FR Y-9C Reporting: The $3 Billion Line and the 40-Day Clock
FR Y-9C reporting is how the Federal Reserve Board collects consolidated GAAP financial statements and regulatory capital data from U.S. holding companies with $3 billion or more in total consolidated assets, and from smaller ones that a Reserve Bank requires to file or that elect to comply with the Federal Reserve’s capital adequacy guidelines. The Consolidated Financial Statements for Holding Companies (FR Y-9C) is filed as of every quarter-end and is due 40 calendar days later, 45 days after 31 December, by 5:00 P.M. at the district Reserve Bank. The General Instructions state that no extensions of time are granted.
The stakes sit on page 1 of the form. The chief financial officer, or the person performing that function, attests that the report was prepared in conformance with the Board’s instructions and is true and correct to the best of the signer’s knowledge and belief, and the General Instructions tie any knowing and willful misrepresentation or omission of a material fact to the sanctions in 18 USC 1001 and 1007. The same report carries Schedule HC-R, where a qualifying holding company opts into or out of the community bank leverage ratio (CBLR) framework, so one yes-or-no item decides how much of the capital schedule the rest of the filing contains.
Three tests set most of what a given holding company files: whether it is the top tier with $3 billion or more in total consolidated assets, whether it reached $5 billion on the prior year’s 30 June report, and whether it has a CBLR election in effect at quarter-end. The sources are the instruction book marked Effective September 2026, the form, the 2026 supplemental instructions and the Reporting Central user guide for the FR Y-9C dated June 2026. Where those documents are silent, the text says so.
Related reading: FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period
Legal basis of the FR Y-9C: five citations on the cover page
The cover page states that the report is required by law and lists its authority: 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 section 252.153(b)(2) of Regulation YY (12 CFR 252.153(b)(2)). Read against the respondent panel, the citations line up with the four filer types: bank holding companies under the BHC Act, savings and loan holding companies (SLHCs) under HOLA, securities holding companies under section 618, and U.S. intermediate holding companies (IHCs) under Regulation YY. The form lists the citations without assigning them to filer types, so this mapping is an interpretation. The Regulation YY provision is short: each U.S. intermediate holding company shall submit information in the manner and form prescribed by the Board.
The collection runs under OMB control number 7100-0128, and the form shows an approval expiry of 31 December 2028.
Three documents carry the operative detail. The instruction book is split into General Instructions, Line Item Instructions and a Glossary, and it warns that no single section necessarily gives the complete instructions for an item, so the three are read together with the validation edits bound at the back. The form fixes the captions and the MDRM codes. Quarterly supplemental instructions flag accounting standards and capital rules that the book has not yet absorbed. Capital content has its own anchor: the Schedule HC-R instructions are to be read with the Board’s regulatory capital rules in 12 CFR part 217.
Version control is the first trap. On the Board’s FR Y-9C page, the June 2026 form and instructions now sit under Historical, and the Current instructions are the September 2026 book. The form did not change between those editions: the June 2026 and current form PDFs are byte-identical, with a cover stamped 03/2026. The instruction book did change, in Schedule HC-R, in the Glossary entry on brokered deposits and in the edit appendix, so a link to the June book is a link to superseded text.
Who must report the FR Y-9C, and who files a different FR Y-9 report
The starting rule is wide. All bank holding companies, SLHCs, securities holding companies and U.S. intermediate holding companies, regardless of size, must submit financial statements to the Federal Reserve unless specifically exempted. Size then decides which statement. A holding company with total consolidated assets of $3 billion or more (the top tier of a multi-tiered organization) files the FR Y-9C quarterly, as of the last calendar day of March, June, September and December, and also files the FR Y-9LP, the parent company only statements, for the same dates.
| Holding company situation | Report under the General Instructions | Frequency |
|---|---|---|
| Top tier, total consolidated assets $3 billion or more | FR Y-9C, plus FR Y-9LP for the parent | Quarterly |
| Lower-tier holding company in an FR Y-9C organization | Separate FR Y-9LP, whatever its size | Quarterly |
| Total consolidated assets under $3 billion, not below an FR Y-9C filer | FR Y-9SP | Semiannual, June and December |
| Employee stock ownership plan holding company | FR Y-9ES | Annual, as of 31 December |
| SLHC in one of the two exempt categories | FR 2320 | Not stated in the FR Y-9C book |
Only the top tier files the FR Y-9C for a multi-tiered organization. If that top-tier company is itself exempt from the FR Y-9C, the obligation drops to the lower-tier holding company with $3 billion or more in assets. A holding company under $3 billion that sits below an FR Y-9C filer reports on the FR Y-9LP instead of the FR Y-9SP.
