FR Y-9LP and FR Y-9SP Reporting: Parent-Only Statements at $3 Billion

FR Y-9LP and FR Y-9SP reporting puts a U.S. holding company’s parent-only books in front of the Federal Reserve: the parent’s own income statement and balance sheet, with its subsidiaries carried as equity-method investments. Under the Board’s FR Y-9LP instructions, effective March 2026, every holding company that files the consolidated FR Y-9C submits the FR Y-9LP quarterly, and so does each of its lower-tier holding companies. Under the FR Y-9SP instructions, effective December 2025, holding companies with total consolidated assets of less than $3 billion submit a shorter FR Y-9SP as of 30 June and 31 December. Both reports are due 45 calendar days after the as-of date, and both books state that no extensions of time are granted.

The Board’s December 2025 clearance notice estimated 411 FR Y-9LP respondents and 3,596 FR Y-9SP respondents, at 5.27 and 5.45 hours per response. Which form a given legal entity files depends on its group as well as its own balance sheet: a lower-tier holding company far below $3 billion still files the quarterly FR Y-9LP when its group files the FR Y-9C. The trigger date carries as much weight as the threshold, because the move to quarterly filing follows the consolidated-assets figure at 30 June of the preceding year.

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

Legal basis for FR Y-9LP and FR Y-9SP: BHC Act section 5(c), HOLA section 10 and Regulation Y

Page 1 of each form states that the report is required by law, and the two citation lists differ. The FR Y-9LP cites 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. The FR Y-9SP cites section 5(c) of the Bank Holding Company Act, section 225.5(b) of Regulation Y (12 CFR 225.5(b)) and section 10 of the Home Owners’ Loan Act. The issuing authority for both is the Board of Governors of the Federal Reserve System, and the completed reports go to the Federal Reserve Bank of the district where the holding company files.

The filer populations explain most of the difference. The FR Y-9LP instructions cover bank holding companies, savings and loan holding companies, securities holding companies and U.S. intermediate holding companies, which lines up with a form that adds Dodd-Frank section 618 (securities holding companies) and section 165 with Regulation YY (intermediate holding companies). The FR Y-9SP instructions name bank holding companies, savings and loan holding companies and securities holding companies, and leave intermediate holding companies out. The FR Y-9SP form does not cite section 618 even though its instructions include securities holding companies; neither document comments on that. Pairing each citation with a filer type is my interpretation, because the forms list the citations without assigning them.

Section 225.5(b) of Regulation Y speaks of an annual report. It requires each bank holding company to furnish, in the manner and form the Board prescribes, an annual report of its operations, and its closing sentence adds that additional information and reports shall be furnished as the Board may require. My reading is that the semiannual and quarterly parent-only statements rest on that closing sentence together with section 5(c) of the Act; the regulation itself names no schedule, threshold or deadline.

The operational rules live one level down, in the Board’s instruction books and report forms. Both reports belong to the FR Y-9 family under OMB control number 7100-0128, which the Board extended for three years with revision in a notice published on 8 December 2025 (90 FR 56756). The FR Y-9LP cover, stamped 03/2026, prints an approval expiry of 31 December 2028; the FR Y-9SP cover, stamped 12/2024, still prints 31 December 2027.

Who must report the FR Y-9LP or the FR Y-9SP: the $3 billion line and the group test

The instructions start from a broad rule: bank holding companies, savings and loan holding companies, securities holding companies and U.S. intermediate holding companies submit financial statements to the Federal Reserve regardless of size unless specifically exempted. They then sort filers by the top-tier company’s total consolidated assets. At $3 billion or more, the top tier files the FR Y-9C and the FR Y-9LP quarterly, as of the last calendar day of March, June, September and December, and each holding company that files the FR Y-9C submits the FR Y-9LP for its parent company. Below $3 billion, the holding company files the FR Y-9SP as of the last calendar day of June and December.

