Supporting Statement for the

Senior Financial Officer Surveys

(FR 2023; OMB No. 7100-0223)

Summary

The Board of Governors of the Federal Reserve System (Board), under delegated 

authority from the Office of Management and Budget (OMB), proposes to extend for three years, 

without revision, the Senior Financial Officer Surveys (FR 2023; OMB No. 7100-0223).1

 The 

Board uses the surveys in this collection for monetary policy purposes: to gather qualitative and 

limited quantitative information about liability management, the provision of financial services, 

and the functioning of key financial markets from a selection of up to 80 large commercial banks 

(or, if appropriate, from other depository institutions or major financial market participants). A 

senior officer at each respondent bank would complete this voluntary survey usually through an 

electronic submission. Although a survey may not be collected in a given year, the Board may

conduct up to four surveys per year when significant informational needs arise and cannot be met 

from existing data sources.

The current annual burden for the FR 2023 is estimated to be 960 hours, based on four 

surveys per year. These surveys do not have a fixed set of questions; each survey would consist 

of a limited number of questions directed at topics of timely interest. Accordingly, a sample 

form is not included with this proposal.

Background and Justification

The Board uses Senior Financial Officer Surveys to obtain information about deposit 

pricing and behavior, bank liability management, the provision of financial services, and reserve 

management practices. Surveys conducted under the FR 2023 help pinpoint developing trends in 

bank funding practices, enabling the Board to distinguish these trends from transitory 

phenomena. The FR 2023 also complements other deposit reports that, by themselves, provide 

limited insight into the causes of the changing behavior of deposit holders and depository 

institutions. Moreover, the FR 2023 has given the Board the opportunity to follow periodic 

developments in financial markets related to extraordinary events that are beyond the scope of 

other reports. Before initiating a new survey, the Board would determine if the information to be

collected is available by other means or sources within the Federal Reserve System to avoid 

duplication.

 

1 Certain criteria apply to information collections conducted via the Board’s ad hoc clearance process. Such 

information collections shall (1) be vetted by the Board’s clearance officer as well as the Division director 

responsible for the information collection, (2) display the OMB control number and respondents shall be informed 

that the information collection has been approved, (3) be used only in such cases where response is voluntary, (4) 

not be used to substantially inform regulatory actions or policy decisions, (5) be conducted only and exactly as 

described in the OMB submission, (6) involve only noncontroversial subject matter that will not raise concerns for 

other Federal agencies, (7) include information collection instruments that are each conducted only one time, (8) 

include a detailed justification of the effective and efficient statistical survey methodology (if applicable), and (9) 

collect personally identifiable information (PII) only to the extent necessary (if collecting PII, the form must display 

current privacy act notice). In addition, for each information collection instrument, respondent burden will be 

tracked and submitted to OMB.
2

In February 1994, the Board used the FR 2023 to conduct a survey requesting

information about the availability and profitability of providing brokerage services to retail 

customers and the provision of non-brokerage services to mutual funds. This survey found 

evidence that large banks were continuing to expand their retail brokerage programs and helped 

quantify the importance of these activities for bank profitability. The Board used the FR 2023 

again in December 1994, focusing on bank funding practices. Results from this survey helped 

identify factors that explained banks’ increased reliance on managed liabilities to fund domestic 

credit. In May 1996, the Board used the FR 2023 to investigate bank reserve management 

practices in order to increase understanding of how banks might operate with low required 

reserve balances. Information from this survey assisted in the smooth implementation of 

monetary policy as sweep accounts drove down the level of required operating balances.

The Board conducted a survey in May 1998 under the FR 2023 that was designed to 

gauge the effect on banks’ reserve management of the imposition of a charge on banks that 

overdraw their accounts at the Federal Reserve during the course of the day (the so-called 

daylight overdraft fee) and the expansion of the operating hours of the Fedwire system. The 

survey documented the tendency of banks to concentrate delivery of federal funds later in the 

day, potentially in response to changes in the Federal Reserve’s intraday credit policy. This 

survey also confirmed previous anecdotal evidence that banks used the extension of Fedwire 

operating hours to transfer funds linked not only to international transactions, which was 

expected, but also to domestic transactions.