The Reserve Bank can reach below the line. Footnote 3 of the General Instructions lets the Reserve Bank require a holding company under $3 billion to file the FR Y-9C and FR Y-9LP to meet supervisory needs, considering criteria including whether it is engaged in significant nonbanking activities, conducts significant off-balance-sheet activities such as securitizations or managing assets for third parties, or has a material amount of SEC-registered debt or equity outstanding, other than trust preferred securities. A holding company that is not subject to the Board’s capital adequacy guidelines but elects to comply with them must file a complete FR Y-9C and FR Y-9LP, and the same footnote says it generally would not be permitted to revert to the FR Y-9SP later.
Two kinds of holding company file no holding company financial statements at all: one granted an exemption under section 4(d) of the Bank Holding Company Act, and a qualified foreign banking organization, as defined in section 211.23(a) of Regulation K, that controls a U.S. subsidiary bank. Two kinds of SLHC are carved out of the FR Y-9C and FR Y-9SP and file the FR 2320 instead: a grandfathered unitary SLHC with primarily commercial assets whose thrifts make up less than 5 percent of its consolidated assets, and an SLHC that primarily holds insurance-related assets and does not otherwise submit financial reports to the SEC under section 13 or 15(d) of the Securities Exchange Act of 1934. The Reserve Bank of the district in which an otherwise exempt company is registered can still require it to file.
Some FR Y-9C filers leave a whole schedule empty by rule. The capital rules apply to covered SLHCs, meaning top-tier SLHCs that are not substantially engaged in insurance or commercial activities. An SLHC is an insurance SLHC if it is an insurance underwriting company or if, as of 30 June of the previous calendar year, it held 25 percent or more of its total consolidated assets in insurance underwriting subsidiaries, and the HC-R instructions state that insurance SLHCs are not required to complete Schedule HC-R even when they complete the other schedules.
Foreign operations are inside the perimeter when they belong to the consolidated holding company. Branches, subsidiaries, variable interest entities and international banking facilities within its scope are consolidated, and selected items are split between domestic and foreign offices, reported at the same level of consolidation as the full statement. The FR Y-9C instructions give no filing role to a foreign bank’s U.S. branches or agencies; at the foreign parent’s level, reporting runs through other Federal Reserve forms, such as the capital and asset report in our FR Y-7Q explainer for foreign banking organizations.
What the report contains: from Schedule HI to Schedule HC-R
The Reporting Central user guide describes the FR Y-9C as multiple schedules holding over a thousand financial data and text fields. Each field is identified by an eight-character MDRM code; BHCK4435, for example, is interest and fee income on loans secured by 1-4 family residential properties in domestic offices.
Cover page and income statement schedules
Page 1 carries the report date (BHCK 9999), the legal title and mailing address, the CFO’s printed name, signature and date of signature, the confidentiality question and a contact person. Page 2 asks for the chief executive officer’s contact details, which are for the Board’s confidential use. The income group follows: Schedule HI (consolidated income statement), HI-A (changes in holding company equity capital), HI-B (charge-offs and recoveries in Part I, changes in allowances for credit losses in Part II), HI-C (disaggregated data on the allowances for credit losses) and the notes to the income statement, one set for predecessor financial items and one for other explanations. All income schedules are reported on a calendar year-to-date basis, so the September report carries nine months of income.
Balance sheet and supporting schedules
Schedule HC is the consolidated balance sheet at quarter-end. The supporting schedules break it down by product and risk: HC-B securities, HC-C loans and leases, HC-D trading assets and liabilities, HC-E deposits, HC-F and HC-G other assets and liabilities, HC-H interest sensitivity, HC-I insurance-related underwriting, HC-K quarterly averages, HC-L derivatives and off-balance-sheet items, HC-M memoranda, HC-N past due and nonaccrual assets, HC-P 1-4 family residential mortgage banking, HC-Q fair value measurements, HC-S servicing and securitization, HC-V variable interest entities, and the notes to the balance sheet.
Schedule HC-M carries a structural question that is easy to skip. Item 11 asks whether all changes in investments and activities have been reported on the FR Y-10, and Appendix B of the Reporting Central guide states that it must not be left blank or entered as N/A: the answer is 1 for yes (or for no changes to report) and 0 for no, and a 0 means the FR Y-10 still has to be completed.