The group rule settles most edge cases. Where the top tier files the FR Y-9C, a separate FR Y-9LP is due for each lower-tier holding company “regardless of the size of the subsidiary holding company,” and a holding company below $3 billion that is a subsidiary of an FR Y-9C filer reports on the FR Y-9LP instead of the FR Y-9SP. In a group below $3 billion, the top tier files the FR Y-9SP for the top-tier parent and a separate FR Y-9SP is due for each lower-tier holding company, which the subsidiary may submit itself or have submitted for it. If the top tier is exempt from the FR Y-9C, a lower-tier holding company with $3 billion or more files it.

Two exemptions appear in both books: a holding company 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. The books add that a holding company not required to file under these criteria may still be required to file by the Federal Reserve Bank of the district in which it is registered. The FR Y-9C instructions carry a further carve-out that the parent-only books do not repeat. Certain savings and loan holding companies are exempt from the FR Y-9C and the FR Y-9SP and file the FR 2320 instead: a grandfathered unitary savings and loan holding company with primarily commercial assets whose thrifts make up less than 5 percent of consolidated assets, and one that primarily holds insurance-related assets and does not otherwise file financial reports with the SEC under section 13 or 15(d) of the Securities Exchange Act of 1934.

The line also moves by supervisory choice. A footnote in both books lets the Reserve Bank require a holding company below $3 billion to submit the FR Y-9C and the FR Y-9LP to meet supervisory needs. The criteria it lists, without limiting itself to them, are significant nonbanking activities, significant off-balance-sheet activities (including securitizations or managing or administering assets for third parties), and a material amount of SEC-registered debt or equity securities other than trust preferred securities. The same footnote states that a holding company not subject to the Federal Reserve’s capital adequacy guidelines that nonetheless elects to comply with them must file a complete FR Y-9C and FR Y-9LP and generally would not be permitted to revert to the FR Y-9SP.

For entry, the instructions apply the $3 billion line once a year, using the 30 June figure. A top-tier holding company that reaches $3 billion or more in total consolidated assets as of 30 June of the preceding year begins reporting the FR Y-9C and the FR Y-9LP in March of the current year, and its lower-tier holding companies begin the FR Y-9LP in March as well. If the threshold is reached through a business combination, the start moves forward to the first quarterly report date after the combination’s effective date. Once filing has begun, the instructions say that, in general, the holding company should file a complete FR Y-9C and FR Y-9LP going forward; a holding company whose total consolidated assets then fall below $3 billion for four consecutive quarters may revert to the FR Y-9SP, and so may its lower-tier holding companies.

What the report contains: FR Y-9LP schedules PI to PC-B and the shorter FR Y-9SP

Both reports are parent-only statements prepared under U.S. GAAP and the Board’s instructions, with investments in subsidiaries, associated companies and corporate joint ventures over which the parent exercises significant influence accounted for under the equity method. The FR Y-9LP is the fuller set. The Board’s December 2025 notice describes it as an income statement, a cash flow statement, a balance sheet, a schedule of investments in subsidiaries and associated companies, memoranda and notes. The FR Y-9SP collects basic balance sheet and income data for the parent, plus data on its intangible assets and intercompany transactions.

Schedule PI splits operating income by counterparty: bank subsidiaries and associated banks, nonbank subsidiaries and associated nonbank companies, and subsidiary or associated holding companies, each broken into dividends, interest, management and service fees, and other income. Equity in undistributed income of subsidiaries sits below the line in items 7.a to 7.c, and item 8 is net income. Schedule PC-A then shows the parent’s equity investments, including goodwill and other identifiable intangibles, and its nonequity investments and receivables, again by bank, nonbank and holding company subsidiaries. Schedule PC-B gathers parent-level memoranda: amounts maturing within one year, borrowings from unaffiliated parties that the parent guarantees for its subsidiaries, past-due and nonaccrual loans of the parent, pledged securities, and parent borrowings not held by financial institutions or insiders.

Two PC-B items belong to specific filers. Items 15(a) to 15(h), the combined assets, loans, operating revenue and counts of nonbank and thrift subsidiaries, are completed only by the top-tier holding company that files the FR Y-9C, and lower-tier filers leave them blank. Item 17, total nonbank assets, applies only to top-tier holding companies subject to the capital plan rule in 12 CFR 225.8 and to top-tier savings and loan holding companies with $100 billion or more in total consolidated assets that are not substantially engaged in insurance underwriting or commercial activities. Filers report the quarter’s average, calculated on a monthly basis.

