FR Y-14M: Navigate Capital Assessments and Stress Testing Like a Pro (2025 Guide)
Are you a bank holding company (BHC), intermediate holding company (IHC), or covered savings and loan holding company (SLHC) navigating the complexities of the FR Y-14M report? This guide simplifies the process, ensuring accurate and timely submissions while minimizing your reporting burden.
What is the FR Y-14M Report?
The FR Y-14M report collects crucial loan portfolio data from BHCs, IHCs, and SLHCs. The Federal Reserve uses this data for supervisory stress testing models and continuous monitoring. It covers these key areas:
- Domestic First Lien Closed-end 1-4 Family Residential Loans
- Domestic Home Equity Loans and Lines of Credit
- Address Matching
- Domestic Credit Card Data
Who Needs to File the FR Y-14M?
You're required to submit the FR Y-14A/Q/M if you meet ALL of the following criteria:
- Your company is a BHC, IHC, or SLHC.
- Your total consolidated assets are $100 billion or more.
- The $100 billion or more is defined by the capital plan rule (12 CFR 225.8) for BHCs and IHCs, and the Board’s rule on savings and loan holding companies (12 CFR part 238) for SLHCs.
- You meet the threshold based on your FR Y-9C submission as of the end of the quarter. Firms are required to begin submitting the FR Y-14M the reporting period after the end of the quarter in which they met the threshold.
Materiality Thresholds: What You Need to Know
Certain data elements and schedules depend on materiality thresholds. Here's how to determine if a specific data collection or element applies to you:
- Category IV Firms: Material portfolios have asset balances greater than $5 billion or exceed ten percent of Tier 1 capital (averaged over the four preceding quarters to the reporting quarter).
- Category I, II, or III Firms: Material portfolios have asset balances exceeding $5 billion or more than five percent of Tier 1 capital (averaged over the four preceding quarters to the reporting quarter).
The materiality threshold is based on the asset balances associated with the BHC’s, IHC’s or SLHC’s owned portfolio. All data used to determine materiality should be measured as of the close of business of the last calendar day of the quarter, and assets included in a given portfolio are defined in the instructions for each schedule. Even if portfolios are immaterial, BHCs, IHCs, and SLHCs can still opt to complete the data schedules.
When and Where to Submit
- Frequency: Monthly, as of the last business day of each calendar month.
- Due Date: The 30th calendar day after the last business day of the preceding calendar month. If the 30th falls on a weekend or holiday, the deadline shifts to the next business day.
- Where: Electronically, either directly to the Federal Reserve or through data aggregators.
- New Reporters: Receive an initial onboarding delay; the first deadline is 90 days after the reporting month corresponding to the quarter when the initial FR Y-14Q reports are submitted.
How to Prepare Accurate Reports
-
GAAP Compliance: Adhere to generally accepted accounting principles (GAAP).
-
Consolidation Rules: Follow FR Y-9C General Instructions for consolidation guidelines.
-
Technical Details:
- Dates: Use YYYYMMDD format.
- Negative Numbers: Use a minus sign (-).
- Data Completeness: Fill all items with an amount, zero, or null value, unless specified options like "not available" or "other" are available. Leave blank only if no applicable options exist.
- File Format: Use a single pipe-delimited text file for First Lien, Home Equity, and Address Matching Schedules, with a vertical bar (|) delimiter (ASCII decimal 124, ASCII hexadecimal 7C).
Key Resources for Accurate Reporting
- FR Y-14M instructions
- FR Y-14Q/A instructions
- The latest FR Y-9C instructions available on the Federal Reserve’s public website: http://www.federalreserve.gov/reportforms
Navigating CECL (ASU 2016-13)
The Financial Accounting Standards Board (FASB) issued accounting standards update (ASU) 2016-13 which introduced the current expected credit losses methodology (CECL). Institutions that have adopted CECL should also refer to Regulation YY, 12 CFR part 252, regarding the requirement to reflect ASU 2016-13 for a given stress test cycle.
Important Considerations
- Confidentiality: Data is treated confidentially under Freedom of Information Act exemption 8 (5 U.S.C. 552(b)(8)) and Exemption 4 (5 U.S.C. 552(b)(4)).
- Amended Reports: Required for significant errors or omissions discovered after submission. Contact your Reserve Bank if resubmissions are needed.
- International Exposures: You are not required to report if foreign law prohibits it. Provide a detailed legal analysis justifying the omission.
Where to Get Help
Submit questions or requests for interpretations via e-mail to your designated Reserve Bank contact.
By following these guidelines, you can confidently navigate the FR Y-14M reporting process, ensuring accuracy, compliance, and reduced burden.