Schedule HC-R and the CBLR fork
Schedule HC-R holds regulatory capital: Part I covers capital components and ratios, Part II risk-weighted assets. In Part I, items 11 through 19 have two columns, column A for non-advanced approaches holding companies (including those subject to Category III standards) and column B for advanced approaches holding companies. Ratios are reported as percentages rounded to four decimal places, and the upload guide gives the leverage ratio (BHCA7204) an 8,4 decimal format.
Item 31.a determines which items follow. A holding company that enters 1, meaning a CBLR election is in effect at the quarter-end report date, completes items 32 through 36 and leaves items 37 through 53 and all of Part II blank. One that enters 0 skips items 32 through 36, completes items 37 through 53 as applicable, and completes Part II. The election itself is made on the FR Y-9C: qualifying holding companies opt in and out through their filing, and the Board may disallow the framework for an otherwise qualifying holding company based on its risk profile. Under the September 2026 book, a holding company in general qualifies with a leverage ratio greater than 8 percent (item 31), under $10 billion in total consolidated assets (item 32), no advanced approaches status, trading assets and trading liabilities of 5 percent or less of total consolidated assets (item 33), and off-balance-sheet exposures of 25 percent or less (item 34). The grace-period arithmetic is in our FR Y-9C CBLR update.
Size tiers inside the form
The $5 billion switches key off one number: total assets on the prior year’s 30 June report. The form’s footnotes repeat it (“Asset-size test is based on the prior year June 30 report date”), and the edits encode it by reading Schedule HC item 12 from the June report of the previous calendar year in every quarter. A holding company’s $5 billion tier is therefore fixed for the whole calendar year, whatever its assets do between quarter-ends.
| Schedule or items | Who completes them, per the form |
|---|---|
| HC-D trading assets and liabilities | $5 billion or more, with total trading assets of $10 million or more in any of the four preceding calendar quarters |
| HC-P 1-4 family mortgage banking | $5 billion or more, where domestic originations and purchases for resale, sales, or quarter-end loans held for sale or trading exceed $10 million for two consecutive quarters |
| HC-Q fair value measurements | $5 billion or more, where the holding company has elected a fair value option or must complete HC-D |
| HC-S and HC-V | $5 billion or more |
| HC-I insurance underwriting | All top-tier holding companies; item 1 only with $10 million or more in reinsurance recoverables |
| HI memoranda 6 and 7 (other noninterest income and expense detail) | Under $5 billion: annually, in the December report; $5 billion or more: quarterly |
| HI-C items 1 to 11; HC-C memoranda 1.a.(1) to 1.f.(3)(c); HC-R Part II items 1 to 25 | Under $5 billion: June and December reports only |
Further switches sit at $10 billion, $30 billion and $100 billion for particular items; Schedule HC-L item 15, for instance, is completed only by holding companies with total assets of $10 billion or more, and HC-M memoranda item 22, the web address of the holding company’s risk disclosures, only at $30 billion or more.
Units, rounding and signs
Amounts are in thousands of dollars. A holding company with total assets under $10 billion rounds to the nearest thousand, so items under $500 are reported as zero. At $10 billion or more, the holding company may instead round to the nearest million and report zeros for the thousands, in which case amounts under $500,000 become zero. Rounded detail is adjusted so components sum to their totals, and total assets (Schedule HC, item 12) and total liabilities and equity capital (item 29) are derived from unrounded numbers before rounding, so the two come out equal. Commas are not used to separate thousands, millions and billions.
Negative entries are generally not appropriate on the balance sheet: an asset with a credit balance is reported as a liability, and a liability with a debit balance as an asset. The General Instructions list the exceptions, among them investments in unconsolidated subsidiaries (HC item 8), retained earnings, accumulated other comprehensive income, total equity capital and a run of Schedule HC-R capital lines and ratios. A negative takes a minus sign, never parentheses. On Schedule HI negatives may appear as appropriate, with income items carrying a debit balance and expense items carrying a credit balance reported with a minus sign.
FR Y-9C reporting deadlines: 40 days, 45 days and 5:00 P.M.
