FR Y-7Q Reporting: The Fed’s Capital and Asset Report for FBOs

ByRegReportingDesk
RegReportingDesk card: Federal Reserve, Board of Governors of the Federal Reserve System, United States

FR Y-7Q reporting is how the Federal Reserve Board collects consolidated capital and asset figures from every foreign banking organization (FBO) with a U.S. banking presence. The form, formally the Capital and Asset Report for Foreign Banking Organizations (OMB control number 7100-0125), runs to four pages in U.S. dollar millions. Since the 31 December 2024 report date, every filer has had 70 calendar days to deliver it to its Reserve Bank, under a revision the Board approved in December 2023.

The short form carries more weight than its length suggests. Regulation YY (12 CFR part 252) defines an FBO’s combined U.S. assets by reference to the figure reported on the FR Y-15 or the FR Y-7Q, and its U.S. non-branch assets by reference to the FR Y-7Q alone. Those two measures sit inside the Regulation YY thresholds for enhanced prudential standards and for the requirement to form a U.S. intermediate holding company, so items 6 and 7 of Part 1A are threshold numbers as well as report lines.

The Board describes the collection as consolidated regulatory capital information that it uses to assess an FBO’s ability to be a continuing source of strength to its U.S. banking operations and to determine compliance with U.S. laws and regulations. Its February 2025 burden estimate counted 122 quarterly and 19 annual respondents.

Related reading: FR 2052a Reporting: Complex Institution Liquidity Monitoring Report

The fixed FR Y-7Q calendar under the current instructions:

  • Report dates: 31 March, 30 June, 30 September and 31 December for quarterly filers; 31 December for annual filers.
  • Remittance: received by the Reserve Bank no more than 70 calendar days after the report date, by 5:00 p.m. at that Reserve Bank. By my count that lands on 9 June, 8 September, 9 December and 11 March (10 March when February has 29 days).
  • Weekend or holiday deadline: due by 5:00 p.m. on the first business day afterwards.
  • Extension request: normally no later than 30 calendar days before the deadline.
  • Public availability on request: 120 days after the quarterly or annual as-of date, unless confidential treatment is granted.

The form states that the report is required by law under section 5(c) of the Bank Holding Company Act (12 U.S.C. 1844(c)) and sections 8(c) and 13 of the International Banking Act (12 U.S.C. 3105(c), 3106(c) and 3108). The issuing authority is the Board of Governors of the Federal Reserve System. The FBO prepares the report under the Board’s instructions, and the Federal Reserve Banks receive it and monitor filings for timeliness and accuracy. The current form carries OMB approval to 31 March 2028.

Frequency, deadlines and line definitions live in those instructions, and the Board changes them through Paperwork Reduction Act notices in the Federal Register. The move from a 90-day to a 70-day deadline came that way, in an announcement of Board approval under delegated authority published on 11 December 2023 (88 FR 85886).

A second layer comes from Regulation YY. Sections 252.143 and 252.154 require two groups of FBOs to certify to the Board that they meet capital adequacy standards on a consolidated basis, set by the home-country supervisor and consistent with the Basel Committee’s capital framework: FBOs with average total consolidated assets of $250 billion or more and combined U.S. assets below $100 billion, and FBOs with combined U.S. assets of $100 billion or more. Paragraph (b) of each section requires reports on compliance with those capital measures to be provided concurrently with the FR Y-7Q, and Part 1B of the form is where the figures go. Section 252.143(a)(1)(i) defines Basel-consistent standards to include all minimum risk-based capital ratios, any minimum leverage ratio and all restrictions based on applicable capital buffers in Basel III. The buffer and leverage lines in Part 1B follow that list.

Falling short has a stated consequence. Under sections 252.143(c) and 252.154(c), the Board may impose requirements, conditions or restrictions relating to the activities or business operations of the U.S. operations. It notifies the FBO first and describes the basis, and the FBO has 14 calendar days to request reconsideration in writing.