The FR Y-9SP keeps the same skeleton with less detail. Schedule SI reports dividends and other income from bank subsidiaries, nonbank subsidiaries and subsidiary holding companies, interest and other expense, and equity in undistributed income in items 13(a) to 13(c). Schedule SC carries the parent balance sheet, with investments in bank, nonbank and subsidiary holding companies each split into equity investment, goodwill, and loans and receivables. Schedule SC-M is where the supervisory screens sit: total consolidated assets of the holding company (item 1, required from every filer), off-balance-sheet activities and SEC-registered securities (items 8(a) and 8(b)), the FR Y-10 confirmation (item 14), nonbank subsidiary totals for top-tier filers (item 17) and the FR Y-12 screening questions (items 18 and 19). Two sets of items appear only in December: the full-scope external audit questions in the Schedule SC memoranda, completed by top-tier and single-tier holding companies, and Schedule SI memorandum item 5, which asks top-tier companies whether they have 100 or more full-time equivalent employees.

The word “subsidiary” carries a narrower meaning here than in Regulation Y. For bank holding companies, Regulation Y section 225.2 reaches companies 25 percent or more owned or controlled, and Regulation LL uses a more-than-25-percent test for savings and loan holding companies. For the parent-only statements, the FR Y-9LP instructions define a subsidiary as a company in which the parent directly or indirectly owns more than 50 percent of the outstanding voting stock, and an associated company as one in which it owns 20 to 50 percent and exercises significant influence. The FR Y-9SP instructions describe associated banks as those in which the holding company controls between 20 and 25 percent.

All dollar amounts are in thousands, rounded to the nearest thousand, with items below $500 reported as zero. Rounded details are adjusted so that totals equal the sums of their components, and total assets and total liabilities and equity capital, which must be equal, are derived from unrounded numbers before rounding. The FR Y-9LP adds an option: a holding company with total assets of $10 billion or more may round to the nearest million, reporting zeros in the thousands column, in which case amounts below $500,000 are reported as zero.

Negative entries are generally not appropriate outside listed items. On the FR Y-9LP the list is Schedule PC item 5 (investments in and receivables due from subsidiaries and associated companies) and equity items 20(d) to 20(f). On the FR Y-9SP it is the equity investments in bank, nonbank and subsidiary holding companies (Schedule SC items 4(a), 5(a) and 6(a)) and equity items 16(c) to 16(e). The income statement and the FR Y-9LP cash flow statement may carry negatives as appropriate, and assets with credit balances move to liability items while liabilities with debit balances move to asset items. Negatives are recorded with a minus sign. Blank and zero also differ: the FR Y-9LP expects an amount or a zero in every item except where the organization’s structure makes the item inapplicable, and the FR Y-9SP lists its blank items and states that any other blank would be interpreted as a zero.

Deadlines: 45 calendar days after each as-of date, with no extensions

The submission date for both reports is 45 calendar days after the as-of date, defined as the date by which the Federal Reserve must receive the report; the FR Y-9LP book names the appropriate Reserve Bank. Reports are due by the end of the reporting day, which the books set at 5:00 P.M. at each of the Reserve Banks. A deadline that falls on a weekend or holiday moves to the first business day after it. Earlier submission is encouraged, and no extensions of time are granted.

The 14 August and 14 November dates for the FR Y-9LP, and the 14 August and 14 February dates for the FR Y-9SP, are the books’ own examples; 15 May and 14 February for the FR Y-9LP are the same 45-day count applied to 31 March and 31 December. All dates in the table move under the weekend and holiday rule. The FR Y-9C runs on 40 days after the March, June and September dates and 45 days after December, so for three quarters the parent-only statement is due five days after the consolidated report, and at year-end the two fall on the same day.