The as-of dates are 31 March, 30 June, 30 September and 31 December. The submission dates follow from two counts in the General Instructions, and the book gives two of the four as examples.
| As-of date | Submission date before any roll | Basis |
|---|---|---|
| 31 March | 10 May | 40 calendar days |
| 30 June | 9 August | 40 calendar days (example in the instructions) |
| 30 September | 9 November | 40 calendar days |
| 31 December | 14 February | 45 calendar days (example in the instructions) |
The instructions define the submission date as the date by which the Federal Reserve must receive the report, and the report is due by the end of the reporting day, 5:00 P.M. at each district Reserve Bank. When the date falls on a weekend or holiday, the report must be received on the first business day after it. Earlier submission is encouraged and no extensions are granted. The report for the quarter now closing is due on the matching date in the table, rolled to the next business day when it lands on a weekend or holiday.
The roll rule can stack. The Board’s holiday schedule places Washington’s Birthday on a Monday in mid-February, so in a year when 14 February is a Sunday and the Monday after it is that holiday, the December report is due on the Tuesday. By the same rule, a 9 November that falls on a Saturday rolls past Monday 11 November, Veterans Day, to Tuesday 12 November.
Entry is read from the 30 June balance sheet. A top-tier holding company that reaches $3 billion in total consolidated assets as of 30 June of one year begins reporting the FR Y-9C and FR Y-9LP in March of the following year, and its lower-tier holding companies start their FR Y-9LP reports in the same March. On the plain reading of that rule, organic growth that carries a holding company past $3 billion in the third quarter is next measured at the following 30 June; if the holding company is still over the line then, its first FR Y-9C is the March report after that, unless the Reserve Bank requires an earlier start under footnote 3. Acquisitions follow a different clock, covered in the FAQ below.
The FR Y-9LP that accompanies the FR Y-9C has its own instruction book, which is not part of the FR Y-9C booklet; the FR Y-9C instructions do not restate its submission dates.
Submission through Reporting Central: file layout, signatures and amendments
All holding companies must submit the FR Y-9C electronically. The General Instructions point filers to their district Reserve Bank or to the FRB Services Reporting Central pages for procedures, and a holding company that believes it may not be able to submit electronically is told to contact the Reserve Bank. FRB Services describes Reporting Central as the single point of entry for electronic report submission by direct data entry and file upload, reached through the FedLine Web access solution, and its user-guide index lists the FR Y-9C as a mandatory electronic report with a text-format upload guide. Its report series migration schedule lists the FR Y-9C, with the FR Y-9LP and FR Y-15, as migrated to the updated Reporting Central application in the 26 to 28 June 2026 wave, and does not mark the FR Y-9C among the reports moving to an XML file upload format.
The upload file
The Reporting Central user guide for the FR Y-9C (Statistics Function, June 2026) specifies a plain text upload. Each financial item is written as the letter L, the eight-character MDRM, a plus sign and the value, so the guide’s own example for item 1.a.(1)(a) reads LBHCK4435+100. The FR Y-9C has a maximum of one column per MDRM, so each financial item carries exactly one plus sign. Negative values take a leading minus sign, zero is entered as 0, and a null item is left blank after the plus sign. Standard financial items are in thousands, with up to 14 digits and no decimal places; nonstandard items have their own limits in Appendix B of the guide, such as the 8,4 decimal format for the capital ratios and a single digit for yes-or-no questions. Text items, such as the contact name, take two underscore characters before the value and two after it.
The file is saved as tab-delimited text with a header record as its first line: ten positions for the RSSD ID with leading zeroes, ten positions for the series ID FRY9C plus five trailing spaces, then the as-of date in MM-DD-YYYY format. Formatting errors appear in the upload window. A clean file returns a File Upload Complete message and loads into the report screen, where the data can be validated, saved, submitted or deleted. Neither the instruction book, the form nor the guide prescribes an XBRL taxonomy, an XML schema or a file-naming convention for this report.
Signature and record retention
A physical or electronic copy of the report must be signed, in ink or electronically, by the CFO or the person performing that function. A holding company that signs in ink keeps the signed physical copy for three years after submission. Electronic signatures are permitted where the process meets the five principles in the General Instructions, which cover the form of signature, intent to sign using the attestation text, association with the full report including a signing date before submission, authentication of the signer, and integrity of the record, retained for three years after the report date unless state law or the Board requires longer. The electronic signature is not transmitted to Reporting Central with the data; the signed report has to be available to Board examiners on request.
Amended reports
The Federal Reserve may require amended reports when previously submitted reports contain significant errors, and it may require amendments when its interpretation of GAAP or the instructions for a transaction differs from the holding company’s, weighing materiality as described in FASB Concepts Statement No. 8. A holding company should file an amended report when internal or external auditors make audit adjustments that result in a restatement. After an acquisition that restates prior periods, the Federal Reserve requests revised reports for the prior year-ends, asking at least for Schedules HC and HI where the full set of schedules cannot be completed. The posted documents do not describe the resubmission mechanics inside Reporting Central; where required data are not available, the instructions send the holding company to its Reserve Bank.
