Federal Register: February 4, 2009 (Volume 74, Number 22)

DOCID: fr04fe09-105 FR Doc E9-2274

SUBJECT CATEGORY:

Submission for OMB Review; Comment Request--Thrift Financial Report: Schedules SC, SO, VA, PD, LD, CC, CF, DI, SI, FV, FS, HC, CSS, and CCR

DATES: Submit written comments on or before March 6, 2009. The regulatory reporting revisions described herein take effect on a phasedin basis on March 31, 2009, June 30, 2009, and December 31, 2009.

DOCUMENT SUMMARY:

In accordance with the requirements of the Paperwork Reduction Act of 1995 (44 U.S.C. 3507), OTS may not conduct or sponsor, and the respondent is not required to respond to, an information collection unless it displays a currently valid OMB control number. On October 1, 2008, OTS requested public comment for 60 days (73 FR 57205) on a proposal to extend, with revisions, the Thrift Financial Report (TFR), which is currently an approved collection of information. The notice described regulatory reporting revisions proposed for the TFR, Schedule SCConsolidated Statement of Condition, Schedule SOConsolidated Statement of Operations, Schedule VAConsolidated Valuation Allowances and Related Data, Schedule PDConsolidated Past Due and Nonaccrual, Schedule LDLoan Data, Schedule CCConsolidated Commitments and Contingencies, Schedule CFConsolidated Cash Flow Information, Schedule DIConsolidated Deposit Information, Schedule SI
Supplemental Information, Schedule FSFiduciary and Related Services, Schedule HCThrift Holding Company, Schedule CSSSubordinate Organization Schedule, and Schedule CCRConsolidated Capital Requirement, and on a proposed new schedule, Schedule FVConsolidated Assets and Liabilities Measured at Fair Value on a Recurring Basis. The changes were proposed on a phasedin basis over 2009.

The revisions would eliminate 3 lines from the TFR, eliminate Schedule CSS in its entirety, revise 24 existing items, add 240 new items (including a new Schedule FV), and eliminate confidential treatment of Schedule FS and Schedule HC data.

After considering the comments received on the proposal, OTS has adopted most of the proposed revisions, with limited exceptions in response to certain comments, on the phasedin basis that had been proposed. OTS continues to evaluate certain other proposed revisions in light of the comments received thereon and will not implement these revisions on their proposed effective dates. OTS is submitting the adopted revisions to OMB for review and approval.

SUMMARY:

Agency Information Collection Activities; Proposals, Submissions, and Approvals

SUPPLEMENTAL INFORMATION

The effect of the proposed revisions to the reporting requirements of these information collections will vary from institution to institution, depending on the institution's involvement with the types of activities or transactions to which the proposed changes apply. OTS estimates that implementation of these reporting changes will result in a small increase in the current reporting burden imposed by the TFR. The following burden estimates include the effect of the proposed revisions.

Title: Thrift Financial Report.

OMB Number: 15500023.

Form Number: OTS 1313.

Statutory Requirement: 12 U.S.C. 1464(v) imposes reporting requirements for savings associations. Except for selected items, these information collections are not given confidential treatment.

Type of Review: Revision of currently approved collections.

Affected Public: Savings associations.

Estimated Number of Respondents and Recordkeepers: 811.

Estimated Burden Hours per Respondent: 54.68 burden hours on average.

Estimated Frequency of Response: Quarterly.

Estimated Total Annual Burden: 177,398 burden hours.

Abstract: All OTSregulated savings associations must comply with the information collections described in this notice. OTS collects this information each calendar quarter or less frequently if so stated. OTS uses this information to monitor the condition, performance, and risk profile of individual institutions and systemic risk among groups of institutions and the industry as a whole. Except for selected items, these information collections are not given confidential treatment. I. Background

OTS last revised the form and content of the TFR in a manner that significantly affected a substantial percentage of institutions in March 2007. Revisions since March 2007 focused on specific activities and were primarily made in response to changes in generally accepted accounting principles (GAAP). These focused revisions meant that the new or revised TFR items were minor or applicable to only a small percentage of institutions.

During the past year OTS has evaluated its ongoing information needs. OTS recognizes that the TFR imposes reporting requirements, which are a component of the regulatory burden facing institutions. Another contributor to this regulatory burden is the examination process, particularly onsite examinations during which institution staff spend time and effort responding to inquiries and requests for information designed to assist examiners in evaluating the condition [[Page 6087]]
and risk profile of the institution. The amount of attention that examiners direct to risk areas of the institution under examination is, in large part, determined from TFR data. These data, and analytical reports including the Uniform Thrift Performance Report, assist examiners in scoping and making their preliminary assessments of risks during the planning phase of the examination.

