16 (830). On the FR Y-11S, validity edit 0100 requires the fair value option answer to be “1” or “0”, and quality edits expect total assets from $250 million to below $500 million (0900), net income below total assets (0920), equity capital no larger than total assets (0940) and off-balance-sheet items from zero to below $5 billion (0960). Neither the instructions nor the Reporting Central guide say how a quality-edit exception is explained; the instructions name the Reserve Bank in the district where reports are submitted as the address for interpretation questions.

Caveats and interactions: confidentiality, neighbouring reports, Reserve Bank discretion and lapsed relief

Public on request unless confidential treatment is granted

FR Y-11 and FR Y-11S reports are available to the public upon request on an individual basis, and the Board’s report page describes the microdata as public information, with certain exceptions, through its Freedom of Information Office. A holding company may request confidential treatment for one or more subsidiaries where disclosure would likely cause substantial competitive harm or an unwarranted invasion of personal privacy. The request must be in writing, concurrent with the submission, and demonstrate the specific harm, since a bare statement that harm would result is not sufficient; the information concerned should be bound separately under its own page 1 labelled “CONFIDENTIAL”.

The page 1 check boxes carry their own consequence: a filer that does not meet both requirements, or does not check the boxes saying whether the justification letter is enclosed or sent separately, will not have confidential treatment considered, and the answers to those questions are themselves public. Granted treatment can also end later: the instructions let the Federal Reserve release the information under its rules on availability of information or as otherwise provided by law, notifying the institution first. The instructions still cite 12 CFR 261.16 for that release, a section that now covers fee schedules and fee waivers; requests for confidential treatment and the Board’s process for deciding them sit in sections 261.17 and 261.18 of 12 CFR part 261.

The reports that sit beside the FR Y-11

The FR Y-11 belongs to a family of subsidiary-level returns whose exemptions keep a subsidiary in only one. A foreign-domiciled subsidiary goes to the FR 2314, whose instructions exempt subsidiaries required to file the FR Y-11 or FR Y-11S. U.S. nonbank subsidiaries an FBO holds other than through a U.S. bank holding company, financial holding company or U.S. bank fall under the FR Y-7N, whose instructions exempt subsidiaries of a U.S. bank holding company reporting on the FR Y-11; the FBO capital return is covered in our FR Y-7Q guide. Merchant banking investments, exempt here, are captured in the FR Y-12’s nonfinancial equity investment totals for holding companies above that report’s threshold, as our FR Y-12 reporting guide explains.

The instructions also lean on the FR Y-9C and FR Y-9SP books for definitions, which in my reading means a change to the FR Y-9C glossary can alter what an FR Y-11 line captures without any change to the FR Y-11 book.

Proportionality and Reserve Bank discretion

The proportionality is the tiering itself: the five-item FR Y-11S between $250 million and $500 million, the detailed report once a year up to $1 billion, and quarterly reporting only behind the holding-company gate. The instructions describe no waiver or extension procedure, and the discretion they grant runs toward more reporting, including the Federal Reserve’s reserved right to require additional information where the report is not sufficient to appraise a subsidiary’s financial soundness or compliance with applicable laws.

Footnotes that no longer apply

Three footnotes in the General Instructions still describe temporary threshold relief measured on the lesser of the normal measurement date or a December 31, 2019 as-of date. Each is limited to report dates through December 31, 2021, so the text has no effect on any later report date.

Recent and upcoming changes: the 2025 revisions, the December 2025 edit book and the 2028 clearance date

The 2025 cycle was the substantive one. The February 5, 2025 notice proceeded with the June 2024 proposal with certain modifications and set March 31, 2025 as the effective date, a quarter later than proposed. It aligned the reporting of loan modifications to borrowers experiencing financial difficulty with ASU 2022-02, now BS-A item 7.d, and the proposal’s other GAAP-driven changes covered provisions on off-balance-sheet credit exposures and expected recoveries, which IS-B memoranda M.3 and M.4 now capture. Answering the single comment letter, the Board also stated that off-balance-sheet and allocated transfer risk provisions belong in Schedule IS item 4.