Amendment has a limit, spelled out in the September 2026 supplemental instructions. Amending a submitted FR Y-9C to report a debt security retroactively in another category, when the transfer was not documented with evidence of its actual date, is inappropriate. Transfers are reported at fair value on the transfer date under ASC Topic 320, and the supplemental expects classification to be reassessed in general alignment with the quarterly FR Y-9C dates.
Validation edits: what blocks acceptance and what needs an explanation
The back of the instruction book carries the edits in two sets. The validity checklist, pages CHK-1 to CHK-31 in the September 2026 book, is headed “Each edit in the checklist must balance, rounding errors are not allowed”. The second set, EDIT-1 to EDIT-103, holds the quality, interseries and intraseries edits. Each row carries effective dates, the target item and MDRM, and the test in words and as an algorithm. Five rows show the range:
- Validity 2145: Schedule HC item 29 must equal item 12, the equality the rounding rule is built to protect.
- Validity 5213: Schedule HC-R Part I item 31.a, the CBLR election, must not be null.
- Quality 9000: Schedule HI item 1.a.(1)(a) should not be null and should not be negative.
- Intraseries 5139: in June, September and December, if Schedule HI-A item 9 (changes incident to business combinations) is unchanged from the previous quarter, year-to-date interest on 1-4 family residential loans should be at least the previous quarter’s figure less $2 thousand.
- Interseries 4138: for advanced approaches and Category III holding companies, the supplementary leverage ratio in HC-R Part I item 53 should equal the figure on the FFIEC 101, Schedule A, Table 2, item 2.22.
In the tables, validity tests use “must” and quality tests “should”. Many quality edits are conditioned on the prior-year June total assets: for a holding company under $5 billion, quality edits 1234 and 1235 expect HC-C memorandum item 1.f.(3)(a) to be filled in the June and December reports and left null in March and September. An item reported in the wrong quarter fails an edit even when the amount is right.
The instruction book does not say which edits stop a submission or how a failed quality edit is explained. District guidance covers part of that. The Federal Reserve Bank of St. Louis states on its financial and regulatory reporting page that Reporting Central runs validity edits that must be resolved before data can be accepted, that the requirement to supply quality edit explanations at the time of submission has been removed, and that institutions are encouraged to email quality edit explanations to its Statistics shared inbox. That page speaks for the St. Louis district.
No list of rejection codes appears in the instruction book or the user guide. The guide’s error messages, covered with the upload file above, flag formatting problems in the text file and appear in the file upload window. The General Instructions add a manual check that no edit replaces: before submission, every amount is compared with the previous report, and unusual changes are explained briefly to the Reserve Bank.
One mismatch in the September 2026 book matters for CBLR electors. Its edit appendix is headed “Effective as of March 31, 2026”, where the June 2026 book’s appendix was headed June 30, 2026, and it still carries validity edit 5206: if item 31.a equals 1, the leverage ratio in item 31 must be greater than or equal to 8 percent. The September 2026 HC-R instructions treat an electing holding company that temporarily fails a qualifying criterion as well capitalized so long as its leverage ratio stays above 7 percent within the four-quarter grace period. The posted documents do not say how the edit is applied to a grace-period filer between 7 and 8 percent.
Caveats and interactions: accounting choices, confidentiality and neighbouring reports
The consolidation perimeter follows the holding company’s annual reports to the SEC or, for a holding company that does not file with the SEC, GAAP: generally every company in which it owns more than 50 percent of the outstanding voting stock, consolidated line by line with intercompany balances and transactions eliminated. Holding companies that file with the SEC should generally show the same total assets, total liabilities, total equity capital and net income in both places. Two exclusions are written in. A majority-owned subsidiary that the holding company does not control, for example because the subsidiary is in bankruptcy, is reflected in investments in unconsolidated subsidiaries (HC item 8) instead of being consolidated. Custody and safekeeping holdings stay off the balance sheet unless customer cash is commingled with the holding company’s general assets.
One exception to the elimination rule is narrow enough to miss: for Schedule HC-M memoranda items 7(a) and 7(b) only, the total assets of captive insurance and reinsurance subsidiaries are measured before eliminating intercompany transactions with the rest of the consolidated holding company.