A riskfocused review of the information from an institution's TFR allows examiners to make preliminary risk assessments prior to onsite work. The degree of perceived risk determines the extent of the examination procedures that examiners initially plan for each risk area. If the outcome of these procedures reveals a higher level of risk in a particular area, the examiner adjusts the examination scope and procedures accordingly.

TFR data are also a vital source of information for the monitoring and regulatory activities of OTS. Among their benefits, these activities aid in determining whether the frequency of an institution's examination cycle should remain at maximum allowed time intervals, thereby lessening overall regulatory burden. More riskfocused TFR data enhance the ability of OTS to assess whether an institution is experiencing changes in its risk profile that warrant immediate follow up, which may include accelerating the timing of an onsite examination.

In developing this proposal, OTS considered a range of potential information needs, particularly in the areas of credit risk, liquidity, and liabilities, and identified those additions to the TFR that are most critical and relevant to OTS in fulfilling its supervisory responsibilities. At the same time, OTS identified certain existing TFR line items that are no longer sufficiently critical or useful to warrant their continued collection. OTS recognizes that the reporting burden that would result from the addition to the TFR of the new items discussed in this proposal would not be fully offset by the proposed elimination of, or establishment of reporting thresholds for, a limited number of other TFR items, thereby resulting in a net increase in reporting burden. After savings associations make any necessary changes to their systems and records, OTS estimated that these reporting changes would produce an average net increase of 2.0 hours per institution per year in the ongoing reporting burden of the TFR. Nevertheless, when viewing these proposed revisions to the TFR within a larger context, they are intended to maintain the effectiveness of the on and offsite supervision activities of the OTS, which should help to control the overall regulatory burden on institutions.

II. Current Actions

On October 1, 2008, OTS requested comment on proposed revisions to the Thrift Financial Report (73 FR 57205). The proposed changes were to be implemented on a phasedin basis during 2009. A limited group of changes was proposed to take effect March 31, 2009; most revisions were proposed to take effect June 30, 2009; and a final group of revisions was proposed to take effect December 31, 2009.\1\
\1\ In addition, on November 26, 2008, OMB approved the Federal banking agencies' joint emergency clearance requests to add two items to Call Report Schedule RCO, Other Data for Deposit Insurance and FICO Assessments, and to TFR Schedule DIConsolidated Deposit Informationthat are effective December 31, 2008, and that are applicable to all institutions participating in the FDIC's Transaction Account Guarantee Program. A participating institution must report the amount and number of its noninterestbearing transaction accounts, as defined in the FDIC's regulations governing the program, of more than $250,000 in Call Report Schedule RCO, Memorandum items 4.a and 4.b, or in TFR Schedule DI, lines DI570 and DI575. The FDIC will use this information to calculate assessments for participants in the Transaction Account Guarantee Program. Because OMB's approval of the agencies' emergency clearance request expires on May 31, 2009, the agencies proposed on December 23, 2008, under OMB's normal clearance procedures to collect these two items each quarter until the Transaction Account Guarantee Program ends. See 73 FR 78794.

OTS received one comment letter on the proposed revisions from a trade group representing banks and savings associations of all sizes. The trade group noted the added burden the proposed revisions would place on institutions filing the TFR and asked that OTS adopt only those changes essential to its mission. The trade group commented on a reporting issue that was not addressed in the original proposal and recommended a revision requiring institutions to report ``reciprocal deposits'' \2\ separately from brokered deposits. OTS will consider this recommendation concerning reciprocal deposits when it next assesses the need and basis for possible future revisions to the TFR. This commenter also commented on the reporting of sweep accounts from other institutions, including affiliated institutions, noting that the TFR may need to be revised depending on the resolution of how such accounts are treated for deposit insurance assessment purposes. \2\ The trade group also recommended that ``reciprocal deposit'' be defined as a deposit ``obtained when an insured depository institution exchanges funds, dollarfordollar, with members of a network of other insured depository institutions, where each member of the network sets the interest rate to be paid on the entire amount of funds it places with other network members, and all funds placed through the network are fully insured by the FDIC.''

After considering the comments received on the proposal, OTS has decided to move forward with most of the reporting changes, with limited modifications in response to certain comments, on the phasedin basis that had been proposed. Sections III, IV, and V of this notice identify the changes proposed to take effect March 31, June 30, and December 31, 2009, respectively; and discuss the comments received on the proposed TFR revisions that OTS has decided to implement, as modified.