The reporting perimeter starts in Regulation K. Under 12 CFR 211.21(o), an FBO is a foreign bank that operates a branch, agency or commercial lending company subsidiary in the United States, controls a U.S. bank, or controls an Edge corporation acquired after 5 March 1987, together with any company of which that foreign bank is a subsidiary. Regulation YY adopts the same definition in 12 CFR 252.2, except that a top-tier FBO incorporated or organized under the laws of any State is not treated as an FBO for Regulation YY purposes.

Who must report the FR Y-7Q: top-tier FBOs, the $50 billion switch and FHC status

Every top-tier FBO files. The Board’s report page describes the panel as all FBOs organized under foreign law that engage in U.S. banking through subsidiary banks, Edge or agreement corporations, subsidiary commercial lending companies, or branches and agencies, and it calls the reports mandatory. A foreign bank whose only U.S. offices are branches or agencies is inside that description. The instructions contain no size-based exemption; the smallest filers move to an annual frequency.

The top-tier reporter is generally the same entity that files the annual FR Y-7. For some tiered groups the instructions say the initial determination may require consultation with Federal Reserve staff, based primarily on whether the top-tier entity provides capital ratio information to its home-country authorities.

Part 1A: quarterly or annual

A top-tier FBO reports Part 1A quarterly in two cases: where the FBO or any FBO in its tiered structure has effectively elected to be a financial holding company (FHC), and where the FBO has total consolidated assets of $50 billion or more as of the report date, whatever its FHC status. Non-FHC groups below $50 billion report annually.

The $50 billion test reads item 5, the group’s worldwide consolidated assets. A large bank with one small U.S. branch is a quarterly filer, and the size of the U.S. operation plays no part in the Part 1A frequency decision.

The switch is sticky. An FBO that reaches $50 billion begins quarterly Part 1A reporting as of the first quarter in which it reached that level, and it stays quarterly until it has reported less than $50 billion for each of the four quarters in a full calendar year. Only then does a non-FHC FBO revert to annual reporting, and a later report of $50 billion or more sends it straight back to quarterly.

Part 1B: the Regulation YY capital certifiers

Part 1B is reported quarterly by each top-tier FBO with combined U.S. assets of $100 billion or more, or with combined U.S. assets below $100 billion and total consolidated assets of $250 billion or more. Those are the populations of sections 252.154 and 252.143.

Part 2: lower-tier FBOs in FHC groups

Part 2 applies only where the top-tier FBO or an FBO in its tiered structure has FHC status. It is reported quarterly for each lower-tier FBO that operates a U.S. branch or agency, or owns an Edge or Agreement corporation or a commercial lending company subsidiary in the United States. Each qualifying lower-tier FBO gets its own Part 2, and top-tier figures stay in Parts 1A and 1B.

The reason for the lower-tier detail sits in Regulation Y. Under 12 CFR 225.90(a), a foreign bank is treated as an FHC only if the foreign bank, any other foreign bank that maintains a U.S. branch, agency or commercial lending company and is controlled by the foreign bank or by a company that owns or controls the foreign bank, and any U.S. depository institution subsidiary are and remain well capitalized and well managed. Section 225.90(b) sets the well-capitalized test for a foreign bank at a 6 percent Tier 1 ratio and a 10 percent total capital ratio under Basel-consistent home-country standards, with capital comparable to that required of a U.S. bank owned by an FHC, or a Board determination of comparability. I read Part 2 as the Board’s capital feed for those controlled foreign banks; the instructions themselves do not draw the link.

What the report contains: page 1, Part 1A, Part 1B and Part 2

Page 1 carries the FBO’s legal name, which must match the name on the Report of Changes in Organizational Structure (FR Y-10), the mailing address, a contact person in the United States, the signing officer’s details and the confidentiality check box. Three data pages follow.

Part 1A items 1 to 5: home-country capital

Item 1 asks whether the home-country supervisor requires the FBO to calculate its capital ratios using a risk-adjusted framework consistent with the Basel Capital Accord, coded 1 for yes and 0 for no. Items 2 to 5 report Tier 1 capital, total risk-based capital, risk-weighted assets and total consolidated assets at the end of the reporting period, each on a consolidated basis. With a yes in item 1, the figures are those the FBO reports to its home supervisor under the Basel framework. With a no, the FBO provides its closest possible approximation.