Accounting choices have two further limits. A holding company that is a private company under GAAP may use FASB private company accounting alternatives in the FR Y-9C, but the Federal Reserve may prescribe a principle no less stringent than GAAP if it finds an alternative inconsistent with supervisory objectives, with appropriate notice. Subsequent events follow ASC Topic 855: events between the balance sheet date and filing that give evidence about conditions at quarter-end are recognized in the report.
The completed report is generally available to the public on request. The instructions withhold FDIC deposit insurance assessments (Schedule HI memoranda item 7(g)), the engagement partner’s name and email (Schedule HC memoranda items 2b(1) and 2b(2)), the representation and warranty reserves in Schedule HC-P items 7(a) and 7(b), and the CEO contact information. Anything else stays public unless the holding company asks in writing, before the electronic submission, for confidential treatment under a Freedom of Information Act exemption, such as exemption 4 for commercial or financial information or exemption 6 for personal privacy, and demonstrates the specific harm; stating that competitive harm would result is not sufficient. Page 1 records the request and whether the justification letter accompanies the report or was sent separately, and if either step is missing, confidential treatment will not be considered. The answers to those page-1 questions are themselves public.
Several reports connect to the FR Y-9C. Each FR Y-9C filer submits the FR Y-9LP for its parent company. Schedule HC-M item 11 ties the filing to the FR Y-10 structure report. Advanced approaches holding companies may use HC-R Part I amounts to complete Schedule A of the FFIEC 101, and interseries edit 4138 tests the supplementary leverage ratio across the two. The FR Y-14Q instructions refer filers to the FR Y-9C General Instructions for the rules of consolidation; the stress-testing schedules themselves are in our FR Y-14A/Q/M schedules and deadlines guide. The bank-level counterpart is the Call Report, which the FR Y-9C instructions reference by its FFIEC 031 and 041 forms in places; our FFIEC Call Report guide covers which of the 031, 041 or 051 forms a bank files.
Proportionality is built into the form instead of granted case by case: the $5 billion tier, the June-and-December-only items for smaller filers and the CBLR path all shrink the item set without an application. Case-by-case discretion still exists: the Board may disallow the CBLR framework for an otherwise qualifying holding company based on its risk profile, and the district Reserve Bank can pull a holding company under $3 billion into FR Y-9C reporting, receives explanations of unusual changes and, under the General Instructions, answers questions and requests for interpretations of any part of the instructions. Transitional relief in the capital schedule is item-driven: Schedule HC-R Part I item 2.a records a 3-year or 5-year 2020 CECL transition election, and a holding company that does not elect the 3-year transition in the FR Y-9C for the quarter in which it first reports CECL allowances cannot elect it later.
Recent and upcoming changes to the FR Y-9C, with dates
Changes reach the FR Y-9C through three channels: a new instruction book, the quarterly supplemental instructions, and Federal Register notices for the underlying rules or the collection itself. The sequence since December 2025 used all three.
| Date | Change | Effect on the FR Y-9C |
|---|---|---|
| 1 December 2025 | eSLR final rule published (90 FR 55248); effective 1 April 2026, early adoption allowed from 1 January 2026 | Early adopters could apply the modified standard from the 31 March 2026 report; early adopting U.S. GSIBs could enter 50 percent of their most recent method 1 surcharge in HC-R Part I item 64 |
| 8 December 2025 | Board final notice extending the FR Y-9 collection with revisions (90 FR 56756); effective with the 31 March 2026 report date | New FR Y-9C items on exposures to nondepository financial institutions for holding companies with $10 billion or more in assets, a new item for structured financial products guaranteed by U.S. government or sponsored agencies, and permission to sign the FR Y-9C electronically |
| 19 March 2026 | Three capital proposals issued; comments due 18 June 2026 | The 27 March 2026 paperwork notice for the two joint proposals (91 FR 14853) does not mention the FR Y-9C |
| 23 April 2026 | CBLR final rule adopted (91 FR 22973, 29 April 2026); effective 1 July 2026 | CBLR requirement lowered from 9 to 8 percent; grace period extended from two to four quarters |
| 30 September 2026 | Board lists an updated form, instructions and supplemental instructions as posted | HC-R text aligned with the CBLR rule; the posted form PDF is byte-identical to the June 2026 edition |
Both rules moved from the supplemental instructions into the book. The June 2026 supplemental dropped its eSLR topic because the instructions had been updated that quarter, and the September 2026 supplemental dropped the CBLR topic once Schedule HC-R read greater than 8 percent, above 7 percent within an applicable four-quarter grace period, and no grace period after use in eight or more of the twenty preceding quarters, citing 12 CFR 217.12(c).