OTS recognizes institutions' need for lead time to prepare for reporting changes, and thus proposed the phasedin implementation schedule for 2009. TFR items that will be new or revised effective March 31, 2009, are limited in number and most are linked to changes in generally accepted accounting principles taking effect at the same time. For the March 31, 2009, report date, thrifts may provide reasonable estimates for any new or revised TFR item initially required to be reported as of that date for which the requested information is not readily available. This same policy on the use of reasonable estimates will apply to the reporting of other new or revised items when they are first implemented effective June 30 and December 31, 2009. The specific wording of the captions for the new or revised TFR line items discussed in this notice and the numbering of these items should be regarded as preliminary.

III. TFR Revisions Proposed for March 2009

OTS received no comments on revisions proposed in response to accounting changes applicable to noncontrolling (minority) interests in consolidated subsidiaries; and to a reporting addition for otherthan temporary impairment charges on debt and equity securities. Therefore, these revisions will be implemented in March 2009 as proposed. A. Background

In December 2007, the Financial Accounting Standards Board issued Statement of Financial Accounting Standards No. 160, ``Noncontrolling Interests in Consolidated Financial Statements'' (FAS 160). Under this Statement, a noncontrolling interest, formerly referred to as a minority interest, is that portion of total stockholders' equity and total net income or loss that is not attributable, directly or indirectly, to the parent; that
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is, to the controlling interest. FAS 160 changes the placement of the noncontrolling interest on the balance sheet and income statement. For savings associations and holding companies with a calendar yearend, the Statement becomes effective in the first quarter of 2009. Accordingly, OTS proposes to make certain changes to Schedules SC, SO, HC, and CCR.

B. Elimination of Existing Items

1. As a result of the issuance of FAS 160 (see Background above), OTS will eliminate line CCR190, Minority Interest in Includable Subsidiaries.

C. Revision of Existing Items

1. As a result of the issuance of FAS 160 (see Background above), OTS will revise the captions of lines SC80 from ``Total Equity Capital'' to ``Total Savings Association Equity Capital'', SC800 from ``Minority Interest'' to ``Noncontrolling Interests in Consolidated Subsidiaries'', SC90 from ``Total Liabilities, Minority Interest, and Equity Capital'' to ``Total Liabilities and Equity Capital'', SO 91 from ``Net Income (Loss)'' to ``Net Income (Loss) Attributable to Savings Association'', HC620 from ``Minority Interest'' to ``Noncontrolling Interests in Consolidated Subsidiaries'', HC640 from ``Consolidated Net Income for the Quarter'' to ``Consolidated Net Income (Loss) Attributable to Holding Company'', CCR100 from ``Total Equity Capital (SC80)'' to ``Total Equity Capital (SC84)'', and CCR105 from ``Minority Interest in Nonincludable Subsidiaries'' to ``Investments in, Advances to, and Noncontrolling Interests in Nonincludable Subsidiaries''.

D. New Items

1. As a result of the issuance of FAS 160 (see Background above), OTS proposes to add lines SC84, Total Equity Capital; SO88, Net Income (Loss) Attributable to Savings Association and Noncontrolling Interests; SO880, Net Income (Loss) Attributable to Noncontrolling Interests; and HC635, Consolidated Net Income (Loss) Attributable to Holding Company and Noncontrolling Interests.

2. To separately capture impairment charges on debt and equity securities, OTS proposes to add line SO441, OtherthanTemporary Impairment Charges on Debt and Equity Securities.
E. Eliminating Confidential Treatment of Schedule FS and Schedule HC Data

OTS has, to this point, provided confidential treatment to some of the information that certain institutions report in Schedule FS Fiduciary and Related Services, on fiduciary and related services income, settlements, surcharges and other losses reported on lines FS310 through FS35, and FS710 through FS70. OTS also accords confidential treatment to all of the information that certain institutions report in Schedule HCThrift Holding Company.

An important public policy issue for the federal banking regulatory agencies has been how to use market discipline to complement supervisory resources. Market discipline relies on market participants having sufficient appropriate information about the financial condition and risks of banks, thrifts, and their holding companies. The TFR is widely used by securities analysts, rating agencies, and large institutional investors as sources of thriftspecific data. Disclosure that increases transparency should lead to more accurate market assessments of individual banks' performance and risks. This, in turn, should result in more effective market discipline on thrifts. For these reasons, we proposed eliminating the confidential treatment of data reported on schedules FS and HC.