For a group headquartered in the European Union, the home-country Tier 1, total capital and risk exposure amounts are the consolidated figures it already submits in COREP (see our COREP reporting guide). My working assumption is that those submissions are the natural source for items 2 to 4, translated into dollars; the FR Y-7Q instructions name no home-country template.

Part 1A items 6 to 8: the U.S. footprint

Item 6 reports total combined assets of U.S. operations, net of intercompany balances and transactions between U.S. domiciled affiliates, branches and agencies. Item 6(a) is the total at quarter-end and item 6(b) the average for the quarter. Item 7 reports total U.S. non-branch assets, and item 8 records the as-of date for the financial data in items 2 to 5, in YYYYMMDD format.

Item 6 carries the most build rules. Each top-tier U.S. domiciled affiliate is consolidated with its own subsidiaries under U.S. GAAP, and the totals for those affiliates and for each branch and agency are combined. Whether an affiliate is consolidated follows the instructions for the FR Y-9C (our FR Y-9C reporting article covers that form’s latest instruction changes), and investments in unconsolidated U.S. affiliates are carried under the equity method. Balances between U.S. entities come out. Net balances with non-U.S. affiliates stay in. Assets of companies held under section 2(h)(2) of the Bank Holding Company Act are excluded.

Netting with foreign affiliates runs affiliate by affiliate, and it works in one direction only. Where a U.S. affiliate has both a gross due-from and a gross due-to balance with the same foreign affiliate, the two are netted; a resulting net due-from is added to item 6, while a net due-to is not subtracted. In the instructions’ worked example, U.S. affiliate A ends with a $25 net due-from and affiliate B with net due-from balances of $200 and $15, so $240 is added. Net due-from balances of International Banking Facilities count toward the U.S. affiliate’s assets, and the instruction pages dated May 2025 point to Schedule M of the FFIEC 002 for calculating gross due-to and due-from positions.

Item 7 uses the same build for the top-tier U.S. domiciled affiliates alone, leaving out the branches and agencies, and it also excludes debt previously contracted (DPC) branch subsidiaries. It includes the affiliates’ exposures to the FBO’s U.S. branches and agencies and to non-U.S. affiliates, except where the non-U.S. affiliate is already consolidated into a top-tier U.S. affiliate.

Item 6(b) is measured differently by filer type. Respondents that do not file the FR Y-15 average the three month-end balances in the quarter, and annual filers apply the same averaging to the fourth calendar quarter. FR Y-15 filers that are Category II or III FBOs use daily averages. Other FR Y-15 filers may report either averages or point-in-time values.

Part 1B: Basel III components, buffers and leverage

Part 1B splits capital into common equity tier 1 (item 1), additional tier 1 (item 2), Tier 1 as the sum of the two (item 3), Tier 2 (item 4) and total risk-based capital as the sum of items 3 and 4 (item 5). Items 6 to 8 report the capital conservation buffer, the firm-specific countercyclical buffer and any GSIB buffer, the last excluding the buffers already in items 6 and 7, each as a percentage of risk-weighted assets rounded to four decimal places, for example 12.3456. Item 9 is a yes-or-no on compliance with the restrictions on capital distributions and discretionary bonus payments associated with the buffers. Items 10 to 12, effective from 1 January 2018, report the home-country leverage numerator, the exposure measure and any minimum home-country leverage ratio that differs from the Basel III leverage ratio.

Blank and zero carry different meanings in the buffer lines. A buffer that does not apply must be left blank; “0” is entered when the respondent has none to report for that as-of date. Pro-forma figures enter in two places. Where the home-country calculation of Tier 1 or total capital differs from a Basel-consistent calculation as defined in Regulation YY, Part 1B items 3 and 5 carry pro-forma estimates. Where the home framework is not Basel-consistent, the leverage items 10 to 12 are reported on a pro-forma basis.