On a fixed calendar, the FR Y-9LP statements for the quarter now closing are due 45 days after its last day, and a semiannual filer’s June statements come due in mid-August with the December statements following in mid-February. For a holding company crossing the line, the first FR Y-9LP falls in the March of the year after the 30 June measurement, or on the first quarterly report date after a business combination’s effective date. The statements cover year-to-date income throughout: the FR Y-9LP income statement is presented on a calendar-year-to-date basis, and the FR Y-9SP income statement covers 1 January to 30 June for the June report and 1 January to 31 December for the December report.

Submission through Reporting Central: a TXT upload keyed on MDRM codes

Both books require every holding company to submit its completed reports electronically and point to the district Reserve Bank and Reporting Central for procedures. The Reporting Central user-guides page lists the FR Y-9LP and FR Y-9SP under its TXT Format section, marked with the single asterisk the page uses for mandatory electronic reports. The upload guides behind the format described here are the FR Y-9LP Reporting Central User Guide dated June 2026 and the FR Y-9SP File Upload User Guide dated April 2026.

The file layout is the same for both reports. Each item starts with the letter “L” as a separator, followed by the eight-character MDRM descriptor from the guide’s Appendix A; FR Y-9LP descriptors mostly begin BHCP and FR Y-9SP descriptors BHSP. A financial value follows a “+” sign, and for the FR Y-9LP the guide sets the maximum number of columns at one, so each financial item carries exactly one “+”. A positive value is entered as is, a negative value is preceded by a minus sign, a zero is entered as 0 and a null is left blank. Text values are preceded and followed by two underscores. The FR Y-9SP guide adds that standard financial data are in thousands with up to 14 digits and no decimal place, and that text items have their own character limits in Appendix A.

The header record carries the identifiers. Both guides specify the first 10 positions as the RSSD ID with leading zeroes, the next 10 as the report series ID (“FRY9LP” or “FRY9SP”) plus four trailing spaces, and then the as-of date in MM-DD-YYYY format. The guides build the file in a spreadsheet, save it as tab-delimited text and tell the preparer to remove any quotation marks at the start and end of the file before adding the header. The FR Y-9LP guide states that only one file upload can be submitted for each respondent and as-of date. After a clean upload, the data load into the report screen, where the FR Y-9LP guide says they can be validated, saved, submitted or deleted; formatting errors appear as messages in the upload window.

Several points a filing team would look for are absent from these sources. Neither guide sets a file-naming convention. Neither instruction book nor guide refers to XBRL or an XML taxonomy for these two reports, and the Reporting Central migration schedule, which flags reports moving to XML upload with a double asterisk, lists the FR Y-9SP (1 to 3 May 2026 wave) and the FR Y-9LP (26 to 28 June 2026 wave) as migrated without that flag. The guides do not describe resubmission mechanics. The books cover amendments as a substantive duty: the Federal Reserve may require an amended report when a previously submitted report contains significant errors, and a holding company should file one when audit adjustments restate statements already submitted.

The signature never travels with the file. A physical copy of each report must be manually signed by the chief financial officer, or the person performing that function, and kept on file for three years following submission; the signature is not part of the electronic submission. By signing the cover page, the officer acknowledges that a knowing and willful misrepresentation or omission of a material fact may bring sanctions under 18 U.S.C. 1001 and 1007.

Validation: validity edits that must balance and quality edits that should hold

Each instruction book ends with its edit checklists. Validity edits are written mostly as “must” tests and carry the header line “Each edit in the checklist must balance, rounding errors are not allowed.” Quality and intraseries edits are written as “should” tests that flag values the Federal Reserve expects to hold. The FR Y-9LP adds interseries edits that compare its figures with the same filer’s FR Y-9C; the FR Y-9SP checklist has validity, quality and intraseries edits only.

On the FR Y-9LP, the validity checks hold the statements together: total liabilities and equity capital (PC item 21) must equal total assets (PC item 10), the cash flow statement’s net income (PI-A Part I item 1) must equal Schedule PI item 8, and the PC-A total must equal PC item 5. Each free-text note pairs an amount with text, so a note with an amount and no description, or a description with no amount, fails. Interseries edit 0678 tests that parent total assets (PC item 10) do not exceed consolidated total assets (FR Y-9C, HC item 12), and edit 0151 expects the confidentiality request code on the FR Y-9LP to match the code on the FR Y-9C. Intraseries edits such as 0107 to 0110 expect year-to-date income from subsidiary holding companies in June, September and December to be no lower than in the previous quarter.