1. Eliminating Confidential Treatment of Schedule FS Data

The trade group commenting on the proposed revisions opposed eliminating the confidential treatment of fiduciary income and loss data, stating that the agencies' original reason for according confidential treatment to these data, i.e., that these data generally pertain to only a portion of a reporting institution's total operations and not to the institution as a whole, still holds true. This commenter also cited significant competitive concerns with the proposed elimination of confidential treatment because making income and loss data publicly available ``may make it possible for competitors to deduce'' an individual institution's fee schedules. In addition, this commenter believed that these publicly disclosed data may be subject to misinterpretation by market participants who would lack a proper understanding of the scope of the income and loss data reported in Schedule FS because fiduciary income and loss data are presented differently in institutions' audited financial statements prepared in accordance with GAAP. Therefore, this commenter believes that institutions' financial statements can satisfy market participants' needs for fiduciary income and loss data. Finally, this commenter stated that market participants may be confused or misled by the fiduciary income and loss information because they would be unable to determine the source or specific fiduciary activity giving rise to the income or loss.

Data on fiduciary and related services income and losses is treated as confidential on an individual institution basis. Nevertheless, OTS publishes aggregate data derived from these confidential items. OTS does not preclude institutions from publicly disclosing the fiduciary and related services income and loss data that the agencies treat as confidential.

In addition, under the Uniform Interagency Trust Rating System, the agencies assign a rating to the earnings of an institution's fiduciary activities at those institutions with fiduciary assets of more than $100 million, which are also the institutions that report their fiduciary and related services income and losses in Call Report Schedule RCT and TFR Schedule FS. The agencies' evaluation of an institution's trust earnings considers such factors as the profitability of fiduciary activities in relation to the size and scope of those activities and the institution's overall business, taking this into account by functions and product lines. Although the agencies' ratings for individual institutions are not publicly available, the reason for rating the trust earnings of institutions with more than $100 million in fiduciary assetsits effect on the financial condition of the institutionmeans that fiduciary and related services income and loss information for these institutions is also relevant to market participants and others in the public as they seek to evaluate the financial condition and performance of individual institutions. Increasing the transparency of institutions' fiduciary activities by making individual institutions' fiduciary income and loss data available to the public should improve the market's ability to assess these institutions' performance and risks and thereby enhance market discipline.

Although the fiduciary income and loss data currently reported in Schedule FS and afforded confidential treatment apply only to a portion of an institution rather than an entire institution, all other data collected in Schedule FS of the TFR is publicly available, even when the data relates only to portions of an institution's activities.

OTS continues to believe that the benefit of increased transparency from the full disclosure of fiduciary income and loss data will improve market discipline by enhancing the market's ability to assess institutionspecific performance and risks. After carefully considering the comments on the public availability of fiduciary income and loss data reported in Schedule FS, OTS is
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adopting the proposal to eliminate the confidential treatment of such data beginning with the data reported as of March 31, 2009. 2. Eliminating Confidential Treatment of Schedule HC Data

The trade group commenting on the proposed revisions recommended a bifurcated approach to eliminating the confidential treatment of Schedule HC data filed by holding companies. The commenter felt that eliminating confidential treatment of Schedule HC data is appropriate for publiclyheld thrift holding companies, but should not be eliminated for privatelyheld thrift holding companies. However, many public requests are received for these data. In addition, some rating agencies have indicated thrift holding company debt ratings suffer due to the lack of publicly available data. Additionally, Federal Reserve Board Schedule Y9 filed by bank holding companies is publicly available on consolidated and unconsolidated bases for both publicly and privately owned bank holding companies. It is reasonable that OTS should be consistent with the FRB's treatment of holding company financial information.

Thus, after carefully considering the comments on the public availability of Schedule HC data, OTS is adopting the proposal to eliminate the confidential treatment of such data beginning with the data reported as of March 31, 2009.

IV. TFR Revisions Proposed for June 2009

OTS received no comments related to the following revisions proposed to be effective as of June 2009. Accordingly, these revisions are adopted as proposed.
A. Elimination of Existing Items

1. Schedule SIConsolidated Supplemental Information

SI805, Do you sell privatelabel or thirdparty mutual funds and annuities?; and

SI860, Fee Income from the Sale and Servicing of Mutual Funds and Annuities.

Line SI805 is a yes/no question regarding the sale of private label or third party mutual funds and annuities. Line SI860 reports the amount of fee income from the sale and servicing of mutual funds and annuities. Institutions that provided a yes response to line SI805 will now provide the same response to new line SI910. OTS believes the data reported in line SI860 can be collected independently of the TFR reporting system during the examination process.