Parts 1A and 1B are wired together. Where the home-country and Basel-consistent figures are identical, the instructions derive Part 1A items 2 and 3 from Part 1B items 3 and 5. The validity edits only insist that Part 1A items 2 and 3 be populated directly by FBOs that answer no to item 1 or report total consolidated assets below $50 billion.

Part 2 and the reporting conventions

Part 2 repeats the Part 1A pattern for each qualifying lower-tier FBO: its legal title and country, the Basel-consistency question, Tier 1 capital, total risk-based capital, risk-weighted assets, total consolidated assets and the as-of date, each on a consolidated basis for that lower-tier FBO.

Amounts are in U.S. dollars, and the form headers specify millions. Items translated from foreign currency use the rate effective on the as-of date of the report. Buffer and leverage percentages carry four decimal places. The instructions state no sign convention; the quality edits expect Tier 1 capital, risk-weighted assets and total consolidated assets to be greater than zero, and items 6(a) and 7 to be non-negative.

FR Y-7Q deadlines: report dates, fiscal-year data and the 70-day clock

The report date for an annual filer is 31 December; quarterly filers report for the four calendar quarter-ends, and each quarterly report is due 70 calendar days after its quarter-end date (for 30 September, that is 9 December). Calendar periods are preferred, but an FBO whose fiscal year differs may report items 2 to 5 from its most recent fiscal year or fiscal quarter, with item 8 showing the true as-of date. The instructions give two examples: a fiscal year ending 31 October feeds the 31 December annual report with item 8 reading 20021031, and a quarterly filer reporting for 31 March with data to 31 January enters 20030131.

Fiscal flexibility stops at the U.S. lines. Items 6(a), 6(b) and 7 are always reported for the calendar quarter-end, and the instructions require the reports to be submitted on the quarter-end schedule whatever date item 8 shows.

The remittance rule is receipt by the appropriate Reserve Bank no more than 70 calendar days after the report date, by the end of the reporting day, 5:00 p.m. at that Reserve Bank. Paper filings have their own timeliness tests: a report mailed and postmarked no later than the third calendar day before the deadline counts as on time, as does hand delivery by the deadline. A deadline on a weekend or holiday moves to 5:00 p.m. on the first business day after it, and a report arriving later than that 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. Earlier submission is encouraged.

Extensions exist and are narrow. Home-country practices that prevent reporting within 70 days might justify one, but only after consultation with Federal Reserve staff. An FBO that cannot meet the deadline must tell its Reserve Bank as soon as possible, normally no later than 30 calendar days before the deadline, giving the reason and the date it will file.

The first applicable report date depends on the trigger. A group that crosses $50 billion begins quarterly Part 1A reporting with the quarter in which it got there. For Part 1B the narrative instructions give no start rule, but the validity edits require the Part 1B items whenever either threshold was met in the current quarter or any of the prior four. The instructions do not address the first report date for an organization that becomes an FBO part-way through a year.

Submission to the Reserve Bank: paper, Reporting Central and the signed page 1

The report goes to the appropriate Federal Reserve Bank. The instructions describe paper submission first and treat electronic filing through Reporting Central as an option, for which FBOs contact their district Reserve Bank or the Reporting Central pages on frbservices.org. An FBO that files electronically must keep the original manually signed page 1 of the Reserve Bank-supplied form for that report date in its files, attached to a printout of the data submitted.

Reporting Central is the Federal Reserve’s single point of entry for electronic report submission, by direct data entry or file upload, reached through the FedLine Web access solution. Access runs through End User Authorization Contacts, and the frbservices.org setup page asks organizations planning EUACs or subscribers located outside the United States to contact the Customer Contact Center. Where the capital team sits at a head office abroad, that request has to be raised before the first electronic filing.

Neither the instructions nor the form specify an XBRL taxonomy, an XML schema or a file-naming convention. Each data point carries a mnemonic and item code on the form, which the edit tables call MDRM numbers: FBOQ 8274 for Tier 1 capital, FBOD 2170 for item 6(a), FBOQ C116 for the as-of date. Those codes give a stable key for mapping between the general ledger, the home-country capital return and the FR Y-7Q.