On the FR Y-9SP, validity edits require total consolidated assets in Schedule SC-M item 1 whenever parent total assets are not zero, require the CEO name, phone number and e-mail address, and enforce the December-only design: edit 0931 requires memorandum item 5 on Schedule SI to be null in June, and edit 0932 allows only null or 1 in December. Among the quality and intraseries edits, 0865 expects total consolidated assets to exceed parent total assets, 1012 flags a period-to-period change in total consolidated assets outside a range of minus 50 to plus 50 percent, and 1015 and 1016 test the retained earnings roll-forward to within 10 percent, the December version using second-half income (year-to-date net income less the June figure). Quality edit 0869 checks that, on a December report, the previous period’s total consolidated assets are below $3 billion.

Neither book publishes a list of rejection codes or says how a quality-edit failure is cleared. The verification paragraph in each book says that all amounts should be compared with the previous report before submission and that unusual changes should be explained briefly to the appropriate Reserve Bank, and the books direct questions on interpretation to the Reserve Bank of the filer’s district. The upload guides add only that formatting errors in the text file produce error messages in the upload window.

The two appendices are on different refresh cycles. The FR Y-9SP book effective December 2025 carries checklists headed “Effective as of December 31, 2025,” with validity edit 0934 added and edits 0899, 0917, 0950, 1010 and 1011 marked as revised. The FR Y-9LP book effective March 2026 still prints checklists headed “Effective as of June 30, 2022,” and its summary of edit changes lists four validity edits added on 28 March 2022.

Caveats and interactions: equity method, the FR Y-9C, and the FR Y-10, FR Y-11 and FR Y-12 links

The parent-only figures sit downstream of other returns. The FR Y-9SP instructions say the equity investment in bank subsidiaries generally should equal the holding company’s proportionate interest in the equity capital accounts in the bank’s Report of Condition, and they build equity in undistributed income from the holding company’s proportionate interest in the net income in the bank’s Report of Income less dividends declared. An optional worksheet supports the calculation and is not submitted with the report; where audit adjustments restate the bank subsidiary’s statements, the worksheet instructions say to use the restated amount. Our FFIEC Call Report guide covers the bank-level return those figures come from.

The two books do not describe the shift in status identically. The FR Y-9SP book, like the FR Y-9C book, starts FR Y-9C and FR Y-9LP reporting at the first quarterly report date after a business combination, a transaction between entities under common control, or a branch acquisition that is not a business combination. The FR Y-9LP book effective March 2026 names only the business combination. A group that crosses $3 billion through a common-control transaction will find the trigger in the FR Y-9SP and FR Y-9C books and not in the FR Y-9LP book, which is a reason to confirm the start date with the Reserve Bank.

Several line items still describe negative amounts in parentheses. On the FR Y-9LP, these include Schedule PI items 1(d), 3(a), 3(c) and 7(a) to 7(c), which say to report a loss or negative amount in parentheses. Schedule PI-A, Part I, items 2(b), 2(c) and 2(e) to 2(g) say to record a negative entry in parentheses rather than with a minus sign, even though the general instructions for the same schedule require a minus sign for the entries in items 2(b), 2(c), 2(e) and 2(f). On the FR Y-9SP, they include Schedule SI items 9(a) and 9(c), which say to report a negative amount in parentheses. The General Instructions in both books require negative entries to be recorded with a minus sign, and both upload guides format negatives with a minus sign, so a file built to the guides carries the minus sign for these items too.

The December 2025 notice permitted electronic signatures for the FR Y-9C signature and attestation requirement from 31 March 2026. The parent-only books contain no equivalent: the FR Y-9LP book effective March 2026 and the FR Y-9SP book effective December 2025 both still describe a physical copy manually signed by the chief financial officer.