The March 2026 proposals cover an expanded risk-based approach for the largest banking organizations, standardized approach amendments and a revised GSIB surcharge. The paperwork notice for the two joint proposals covers the capital-rule collections under Board OMB numbers 7100-0313 and 7100-0314, and the posted FR Y-9C documents do not say whether or when Schedule HC-R would change if the proposals are finalized.
Four accounting standards are queued in the September 2026 supplemental instructions, which state that the FR Y-9C instructions will be revised to conform at a future date, as appropriate:
- ASU 2025-08, purchased loans: annual periods beginning after 15 December 2026 for all holding companies, applied prospectively, so a calendar-year holding company that does not adopt early first applies it in the 31 March 2027 report. Early adopters report initial allowances on purchased seasoned loans in the Notes to the Income Statement (Other), item 2.
- ASU 2025-09, hedge accounting improvements: public business entities for annual periods beginning after 15 December 2026, all other entities one year later.
- ASU 2025-06, internal-use software: all entities for annual periods beginning after 15 December 2027.
- ASU 2025-10, government grants: public business entities for annual periods beginning after 15 December 2028, all other entities one year later; early adopters report grants related to income in Schedule HI item 5.l or item 7.d, following the gross or net presentation in ASC Topic 832.
Frequently Asked Questions
Our holding company passed $3 billion by acquiring another bank. When is the first FR Y-9C due?
Earlier than under the 30 June test. When the top-tier holding company reaches $3 billion through a business combination, a transaction between entities under common control, or a branch acquisition that is not a business combination, it begins reporting the FR Y-9C and FR Y-9LP with the first quarterly report date following the effective date of the transaction, and its lower-tier holding companies begin their FR Y-9LP reports from the same date.
Total assets fell below $3 billion at the last quarter-end. Can we move to the FR Y-9SP next quarter?
Not on one quarter’s figure. The General Instructions allow a holding company to revert to the FR Y-9SP only after its total consolidated assets have fallen below $3 billion for four consecutive quarters, and lower-tier holding companies in the organization may revert with it. The one-quarter dip changes nothing until that run is complete. Footnote 3 adds one limit: a holding company that is not subject to the capital adequacy guidelines but elects to comply with them files the complete FR Y-9C and generally would not be permitted to revert to the FR Y-9SP.
We are an insurance SLHC that files the FR Y-9C. Should Schedule HC-R be filled with zeros?
The edit tables point the other way. Validity edit 5325 applies to grandfathered unitary SLHCs and insurance SLHCs that are not required to file Schedule HC-R, and it requires the items from HC-R Part I item 1 through HC-R Part II memoranda item 5.c to equal null. Zeros would fail it.
Our assets passed $10 billion during the year. From which report may we round to the nearest million?
The rounding paragraph leaves that open. It gives the million-rounding option to holding companies with total assets of $10 billion or more and names no measurement date, unlike the $5 billion tests on the form, which read the prior year’s 30 June report. Reporting in thousands remains permitted at any size, so a holding company can stay in thousands until its Reserve Bank confirms which report date governs.
We closed our trading desk. When does Schedule HC-D stop?
The trigger looks back a year. Schedule HC-D applies to holding companies with $5 billion or more in total assets that reported total trading assets of $10 million or more in any of the four preceding calendar quarters, so on that wording it stays in scope until none of the four preceding quarters shows trading assets at that level. Schedule HC-Q can follow it, because a holding company required to complete HC-D also completes HC-Q.
Does the as-of date move when a quarter-end falls on a weekend?
No. The report is made at the close of business as of the last calendar day of the quarter, whatever day of the week that is. Only the submission date rolls to the next business day.
Related Articles
- FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period: how the September 2026 Schedule HC-R text applies the 8 percent CBLR and counts grace quarters.
- FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026: the bank-level Consolidated Reports of Condition and Income, and which of the three forms a bank files.
- FR Y-14A/Q/M Reporting: Three Filing Clocks, One $100 Billion Panel: the stress-testing schedules that borrow FR Y-9C consolidation rules.
- FR Y-15 Reporting: The Fed’s Systemic Risk Report, Schedule by Schedule: the Fed’s systemic risk report and its GSIB indicator schedules.
- FR Y-7Q Reporting: The Fed’s Capital and Asset Report for FBOs: the capital and asset report for foreign banking organizations.