An authorized officer of the FBO signs page 1, attesting that the report conforms to the Federal Reserve’s instructions and is true and correct to the best of the officer’s knowledge and belief. The instructions warn that a knowing and willful misrepresentation or omission of a material fact may expose the officer to legal sanctions under 18 U.S.C. 1001 and 1007.

Confidentiality is opt-in. The completed report is generally available to the public on request 120 days after the as-of date, and the Board’s report page states that FR Y-7Q data are not published. A respondent seeking confidential treatment must make the request in writing with the submission and justify it under exemption 4, 6 or 8 of the Freedom of Information Act. On page 1 it must answer the confidentiality question and, if the answer is yes, indicate whether the justification letter is included with the submission or provided separately; the instructions add that page 1 should be labelled “CONFIDENTIAL”. If the institution does not fulfil both requirements or does not check the appropriate boxes, confidential treatment will not be considered, and the answers to the page 1 confidentiality questions are themselves public information.

Validation edits: what the FR Y-7Q checklist tests

The instructions close with two edit tables, validity edits and quality edits, both effective for the 31 December 2023 report date. The validity table opens with a rule that matters for every system build: each edit must balance, and rounding errors are not allowed.

The validity edits fall into four groups:

  • Coding: Part 1A item 1 must be 0 or 1 (edit 1001), as must Part 1B item 9 for in-scope FBOs (1085) and the confidentiality indicator (2025).
  • Completeness: the page 1 officer and U.S. contact fields (1010 to 1034), Part 1A items 4, 5 and 8 (1050, 1052, 1054), and the Part 2 items whenever a lower-tier legal title is entered (1007, 1056 and 2040 to 2055).
  • Conditional completeness: Part 1A items 2 and 3 for FBOs that answer no to item 1 or report less than $50 billion (1046, 1048), and Part 1B items 1 to 5 for FBOs that met either Part 1B threshold in the current quarter or any of the prior four (1060 to 1080).
  • Arithmetic: Part 1B item 3 must equal items 1 plus 2 (1090), and item 5 must equal items 3 plus 4 (1095).

The quality edits are worded as “should” tests. Item 7 should not exceed item 6(a) (0510). Total risk-based capital should be at least Tier 1 capital (0540), and total consolidated assets should exceed risk-weighted assets (0560). Three ratio screens follow: Tier 1 at least 50 percent of total capital (0600), Tier 1 at least 4 percent of risk-weighted assets (0601) and total capital at least 8 percent (0602), the last two labelled in the edit table as minimum ratios; the 50 percent test is a composition check, and the 4 percent Tier 1 screen is a reporting edit, not the Basel III Tier 1 minimum. For Part 1B filers that answer no to item 1, Part 1A item 2 should differ from Part 1B item 3 and Part 1A item 3 from Part 1B item 5 (0725, 0730). Part 1B should be empty for lower-tier FBOs and for FBOs below both thresholds in the current quarter and all prior four (0735).

Read together, the edits show where a submission can fail. A filer that rounds CET1, AT1 and Tier 1 to millions independently can miss edit 1090 by a single unit. One that stops completing Part 1B as soon as it drops below the thresholds fails 1060 to 1080 for up to four quarters. One that answers no to item 1 and copies identical figures into Parts 1A and 1B trips 0725 and 0730. The edits test the thresholds on the quarter-end values in items 5 and 6(a), while Regulation YY states its scoping thresholds as averages, so for a group close to a line the edit look-back and the regulatory test can point in different directions.

The instructions do not describe how a filer responds to a quality edit, such as an explanation field or a resubmission step, and they publish no list of rejection codes. Questions about clearing a specific edit go to the district Reserve Bank that monitors the filing.