The completed reports are available to the public on request, and the Board’s report pages state that the data are published in the Federal Reserve Bulletin and the Uniform Bank Holding Company Performance Report, with microdata available through the Board’s Freedom of Information Office with certain exceptions. A filer may request confidential treatment for items within a Freedom of Information Act exemption, such as exemption 4 for confidential commercial or financial information or exemption 6 for personal privacy, under 12 CFR 261.17. The request must be in writing before the electronic submission and must show the specific harm that public release would cause; stating that competitive harm would result is not sufficient. The page 1 check boxes must be completed, and the answers to them are public. On the FR Y-9SP, the CEO contact information and the auditing firm engagement partner’s name and e-mail are for the Federal Reserve’s confidential use and are not released to the public.

Two other reports hang off FR Y-9SP memoranda, and a third points back to the FR Y-9SP book. Schedule SC-M item 14 asks whether all changes in investments and activities have been reported on the FR Y-10; the top-tier (or single-tier) holding company must answer 1 or 0 and may not leave it blank, while lower-tier holding companies leave it blank. Items 18 and 19 screen for the FR Y-12: a company holding nonfinancial equity investments under the listed authorities, in aggregate equal to or above 10 percent of total capital on an acquisition-cost basis, must file it, a report covered in our FR Y-12 reporting guide. Entity-level statements for qualifying nonbank subsidiaries go on the separate FR Y-11, whose instructions refer preparers to the FR Y-9C or FR Y-9SP books for additional information on the items requested; our FR Y-11 and FR Y-11S guide sets out its thresholds.

Neither book describes a waiver procedure or a transitional regime. On my reading, proportionality comes from the split itself, from the December-only items on the FR Y-9SP, and from the Reserve Bank’s discretion to require reports from holding companies outside the size criteria.

Changes: ASU 2016-02 leases on the FR Y-9LP from 31 March 2026 and a December 2025 FR Y-9SP edit refresh

The lease revision traces to the Board’s initial notice of 2 October 2024 (89 FR 80244); the December 2025 notice records that the comment letters addressed other parts of the proposal, that none addressed the FR Y-9LP lease reporting revision, and that the revision was finalized as proposed. The notice described the FR Y-9 revisions as consistent with Call Report changes effective 31 December 2024 and made them effective as of the 31 March 2026 report date. In the FR Y-9LP book effective March 2026, Schedule PC item 6 becomes “Premises and fixed assets (including right-of-use assets)” and covers right-of-use assets accounted for under ASC Topic 842, with a pointer to the Lease Accounting entry in the FR Y-9C Glossary. Lease liabilities for finance leases join the list of borrowings in item 14, other borrowed money with a remaining maturity of more than one year. Lease liabilities for operating leases are excluded from item 14 and go to item 17, other liabilities. The older wording on capitalized leases and capital leases is gone from the book.

The FR Y-9SP book effective December 2025 changed only its cover date and its edit appendix. A comparison of its text with the previous book, whose cover reads “Effective December 2024,” shows the General Instructions and line-item instructions unchanged, and the edit checklists now carry the 31 December 2025 effective date. The Board’s report pages label historical editions by a month that can differ from the cover: the FR Y-9LP book listed as January 2025 carries the cover “Effective December 2024,” as does the FR Y-9SP book listed as June 2025.

Looking ahead, the Board’s page of information collections under review lists only FR Y-9C items among the FR Y-9 reports and names no FR Y-9LP or FR Y-9SP proposal. The December 2025 notice directed readers to that page, and to the OMB inventory of approved collections, for the supporting statements behind the FR Y-9 revisions.

Frequently Asked Questions

We crossed $3 billion at 30 June. Is the December FR Y-9SP for that year still due?

The instructions start FR Y-9C and FR Y-9LP reporting in March of the following year and do not say in terms that the December FR Y-9SP of the crossing year is dropped. The FR Y-9SP checklist contains quality edit 0869, which expects the previous period’s total consolidated assets on a December report to be below $3 billion, so a December filing in this position will raise that flag. The books direct interpretation questions to the Reserve Bank of the filer’s district, and this is one to put to it before the December cycle.

