Federal Reserve Issues Reporting Rules for Savings and Loan Holding Companies

by Katten Muchin Rosenman LLP
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On February 8, the Federal Reserve (or the Board) published in the Federal Register a notice of intent (NOI) to require savings and loan holding companies (SLHCs) to submit the same reports as bank holding companies (BHCs), beginning with the March 31, 2012 reporting period. The NOI stated that the Board would issue a formal proposed notice on information collection activities for SLHCs. The Federal Reserve is proposing a two-year phase-in period for most SLHCs to file Federal Reserve regulatory reports with the Board, as well as an exemption for some SLHCs from initially filing Federal Reserve regulatory reports.

All SLHCs would continue to submit all currently required Office of Thrift Supervision (OTS) reports, the Schedule HC – Thrift Holding Companies as part of the Thrift Financial Report (TFR) and the H-(b)11, through December 31, 2011, reporting period, using the existing processing, editing and validating system, which is the Electronic Filing System (EFS) established by the OTS. Effective for 2012, all SLHCs would still be required to report the HOLA H-(b)11 report (OTS Form H-(b)11; OMB No. 7100-0334) with the Federal Reserve. In addition, SLHCs that are initially exempt from reporting using the Federal Reserve’s regulatory reports would still be required to report Thrift Financial Report Schedule HC (OTS 1313; OMB No. 1557-0255) and the Federal Reserve’s FR Y-6 and FR Y-7 regulatory reports. Details about how SLHCs will submit TFR Schedule HC to the Federal Reserve effective for 2012 will be described in a separate notice in the Federal Register later this year. Additionally, the Federal Reserve will issue a transmittal letter later this year with information regarding the submission of the HOLA H-(b)11 report. Reporting requirements for BHCs would not be affected by this proposal. The Federal Reserve also proposes to revise other regulatory reports filed by BHCs to include SLHCs in the reporting panels going forward, as needed for supervisory purposes.

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