Caveats and interactions: Regulation YY definitions, the FR Y-15 and the FR Y-7

The FR Y-7Q sits upstream of several regulatory measurements. In 12 CFR 252.2, combined U.S. assets are the consolidated assets of each top-tier U.S. subsidiary, excluding any section 2(h)(2) company, plus the total assets of each U.S. branch and agency, as reported by the FBO on the FR Y-15 or FR Y-7Q. U.S. non-branch assets are the consolidated assets of each top-tier U.S. subsidiary, excluding section 2(h)(2) companies and DPC branch subsidiaries, as reported on the FR Y-7Q and reduced for balances between top-tier U.S. subsidiaries. Average U.S. non-branch assets of $50 billion is the Regulation YY threshold for the U.S. intermediate holding company requirement: for FBOs with average total consolidated assets of $100 billion or more and average combined U.S. assets below $100 billion, section 252.142(a)(3) applies the IHC requirement in section 252.147; for FBOs with combined U.S. assets of $100 billion or more, the IHC requirement is in section 252.153(a)(1). The single-counterparty credit limit definitions in subpart Q measure an FBO’s total consolidated assets as the average of its four most recent quarters reported on the FR Y-7Q.

Combined U.S. assets also feed the category labels in section 252.5, and other reports key off those labels. FBO filing frequency for the FR 2052a is one example: daily for Category II FBOs and for Category III FBOs with $75 billion or more of average weighted short-term wholesale funding, monthly for the rest.

For FR Y-15 filers, item 6(b) arrives pre-populated. Where the organization files the Systemic Risk Report (FR Y-15) for the same period at the same level of consolidation, the instructions populate item 6(b) automatically from FR Y-15 Schedule H, column B, item M.4, which ties the FR Y-7Q average to whatever basis the FR Y-15 used.

The FR Y-7 is the annual companion. The two forms usually share a top-tier reporter, but the FR Y-7 is due 120 calendar days after the FBO’s fiscal year-end, and Regulation YY anchors different certifications to each. The U.S. risk-committee certification that section 252.144(a) requires of certain FBOs is filed concurrently with the FR Y-7, while the capital-compliance reports under sections 252.143(b) and 252.154(b) accompany the FR Y-7Q. A compliance calendar that merges the two misses one of the dates.

Proportionality is built into the frequency rules: annual filing for non-FHC groups below $50 billion, Part 1B only above the Regulation YY thresholds, Part 2 only in FHC groups. The discretionary elements are narrow. They cover the top-tier determination for tiered groups, extensions where home-country practice prevents 70-day reporting, and the Federal Reserve’s power to require supporting calculations and definitions of the components of capital.

The data also travel beyond supervision of the FBO itself. In its June 2026 announcement of aggregate financial sector liabilities under Regulation XX (12 CFR part 251), the Board said it used information collected on the FR Y-7Q, the FR Y-9C and the FR XX-1 to calculate the liabilities of the relevant institutions. Its September 2026 proposal implementing the GENIUS Act cited FR Y-7Q data for 31 December 2025 in counting 121 U.S. operations of foreign banks for its Regulatory Flexibility Act analysis.

Head-office teams that serve several host supervisors meet a different design elsewhere. The PRA’s branch return is made as at 30 June and 31 December within 30 business days, in sterling equivalent (our PRA Branch Return guide). In the EU, Article 48k(2) of the Capital Requirements Directive, inserted by Directive (EU) 2024/1619, has third-country branches report their head undertaking’s compliance with prudential requirements on an individual and consolidated basis, and Article 48l(3) lets a competent authority waive that for qualifying branches where it can obtain the information directly from the third-country supervisor (see our guide to EBA third-country branch reporting). The FR Y-7Q asks the parent group itself for its consolidated Basel capital in dollars, so currency translation and the choice of top-tier entity are the points to align across those returns.

Changes to FR Y-7Q reporting since 2022, and the FR Y-15 proposal to watch

The current structure traces to a proposal published on 27 May 2022 (87 FR 32164). The Board proposed a new Part 1A line for combined U.S. assets on a quarterly average basis, removal of the fiscal-year option in favour of calendar periods, deadlines cut from 90 days to 30 days for quarterly filers and to 45 days for annual filers, and deletion of the as-of date items. The changes were to take effect for the 31 December 2022 report date.