The December 2025 edition changed the edit tables, while the form pages carry dates no later than March 2025. The four revised edits are quality edit 565 (an IS-B column A provision implies a non-zero allowance in BS item 3.b), quality edit 610 (IS-A item 3 no larger than stock plus surplus where surplus is not negative) and the two versions of edit 670 tying the opening loan allowance to the previous December.

Nothing in the current materials changes the thresholds. The Bank Policy Institute’s May 26, 2026 letter argues they should be updated for inflation and economic growth, noting that the annual-reporting criteria had not been updated since 2013, but a trade-association letter is a request and a change would need a Board notice and revised instructions. The fixed date ahead is March 31, 2028, when the OMB approval printed on the forms expires; the Board has run earlier renewals of this collection through Federal Register notices like the 2024 and 2025 ones.

Frequently Asked Questions

A nonbank subsidiary crosses $1 billion in total assets in the third quarter through ordinary growth. When does quarterly filing start?

The ordinary quarterly classification is based on the preceding June 30 measurement date, while a newly formed subsidiary or one arising from a business combination may trigger quarterly reporting at the first subsequent quarter-end. The annual detailed-report threshold is assessed at the December 31 report date. A subsidiary that crosses $1 billion through ordinary growth after June 30, without having met the earlier quarterly tests, presents a classification question that should be resolved with its Federal Reserve Bank before the December filing. If the subsidiary still meets a quarterly test at the following June 30, quarterly filing starts with the March report after that. The annual band as written stops below $1 billion, so the question of which report such a subsidiary files in the interim December goes to the Reserve Bank where the reports are submitted.

Two holding companies own a nonbank company 50/50. Which one files, and whose related parties count?

The holding company with majority ownership files the whole report, and where ownership is equal, the largest by total consolidated assets files it. The related-organization definition reaches across both owners: if more than one holding company controls the subsidiary, every organization controlled by each of them is related, whichever one submits.

We sold a qualifying subsidiary in November. Is a December report still due for it?

No. Subsidiaries divested or liquidated during the year are exempt, and reports are due only for subsidiaries in the holding company’s organizational structure at the close of business on the report date. That rule also fixes the December list by the structure on December 31 itself, so a disposal that slips past year-end leaves the report due.

The subsidiary keeps a June fiscal year. Can Schedule IS follow it?

No. Schedule IS reports income and expense for the calendar year-to-date, and the intraseries edits test that cumulative figures do not fall within the calendar year. A non-calendar fiscal year needs a calendar-year cut for every FR Y-11, with post-period adjustments to accruals and estimates that relate to the period booked into it.

Our reporting nonbank subsidiary owns an SEC-registered broker-dealer. Does the broker-dealer appear anywhere in the FR Y-11?

As a subsidiary whose functional regulator is the SEC, the broker-dealer is exempt from a report of its own, and it appears in its parent’s parent-only statements: the investment in BS item 9 with the breakout in BS-M item 4, its undistributed earnings in Schedule IS item 11 and its dividends in item 1.b. Balances between the two are related-institution balances, reported gross.

An FR Y-11S filer reaches $500 million in total assets at December 31. Which report is due?

The annual bands are measured as of the report date, so a subsidiary at $500 million or more and below $1 billion on December 31 owes the detailed annual FR Y-11 for that date. An abbreviated report filed instead would also fail quality edit 0900, which expects FR Y-11S total assets below $500 million.

Related Articles

• FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period: the September 2026 update to the consolidated holding company report whose glossary the FR Y-11 instructions rely on.
• FR Y-7Q Reporting: The Fed’s Capital and Asset Report for FBOs: who files the FBO capital report, what its parts hold and its 70-day deadline.
• FR Y-12 Reporting: Thresholds, Schedules and the 45-Day Deadline: the holding company report on nonfinancial equity investments, including merchant banking holdings.
• FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026: which bank-level Call Report form applies and how its deadline works.
• FR Y-15 Reporting: The Fed’s Systemic Risk Report, Schedule by Schedule: which holding companies and FBOs file the Board’s Systemic Risk Report and what Schedules A to N hold.

