Banks Seek More Time to Adapt to Proposed CCAR Form Changes

By Jeff Bater

Nov. 17 — A banking industry group is urging the Federal Reserve to give big lenders more time to adapt to proposed changes for a form used by the regulator to gather information for the Comprehensive Capital Analysis and Review (CCAR) exercise process.

The Financial Services Roundtable (FSR) said the FR Y-14 forms are complex and that the group wants to ensure the Fed receives quality data. In a letter commenting on proposed Fed changes to the FR Y-14, the group pressed regulators to allow banks at least six months to adapt to any new information requirements pertaining to the form in order to ensure the accuracy of the information submitted.

Data collected through the FR Y-14 forms is used as part of the CCAR and stress testing processes for 33 banks. Estimates collected by the Roundtable from banks indicate the Fed's projections vastly underestimate the time necessary to complete the FR Y-14 forms, according to the industry group.

Differing Burden Projections

“The Federal Reserve's own burden projections estimate it takes banks more than 700,000 total industry employee hours to submit the requested data,” the FSR said in a news release. “On average, banks report needing 170,000 hours each to collect, prepare, and submit the requested information. This translates into a total regulatory burden of 5.6 million hours for the 33 banks (the equivalent of 2,800 full-time employees).”

The Roundtable also urged the Fed to re-evaluate its burden projections for the FR Y-14 forms and reduce the number of changes associated with its information requests.

“Since the inception of this process, the Board has made regular changes to the schedules,” the FSR wrote in the comment letter. “Each change, no matter how minor, adds to the reporting burden of respondents. Each change requires a respondent to manually modify data collection procedures or recode systems. More importantly, frequent changes impair the quality of the data and prevent the maturation of this reporting requirement.”

The FSR is also asking the Fed to take steps to improve communication channels with banks, correct inconsistencies that exist within the form, and improve the Fed's process for accepting and reviewing FR Y-14 data.

The group said the Fed continues to make changes to the FR Y-14 form, while “setting tight deadlines for data submission.” It said the ability of banks to prepare and submit accurate data is “vitally important as the Fed is increasingly reliant on stress testing to measure the strength of the financial system.”

To contact the reporter on this story: Jeff Bater in Washington at

To contact the editor on this story: Mike Ferullo in Washington at

For More Information 
The Roundtable news release and comment letter are available at