The final version, announced on 11 December 2023 (88 FR 85886), was softer. The Board had received a joint comment from two trade associations, a comment from one banking organization and further industry feedback. Item 6(b) became an average built from monthly data, retrieved automatically for FR Y-15 filers. The fiscal-year option survived for the non-U.S. items while the U.S. asset items moved to calendar quarters. The deadline became 70 days, first for FR Y-15 filers from the 31 December 2023 report date and for every other filer from the 31 December 2024 report date.

The following clearance left the form alone. The Board’s notice of 5 February 2025 (90 FR 9027) extended the FBO collections for three years and stated that there were no changes to the FR Y-7Q at that time; the form now carries a March 2025 date and an OMB expiry of 31 March 2028. The instruction pages dated May 2025 add the FFIEC 002 Schedule M cross-reference described above and leave the who-must-report text as it was in the December 2023 version.

The live item sits in a different form. On 27 March 2026, alongside its GSIB surcharge changes, the Board proposed removing Schedules H through N from the FR Y-15 (91 FR 14908). FBOs would file Schedules A through G for their combined U.S. operations and separately for any U.S. intermediate holding company; the Board said the change would reorganize reporting without changing the information collected, and that it would take effect two calendar quarters after a final rule is adopted. Comments closed on 18 June 2026. The proposal does not mention the FR Y-7Q, whose instructions source item 6(b) from Schedule H. My reading is that a final rule would need a conforming change to that cross-reference; until one appears in the Federal Register, the Schedule H link stands.

The two other 2026 Federal Register documents that mention the FR Y-7Q, the Regulation XX liabilities announcement and the GENIUS Act proposal, use it as a data source and leave the form unchanged.

Frequently Asked Questions

Our ultimate parent is an insurer that reports no capital ratios at home. Which entity files?

The instructions use this case as their example. A top-tier insurance company that does not provide capital ratio information to its home-country authorities will likely not have to provide capital ratio information on the FR Y-7Q, and the next-highest tier that does provide capital and asset information at home would likely be deemed the top-tier entity for the report. The instructions hedge with “likely”, and they route the initial determination for tiered groups through consultation with Federal Reserve staff.

One lower-tier FBO in our group elected FHC status and the top tier did not. Does that change our frequency?

Yes. Part 1A is reported quarterly where the top-tier FBO or any FBO in its tiered structure has effectively elected FHC status, regardless of the top tier’s size. The same election brings in Part 2 for each lower-tier FBO with a U.S. branch, agency, Edge or Agreement corporation or commercial lending company subsidiary.

Our home supervisor applies Basel III with national deviations. Should item 1 say yes?

Item 1 asks whether the home supervisor has adopted and uses risk-based standards consistent with the Basel Capital Accord, and the instructions set no materiality test for national deviations. For a Part 1B filer the more consequential question is the next one: where the home calculation of Tier 1 or total capital differs from a Basel-consistent calculation under Regulation YY, Part 1B items 3 and 5 carry pro-forma estimates. A documented comparison of the home rules against the Basel definitions answers both questions at once.

Can we leave item 6(b) blank until our FR Y-15 is filed?

The instructions allow the FR Y-7Q to be submitted with automatically retrieved items left blank when the source report is due after the FR Y-7Q, and the FBO then resubmits once the source report has been filed so that the missing data populate. On the Board’s published deadlines the FR Y-15 comes first: it is due 50 calendar days after the 31 March, 30 June and 30 September as-of dates and 65 calendar days after 31 December, against 70 calendar days for the FR Y-7Q. The instructions do not address an FR Y-7Q sent before the FR Y-15 has been filed, so that sequence is a point to clear with the Reserve Bank in advance.

Our fiscal quarter ends a month before the calendar quarter. Which exchange rate applies?

The instructions say only that items translated from foreign currency use the rate effective on the as-of date of the report. They do not separately address a filer whose items 2 to 5 carry an earlier fiscal date in item 8 while items 6 and 7 are calendar quarter-end figures, so the text leaves open whether the item 8 date or the report date governs the rate. That is a point to settle with the Reserve Bank and then apply the same way every quarter.

