Alert September 06, 2011

FRB Seeks Comments on Information Collection Proposal that Would Allow Savings and Loan Holding Companies a Two-Year Phase-In Period to File FRB Regulatory Reports and Would Exempt a Limited Number of SHLCs from Initial Reporting

The FRB issued a Notice of Information Collection, seeking comment on its proposal (the “FRB Proposal”) that would allow savings and loan holding companies (“SLHCs”) a two‑year phase‑in period to file FRB regulatory reports on the same forms as those filed by bank holding companies (e.g., Annual Reports on Form FR Y-6, Financial Reports on Form FR Y-9C) and to exempt a limited number of SLHCs from initially filing FRB regulatory reports.  The FRB uses the FRB regulatory reports to monitor holding company operations, determine compliance with the Bank Holding Company Act and Regulation Y and perform other supervisory functions.

As of July 21, 2011, pursuant to the Dodd-Frank Act, the OTS, the agency previously responsible for the supervision of SLHCs, was merged into the OCC, and the OTS’ former duties are now divided among the FRB, the OCC, the FDIC and the CFPB.  The FRB initially proposed that SLHCs be subject to the same type of regulatory reporting as bank holding companies.  Prior to receiving reports from SLHCs on FRB regulatory reports, the FRB, under the FRB Proposal, would rely on organizational and financial information contained in the Thrift Financial Reports and other OTS reports that thrifts and their holding companies had been filing with the OTS, and the FRB would gradually phase in FRB regulatory reports.  The FRB Proposal would also give a small number of insurance companies an exemption from the reporting requirements.

The FRB will accept comments on the FRB Proposal through November 1, 2011.