Key Takeaways
- Read the $5 billion tier from the prior year’s 30 June Schedule HC item 12 once a year and drive the $5 billion switches and the June-and-December-only items from that single flag, then apply the separate activity tests for Schedules HC-D, HC-P and HC-Q.
- Check item 31.a before anything else in HC-R: a 1 means items 32 to 36 and no Part II, a 0 means items 37 to 53 and Part II.
- For a CBLR elector in a grace-period quarter between 7 and 8 percent, the open point is validity edit 5206, and the Reserve Bank is where it gets settled before the submission date.
- Rebuild the Reporting Central header record for each as-of date: RSSD ID to ten positions, FRY9C plus five spaces, date as MM-DD-YYYY.
- File any confidentiality request in writing before the electronic submission, with the harm demonstrated; a bare claim of competitive harm does not qualify.
- Document every AFS-to-HTM transfer with its actual date when it happens; the September 2026 supplemental calls a retroactive amendment without that evidence inappropriate.
- Keep the signed report outside Reporting Central, ready for examiners: an ink-signed copy for three years after submission, an electronically signed report for three years after the report date unless state law or the Board requires longer.
Sources and References
- Board of Governors of the Federal Reserve System, FR Y-9C report page: federalreserve.gov
- Instructions for Preparation of Consolidated Financial Statements for Holding Companies, Reporting Form FR Y-9C, Effective September 2026: federalreserve.gov
- FR Y-9C instructions, Effective June 2026 (now listed as Historical): federalreserve.gov
- FR Y-9C reporting form, current edition (cover stamped 03/2026; OMB 7100-0128): federalreserve.gov; June 2026 edition: federalreserve.gov
- FR Y-9C Supplemental Instructions, September 2026: federalreserve.gov
- FR Y-9C Supplemental Instructions, June 2026: federalreserve.gov
- FR Y-9C Supplemental Instructions, March 2026 (enhanced supplementary leverage ratio): federalreserve.gov
- Board, Recent Reporting Form Updates (FR Y-9C entry of 30 September 2026): federalreserve.gov
- Federal Reserve System, Reporting Central User Guide, FR Y-9C, Statistics Function, June 2026: frbservices.org
- FRB Services, Reporting Central overview and user guides: app.frbservices.org; user guides
- FRB Services, Report Series Migration Status Update (Reporting Central): frbservices.org
- 12 CFR 252.153, U.S. intermediate holding company requirement for foreign banking organizations (Regulation YY), 2025 edition: govinfo.gov
- Board, Agency Information Collection Activities: Announcement of Board Approval under Delegated Authority and Submission to OMB (FR Y-9 extension with revisions), 90 FR 56756, 8 December 2025: govinfo.gov
- OCC, Board and FDIC, Regulatory Capital Rule: Community Bank Leverage Ratio Framework, 91 FR 22973, 29 April 2026: govinfo.gov
- OCC, Board and FDIC, Regulatory Capital Rule: Modifications to the Enhanced Supplementary Leverage Ratio Standards for U.S. Global Systemically Important Bank Holding Companies and Their Subsidiary Depository Institutions; Total Loss-Absorbing Capacity and Long-Term Debt Requirements, 90 FR 55248, 1 December 2025: govinfo.gov
- 12 CFR 217.12, Community bank leverage ratio framework (Regulation Q): ecfr.gov
- Federal Reserve Bank of St. Louis, Financial and Regulatory Reporting: stlouisfed.org
- Board, Federal Reserve holiday schedule (K.8), 2026 to 2028 dates: federalreserve.gov
- Board press release, Agencies request comment on proposals to modernize the regulatory capital framework, 19 March 2026: federalreserve.gov
- OCC, Board and FDIC, Proposed Agency Information Collection Activities; Comment Request, 91 FR 14853, 27 March 2026: govinfo.gov
- Board, Supervision and Regulation Report, June 2026, Regulatory Developments: federalreserve.gov
- FR Y-14Q instructions, current edition: federalreserve.gov
Before the next FR Y-9C as-of date
Three artifacts come before the numbers each quarter: confirmation that the instruction book in use is the Current one on the Board’s FR Y-9C page, the $5 billion and CBLR flags that decide which items and edits apply, and a Reporting Central header record built for the new as-of date. With those in place, the report for the quarter now closing goes to the district Reserve Bank by 5:00 P.M. on the 40th calendar day, or the 45th after 31 December, rolled to the next business day when that date is a weekend or holiday.
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.