Our FR Y-9SP holding company is being acquired by a group that files the FR Y-9C. When does it switch to the FR Y-9LP?

The FR Y-9LP book says a holding company below $3 billion that is a subsidiary of a holding company filing the FR Y-9C reports on the FR Y-9LP; the FR Y-9SP book phrases the same rule as a subsidiary of a holding company with $3 billion or more. The acquiring group then owes a separate FR Y-9LP for each lower-tier holding company. Neither book states the first report date for a newly acquired lower-tier company, and the shift-in-status paragraph is written around a top tier crossing $3 billion, so the start date is a question for the Reserve Bank.

Our top-tier parent is an employee stock ownership plan. Who files what?

A holding company that is an ESOP at calendar year-end files the FR Y-9ES annually as of 31 December, and no other FR Y-9 series form. Its subsidiary holding companies file the appropriate FR Y-9 report under the normal rules. On the FR Y-9LP, the lower-tier parent reports the nonbank subsidiary memoranda in Schedule PC-B items 15(a) to 15(h), and the ESOP leaves them blank.

Does the $10 billion million-rounding option use consolidated or parent-only total assets?

The FR Y-9LP rounding paragraph refers to “holding companies with total assets of $10 billion or more” without saying which measure and without addressing lower-tier filers inside a larger group; the option is written as one each holding company may take at its own choice. The FR Y-9SP book has no million-rounding option.

Does the March 2026 lease change reach the FR Y-9SP?

The December 2025 notice described the revision as instructing FR Y-9LP filers to report leases under ASU 2016-02. The FR Y-9SP book effective December 2025 contains no right-of-use or lease-liability text, and its line-item instructions match the prior edition, so the published FR Y-9SP instructions carry no equivalent change.

Can confidential treatment be requested after the file has been submitted?

The instructions require the written request before the electronic submission and say confidential treatment will not be considered if the check boxes are not completed; they do not describe a later route. For a holding company filing both the FR Y-9C and the FR Y-9LP, interseries edit 0151 also expects the two confidentiality codes to match.

Which FR Y-9SP items stay blank for a holding company with no nonbank subsidiary?

The book lists them: Schedule SI items 2(a), 2(b) and 13(b), Schedule SC items 5(a) to 5(c) and 14(b), and Schedule SC-M items 9, 10 and 13. Validity edits 0895 and 0897 enforce the mirror image, requiring SI items 2(a) and 2(b) to be completed when the company does own a nonbank subsidiary, so the ownership fact has to be right before either set of items is filled or left empty.

Related Articles

• FR Y-9C Reporting: An 8% CBLR and a Four-Quarter Grace Period: the community bank leverage ratio changes in the FR Y-9C, the consolidated return whose filing brings the FR Y-9LP with it.
• FR Y-12 Reporting: Thresholds, Schedules and the 45-Day Deadline: the nonfinancial equity investment report that FR Y-9SP memoranda items 18 and 19 screen for.
• FR Y-11 Reporting: Four Quarterly Tests and a 60-Day Deadline: entity-level statements for nonbank subsidiaries of U.S. holding companies.
• FFIEC Call Report: Who Files 031, 041 or 051 for 30 September 2026: the bank-level return behind the equity-method figures in the parent-only statements.
• FR Y-15 Reporting: The Fed’s Systemic Risk Report, Schedule by Schedule: the systemic risk indicators report filed by the largest holding companies.

Key Takeaways

• Pull total consolidated assets at 30 June each year: at $3 billion or more, the top tier and every lower-tier holding company owe FR Y-9LP statements from the following March report date.
• Diary 15 May, 14 August, 14 November and 14 February for the FR Y-9LP, and 14 August and 14 February for the FR Y-9SP, each by 5:00 P.M. at the Reserve Bank and rolled forward past weekends and holidays.
• Map right-of-use assets to FR Y-9LP Schedule PC item 6, finance lease liabilities to item 14 and operating lease liabilities to item 17 for every report from 31 March 2026.
• Build each upload header as a 10-position RSSD ID with leading zeroes, “FRY9LP” or “FRY9SP” plus four spaces, and the as-of date in MM-DD-YYYY; the FR Y-9LP guide adds that only one file upload can be submitted for each respondent and as-of date.
• Weigh an election to follow the capital adequacy guidelines below $3 billion as a commitment: it brings a complete FR Y-9C and FR Y-9LP and generally no return to the FR Y-9SP.
• Complete the audit questions and the 100-employee question only on the December FR Y-9SP; a value in the June employee item fails validity edit 0931.
• File the CFO-signed paper copy with the workpapers for three years; the March 2026 electronic-signature option covers the FR Y-9C alone.

