• Amendments to Structure Reporting for Savings and Loan Holding Companies
  • October 31, 2012
  • Law Firm: Jones Walker LLP - Washington Office
  • As authorized under the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 and pursuant to Regulation LL, the Federal Reserve will expand the entities that must submit structure reports to include Savings and Loan Holding Companies ("SLHCs"). These reports are the Report of Changes in Organizational Structure (FR Y-10) effective December 1, 2012, the Annual Report of Holding Companies (FR Y-6), and the Annual Report of Foreign Banking Organizations (FR Y-7). The reporting on the FR Y-6 and FR Y-7 is effective for those entities with fiscal year ends beginning December 31, 2012. In addition, SLHCs must provide a one-time verification with respect to nonbank subsidiaries that meet the quarterly FR Y-11 or FR 23141 reporting criteria.

    The final reporting changes for the FR Y-10, FR Y-6, and FR Y-7 and the one-time verification were announced in the Federal Register on September 14, 2012. The final reporting forms and instructions for these reports have been posted to the Federal Reserve Board’s public website located under Savings and Loan Holding Company Reporting Forms.

    As a result of public comments, and as announced in the September 14, 2012, Federal Register, the Federal Reserve is implementing a phased-in approach for filing the FR Y-10 for nonbank subsidiaries in order to allow SLHCs additional time to acclimate to the structure reporting requirements. Initially, the FR Y-10 will be filed for only top-tier and lower tier SLHCs, depository subsidiaries, and branches by December 30, 2012. FR Y-10 reports will be required for each nonbank subsidiary by June 30, 2013, or September 30, 2013, depending on the size and reporting frequency of the nonbank subsidiary, and by December 31, 2013, for all other entities reportable on the FR Y-10 report that have not been previously reported.