WASHINGTON–The Financial Services Roundtable (FSR) is raising concerns over a new proposal that even the source of that proposal, the Federal Reserve, is saying will require banks to invest more than 700,000 total industry employee hours to assemble the requested data—and that’s the conservative estimate.
The FSR said the proposed changes to information collection forms that are required as part of the Comprehensive Capital Analysis and Review Exercise (CCAR) process will only require even more time than is already demanded. Data collected through the FR Y-14 forms is used by regulators as part of the CCAR and stress testing processes for 33 individual banking institutions. The suite of forms is complex, with dozens of data schedules and thousands of different data fields, the FSR said.
“Estimates collected by FSR directly from banks indicate the Fed’s projections vastly underestimate the time necessary to complete the FR Y-14 forms,” the FSR said. “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.”
In a letter sent to the Fed, FSR urged regulators to allow banks at least six months to adapt to any new information requirements pertaining to the FR Y-14 form in order to ensure the accuracy of the information submitted. FSR also urged the Fed to reevaluate its burden projections for the FR Y-14 forms and reduce the amount of changes associated with its information requests.
FSR also asks 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.