Key Takeaways

• Diary May 30, August 29, November 29 and March 1 (February 29 in leap years) as the sixtieth days, and treat the group deadline as missed if any one subsidiary report is late.
• Treat a top-tier holding company between $500 million and $3 billion as inside the FR Y-11 quarterly gate even when it files the FR Y-9SP instead of the FR Y-9C.
• Build each report parent-only, one legal entity at a time, with equity-method investments in BS item 9 and broken out in BS-M item 4.
• Map IS-B columns B and C from the report form, with the provision in JH90 and JH96; the Reporting Central appendix lists those codes in a different order.
• Book material prior-year corrections through an amended report where possible, or expect edit 600 to flag an opening-equity gap above $1 million.
• Submit any written confidentiality request concurrently with the report, tick the page 1 boxes and bind the confidential data under a separate page 1 marked “CONFIDENTIAL”.
• Keep the signed page 1, the detailed listing and a data printout for three years, and leave the listing out of the submission.

Sources and References

• Board of Governors of the Federal Reserve System, Instructions for the Preparation of Financial Statements of U.S. Nonbank Subsidiaries of U.S. Holding Companies, FR Y-11 and FR Y-11S, Effective December 2025 (General Instructions, line-item instructions and edit tables): FR Y-11/FR Y-11S instructions (PDF)
• Board of Governors, FR Y-11 and FR Y-11S reporting forms, OMB No. 7100-0073: FR Y-11/FR Y-11S reporting form (PDF)
• Board of Governors, FR Y-11/FR Y-11S report page: federalreserve.gov
• Federal Reserve System, Agency Information Collection Activities: Announcement of Board Approval Under Delegated Authority and Submission to OMB, FR Doc. 2025-02257 (February 5, 2025): Federal Register
• Federal Reserve System, Proposed Agency Information Collection Activities; Comment Request, 89 FR 48639 (June 7, 2024): govinfo.gov
• Federal Reserve System, Reporting Central User Guide, FR Y-11 and FR Y-11S (August 2026): frbservices.org (PDF)
• Federal Reserve Bank of New York, Holding Companies Reporting Requirements for June 30, 2024 (July 9, 2024): newyorkfed.org (PDF)
• Board of Governors, FR Y-9SP instructions, Effective December 2025 (FR Y-9C and FR Y-9SP size thresholds): FR Y-9SP instructions (PDF)
• Board of Governors, FR 2314 and FR 2314S instructions, Effective December 2025: FR 2314/FR 2314S instructions (PDF)
• Board of Governors, FR Y-7N and FR Y-7NS instructions, Effective December 2025: FR Y-7N/FR Y-7NS instructions (PDF)
• Board of Governors, FR Y-12 reporting form (Memoranda item 2, merchant banking investments): FR Y-12 form (PDF)
• 12 U.S.C. 1844, 1467a, 1850a and 5365: 1844, 1467a, 1850a, 5365 (law.cornell.edu)
• 12 CFR 252.153, paragraph (b)(2), 2025 edition: govinfo.gov
• 12 CFR part 261, Rules Regarding Availability of Information, sections 261.16 to 261.18, 2025 edition: govinfo.gov
• Bank Policy Institute, BPI Comments on Federal Reserve FR Y-11 and FR 2314 Reporting Requirements (May 26, 2026): bpi.com

Building the FR Y-11 filing list before the June 30 measurement date

The filing list is the control point for the cycle. Each June 30, measure every U.S. nonbank subsidiary’s total assets, the sum of Schedule BS items 20 to 30, its equity capital and its consolidated operating revenue against the top-tier holding company’s figures, strike out exempt entities and record each survivor’s outcome. Then re-run the annual bands on December 31 figures and have the signed page 1 for each report type, the detailed listing and the upload files ready so that every subsidiary report reaches the Reserve Bank by the deadline.

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