B. Revisions of Existing Items

1. Revising the caption for line SO430 from ``Noninterest Income Net Income (Loss) from OtherSale of Assets Held for Sale and AvailableforSale Securities'' to ``Noninterest IncomeNet Income (Loss) from OtherSale of AvailableforSale Securities'' to
separately report gains and losses on the sale of availableforsale securities from gains and losses on loans and leases held for sale and on other assets held for sale. Gains and losses on loans and leases held for sale and on other assets held for sale would be reported in new lines SO431 and SO432 described below; and

2. Revising the language for question HC840 from ``Is the holding company or any of its subsidiaries regulated by a foreign financial services regulator?'' to ``Is the holding company or any of its affiliates conducting operations outside of the U.S. through a foreign branch or subsidiary?'' This line is being revised to more fully identify holding companies with foreign operations, including parallel banking operations. A parallel banking organization exists when at least one U.S. bank and one foreign financial institution are controlled either directly or indirectly by the same person or group of persons who are closely associated in their business dealings or otherwise acting together, but are not subject to consolidated supervision by a single home country supervisor. A foreign financial institution includes a holding company of the foreign bank and any U.S. or foreign affiliates of the foreign bank.
C. New Items

1. Noninterest Income

OTS proposes to add two lines related to gains and losses on the sale of loans and leases held for sale and on other assets held for sale:

SO431, Noninterest IncomeNet Income (Loss) from OtherSale of Loans and Leases Held for Sale; and

SO432, Noninterest IncomeNet Income (Loss) from OtherSale of Other Assets Held for Sale.

These new lines, in conjunction with the revised line SO430 described above, will allow thrifts to separately report gains and losses on the sale of availableforsale securities, on loans and leases held for sale, and on other assets held for sale.

2. Loans in Process of Foreclosure

OTS proposes to add a series of eight lines to Schedule PD related to loans in the process of foreclosure:

PD40, Total Loans in Process of Foreclosure;

PD415, Construction Loans in Process of Foreclosure;

PD421, 14 Dwelling Units Secured by Revolving OpenEnd Loans in Process of Foreclosure;

PD423, 14 Dwelling Units Secured by First Liens in Process of Foreclosure;

PD424, 14 Dwelling Units Secured by Junior Liens in Process of Foreclosure;

PD425, Multifamily (5 or more) Dwelling Units in Process of Foreclosure;

PD435, Nonresidential Property (Except Land) in Process of Foreclosure; and

PD438, Land Loans in Process of Foreclosure.

OTS believes these new line items will provide additional detail on the various types of real estate loans in the process of foreclosure. With these new data items, OTS will be better able to monitor the asset quality and risk profiles of thrifts.

Thrifts would report total unpaid principal balance of loans secured by the various types of real estate for which formal foreclosure proceedings to seize the real estate collateral have started and are ongoing as of quarterend, regardless of the date the foreclosure procedure was initiated. Loans would be classified as in process of foreclosure according to local requirements.

3. Construction Loans With Capitalized Interest

OTS proposes to add a series of six lines to Schedule LD related to construction loans with capitalized interest:

LD710, Construction Loans on 14 Dwelling Units with Capitalized Interest;

LD715, Capitalized Interest on Construction Loans on 14 Dwelling Units Included in Current Quarter Income;

LD720, Construction Loans on Multifamily (5 or More) Dwelling Units with Capitalized Interest;

LD725, Capitalized Interest on Construction Loans on Multifamily (5 or More) Dwelling Units Included in Current Quarter Income;

LD730, Construction Loans on Nonresidential Property (Except Land) with Capitalized Interest; and

LD735, Capitalized Interest on Construction Loans on Nonresidential Property (Except Land) Included in Current Quarter Income.

OTS believes these new line items will provide additional detail on the use of capitalized interest in connection with various types of construction
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loans. With these new data items, OTS will be better able to monitor the risk profiles of thrifts with concentrations of construction loans. 4. Collateralized Debt Obligations, Collateralized Loan Obligations, and Commercial MortgageBacked Securities (CMBSs)

OTS proposes to add a series of six lines to Schedule LD to provide additional reporting detail on collateralized debt obligations (CDOs), collateralized loan obligations (CLOs), and commercial mortgagebacked securities (CMBSs):

LD750, Collateralized Debt Obligations: Carrying Value;

LD755, Collateralized Debt Obligations: Market Value;

LD760, Collateralized Loan Obligations: Carrying Value;

LD765, Collateralized Loan Obligations: Market Value;

LD770, Commercial MortgageBacked Securities: Carrying Value; and

LD775, Commercial MortgageBacked Securities: Market Value.