Sources and References

• Board of Governors of the Federal Reserve System, FR Y-9LP report page: https://www.federalreserve.gov/apps/reportingforms/Report/Index/FR_Y-9LP
• Board of Governors of the Federal Reserve System, FR Y-9SP report page: https://www.federalreserve.gov/apps/reportingforms/Report/Index/FR_Y-9SP
• Instructions for Preparation of Parent Company Only Financial Statements for Large Holding Companies, Reporting Form FR Y-9LP, effective March 2026 (current): FR Y-9LP instructions (PDF)
• FR Y-9LP reporting form (current, OMB 7100-0128): FR Y-9LP form (PDF)
• FR Y-9LP instructions, edition listed as January 2025, cover “Effective December 2024” (historical): FR Y-9LP instructions, January 2025 listing (PDF)
• FR Y-9LP reporting form, January 2025 listing (historical): FR Y-9LP form, January 2025 listing (PDF)
• Instructions for Preparation of Parent Company Only Financial Statements for Small Holding Companies, Reporting Form FR Y-9SP, effective December 2025 (current): FR Y-9SP instructions (PDF)
• FR Y-9SP reporting form (current, OMB 7100-0128): FR Y-9SP form (PDF)
• FR Y-9SP instructions, edition listed as June 2025, cover “Effective December 2024” (historical): FR Y-9SP instructions, June 2025 listing (PDF)
• Instructions for Preparation of Consolidated Financial Statements for Holding Companies, Reporting Form FR Y-9C, effective September 2026 (current): FR Y-9C instructions (PDF)
• 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: FR Y-11 and FR Y-11S instructions (PDF)
• Federal Reserve System, Agency Information Collection Activities: Announcement of Board Approval Under Delegated Authority and Submission to OMB (FR Y-9 and FR Y-14A/Q/M), 90 FR 56756, 8 December 2025, FR Doc. 2025-22264: https://www.govinfo.gov/content/pkg/FR-2025-12-08/pdf/2025-22264.pdf
• 12 CFR 225.5, Registration, reports, and inspections (Regulation Y), Code of Federal Regulations 2025: https://www.govinfo.gov/content/pkg/CFR-2025-title12-vol3/xml/CFR-2025-title12-vol3-sec225-5.xml
• Federal Reserve Financial Services, Reporting Central user guides: https://app.frbservices.org/central-bank/reporting-central/user-guides.html
• Reporting Central User Guide, FR Y-9LP, Statistics Function, June 2026: https://www.frbservices.org/wp-content/uploads/fry-9lp-user-guide.pdf
• FR Y-9SP File Upload User Guide, Statistics Function, April 2026: https://www.frbservices.org/wp-content/uploads/fry-9-sp-upload-user-guide.pdf
• Reporting Central, Report Series Migration Status Update: https://www.frbservices.org/binaries/content/assets/crsocms/central-bank/reporting-central/reporting-central-report-series-migration-schedule.pdf
• Board of Governors of the Federal Reserve System, information collections under review: https://www.federalreserve.gov/apps/reportingforms/home/review

Working the FR Y-9LP and FR Y-9SP calendar from the 30 June test

Total consolidated assets at 30 June are measured once a year, and every due date follows from a 45-calendar-day count. Record the 30 June figure each year as the input to the next form choice. Where a business combination, common-control transaction or branch acquisition is involved, put the start date to the Reserve Bank early, because the FR Y-9LP book names only the business combination while the FR Y-9SP and FR Y-9C books name all three.

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