Do auditor restatements at home mean refiling past quarters?

The instructions say an FBO should file an amended report when internal or external auditors make audit adjustments that result in a restatement of financial statements affecting reports already submitted, and the Federal Reserve may also require an amended report where earlier submissions contain significant errors. Where the required data are not available, the respondent contacts its Reserve Bank about how to submit revisions.

Our only U.S. office is a representative office. Do we file?

Neither the Regulation K definition in 12 CFR 211.21(o) nor the Board’s description of the respondent panel mentions representative offices; both turn on branches, agencies, commercial lending companies, U.S. banks and Edge or agreement corporations. On those texts a foreign bank whose only U.S. presence is a representative office sits outside the FR Y-7Q panel, and acquiring one of the listed vehicles would bring it in.

Key Takeaways

  • Reconcile items 6(a), 6(b) and 7 to the Regulation YY threshold workbook at every quarter-end; 12 CFR 252.2 measures combined U.S. assets and U.S. non-branch assets from this form.
  • Diary each remittance as report date plus 70 calendar days, 5:00 p.m. at the Reserve Bank, and raise any extension request at least 30 days before it.
  • Build Part 1B Tier 1 and total capital by adding the rounded components, so edits 1090 and 1095 tie to the million.
  • Leave Part 1B switched on for four quarters after the group falls below both thresholds; the validity edits look back that far.
  • Treat an FHC election anywhere in the tiered structure as the trigger for quarterly Part 1A and a separate Part 2 per qualifying lower-tier FBO.
  • For Reporting Central filers, file the manually signed page 1 and the data printout together in the FBO’s records.
  • Watch for a final FR Y-15 rule: the proposal would apply it two calendar quarters after adoption, and it would remove the schedule that pre-populates item 6(b).

Sources and References

Preparing the next FR Y-7Q filing

Each quarterly FR Y-7Q is due 70 calendar days after quarter-end; the 30 September report, for example, is due on 9 December. Three artifacts make each filing defensible: the item 6 and item 7 build, reconciled to the Regulation YY threshold calculation and to the FFIEC 002 due-to and due-from figures; the Part 1B capital and buffer schedule, tied to the home-country capital return; and the officer-signed page 1, kept on file where the submission goes through Reporting Central. Before the deadline, confirm whether the four-quarter look-back still places the group inside Part 1B.

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.

Similar Posts

  • PRA Branch Return: Half-Yearly Reporting for UK Bank Branches

    Report Library › Prudential ReportingThe PRA Branch Return is the half-yearly return through which a UK branch of a non-UK bank tells the Prudential Regulation Authority what it is doing in the United Kingdom. From the 30 June 2026 reference date, in-scope firms complete a revised version of the form (template version 1.2), the product…

  • EBA Third-Country Branch Reporting – What the New Harmonised Standards Mean for Your Branch

    Updated July 2026In this guideWhy This Framework ExistsWho Must ReportWhat Gets Reported: Annex I – Branch-Level TemplatesWhat Gets Reported: Annex II – Head Undertaking TemplatesReporting Frequencies and Remittance DatesRelationship to COREP and FINREPLuxembourg RelevanceTimeline and Transitional ProvisionsImplementation ChallengesCRR3 InteractionPractical Steps for ImplementationFrequently Asked QuestionsKey TakeawaysRelated ArticlesSources and ReferencesReport Library › Prudential ReportingIf you run regulatory…

  • FR Y-15 Reporting: The Fed’s Systemic Risk Report, Schedule by Schedule

    Report Library › Prudential ReportingFR 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…

  • FR 2052a Reporting: Complex Institution Liquidity Monitoring Report

    Report Library › Prudential ReportingFR 2052a reporting is the Federal Reserve Board’s granular view of liquidity at the large banking organizations it supervises under the Category I to IV standards. The Complex Institution Liquidity Monitoring Report (OMB control number 7100-0361, renewed by the Board without revision on 4 February 2025) is filed by top-tier U.S….