CDOs are a type of assetbacked security and structured credit product. CDOs are constructed from a portfolio of fixedincome assets that are pooled together and passed on to different classes of owners.

CLOs are a type of assetbacked security and structured credit product. CLOs are structured from a portfolio of nonmortgage business loans that are pooled together and passed on to different classes of owners.

CMBSs are a type of assetbacked security and structured credit product. CMBSs are structured from a portfolio of commercial mortgage loans that are pooled together and passed on to different classes of owners.

5. Recourse Obligations on Loans in Line CC468

OTS proposes to add two lines to Schedule CC related to recourse obligations on loans in CC468, Amount of Recourse Obligations on Assets in CC455 (Line CC455 is the Total Principal Amount of Assets Covered by Recourse Obligations or Direct Credit Substitutes):

CC469, Amount of Recourse Obligations on Loans in CC468 where Recourse Is Limited to 120 Days or Less; and

CC471, Amount of Recourse Obligations on Loans in CC468 where Recourse Extends Beyond 120 Days.

OTS believes these new line items will provide additional detail on the amount of assets with recourse obligations held by thrifts. 6. Loans Sold With Recourse

OTS proposes to add two lines to Schedule CF related to loans sold during the current reporting period with recourse obligations:

CF365, MemoLoans Sold with Recourse of 120 Days or Less; and

CF366, MemoLoans Sold with Recourse Greater Than 120 Days.

OTS believes these new line items will provide additional detail on the quarterly amount of loans sold with recourse obligations held by thrifts.

7. Additions for Deposit AssessmentRelated Purposes

At the request of the Federal Deposit Insurance Corporation for deposit assessmentrelated purposes, the OTS proposes to add the following seven lines to Schedule DI:

DI630, Unsecured Federal Funds Purchased;

DI635, Secured Federal Funds Purchased;

DI641, Securities Sold Under Agreements to Repurchase;

DI645, Unsecured ``Other Borrowings''With a Remaining Maturity of One Year or Less;

DI651, Unsecured ``Other Borrowings''With a Remaining Maturity of Over One Year;

DI655, Subordinated DebenturesWith a Remaining Maturity of One Year or Less; and

DI660, Subordinated DebenturesWith a Remaining Maturity of Over One Year.

The additional reporting detail by maturity is proposed as the FDIC plans to provide a reduction in assessment rates to institutions with longerterm unsecured borrowings and subordinated debt. The FDIC believes that such borrowing and debt will likely remain when an institution fails, thus providing a cushion to help protect the Deposit Insurance Fund.

The trade group commenting on the proposed revisions expressed support for the reporting of maturity distributions of unsecured other borrowings and subordinated debt on Schedule DI, stating that the data would enable the FDIC to implement an adjustment to the riskbased assessment system so that insured depository institutions with greater amounts of general unsecured longterm liabilities could be rewarded with a lower assessment rate.

8. Pledged Loans and Securities

OTS proposes to add two lines to Schedule SI related to loans and securities pledged as collateral for loans:

SI394, Pledged Loans; and

SI395, Pledged Trading Assets.

OTS believes these new line items will provide additional detail on the amount of loans and securities pledged by thrifts as collateral for loans. These data items will permit OTS to better monitor the risk profiles of thrifts with concentrations of pledged loans and securities and are consistent with reporting being added to the Call Report in 2009.

9. Questions Relating to Thrift Activities

OTS proposes to add the following four new questions to Schedule

FOR FURTHER INFORMATION CONTACT

For further information or to obtain a copy of the submission to OMB, please contact Ira L. Mills, OTS Clearance Officer, at ira.mills@ots.treas.gov, (202) 9066531, or facsimile number (202) 9066518, Litigation Division, Chief Counsel's Office, Office of Thrift Supervision, 1700 G Street, NW., Washington, DC 20552.

You can obtain a copy of the 2009 Thrift Financial Report forms from the OTS Web site at http://www.ots.treas.gov/ ?p=ReportFormsBulletins or you may request it by electronic mail from tfr.instructions@ots.treas.gov. You can request additional information about this proposed information collection from James Caton, Director, Financial Monitoring and Analysis Division, (202) 9065680, Office of Thrift Supervision, 1700 G Street, NW., Washington, DC 20552.

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