In August 2006, the Board used the FR 2023 to assess the use of retail sweep programs. 

The results were not published. Respondents almost uniformly indicated that their banks would 

not eliminate retail sweep programs or change vault cash management strategies in response to 

payment of interest on reserves. In the 1996 and 1998 surveys, respondents had indicated more 

willingness to alter their behavior.

As illustrated by these examples, information collected through the FR 2023 has assisted 

the Board in its assessment of bank behavior and financial market conditions by improving 

knowledge of institutional arrangements and by permitting prompt inquiries in response to 

unusual circumstances. Information collected through these surveys has also been used by the 

Federal Open Market Committee and has contributed to the formulation of monetary policy.

In 2012, the minimum asset size for panel institutions was reduced from $3 billion to 

$2 billion and 20 domestically chartered commercial banks with $2 to $10 billion in total assets 

were added to the authorized panel. The expanded panel provides a more comprehensive picture 

of differences in funding conditions at the largest banks and regional banks, and deeper coverage 

of banks that lend in commercial real estate and small business markets.

Description of Information Collection

Both the frequency and the content of the Senior Financial Officer Surveys have been, 

and will continue to be, determined by exigencies. The surveys do not have a fixed set of 

questions; each survey consists of a limited number of both qualitative and quantitative questions 
3

directed at topics of timely interest. To the extent possible, the Federal Reserve notifies 

respondents in advance as to the topic(s) to be covered in an impending survey. In extraordinary 

circumstances, when such notice is not possible, the decision to waive this advance notice 

provision would be made only by Federal Reserve officials. The survey is generally completed 

through electronic submission by a senior financial officer at each respondent bank. If they 

prefer, banks also have the option of responding through a telephone interview conducted either 

by a Reserve Bank officer or senior-level Federal Reserve Board staff member who has expertise 

in the area of bank liability management, or by a Board staff member, as appropriate. The 

surveys are voluntary.

Reporting Panel

The primary panel of respondents is identical to the U.S. commercial bank subset of 

respondents for the Senior Loan Officer Opinion Survey (FR 2018; OMB No. 7100-0058) and

currently comprises 80 large, domestically chartered commercial banks.2

 To ensure adequate 

geographic coverage, the survey panel spans all Federal Reserve Districts. As of March 31, 

2017, the assets of the panel banks totaled $11.8 trillion and accounted for about 69 percent of 

the $17.0 trillion in total assets at domestically chartered institutions. The overlap between the 

reporting panels of the FR 2018 and FR 2023 surveys aids the Board in interpreting the data 

received.

The primary panel of large domestically chartered commercial banks would be 

appropriate for most survey topics. In some situations, however, panels based on alternative 

criteria may be more appropriate or may provide useful additional information. Consequently, 

the Board may survey other types of respondents (such as other depository institutions, bank 

holding companies, or other financial entities) in addition to the primary panel. For example, it 

may be useful to survey foreign banking organizations to gain better insight into the demand for 

reserves at these institutions, or institutional loan investors to gain a better understanding of the 

syndicated loan market. This option enhances the potential scope and utility of the survey and is 

consistent with the uses of the FR 2018. The surveys of optional panels would be conducted 

either by the Reserve Banks or the Board, as appropriate.

Time Schedule for Information Collection and Publication

The survey may be conducted up to four times per year. In 1994, two surveys were 

conducted that assisted the Federal Reserve in its assessment of bank behavior and financial 

market conditions. Since then, only three surveys have been conducted, as there were no 

circumstances requiring more frequent surveys. However, such circumstances could arise in the 

 

2

 The Board tries to maintain the full authorized panel of 80 insured, domestically chartered commercial banks on 

the FR 2018. The panel is heavily weighted towards large complex banking organizations, but also includes a fair 

number of large and medium-sized regional banks, which allows for a greater diversity of responses and provides a 

broader view of the banking system. In addition, the FR 2018 reporting panel also has a subset composed of large 

U.S. branches and agencies of foreign banks. These institutions are not included in the primary FR 2023 panel 

because most of their funding operations are in the wholesale, not retail, market or in their home countries. 

However, should the need arise, U.S. branches and agencies could be surveyed as an optional panel.
4

future and the Board believes that the authority to conduct up to four surveys a year is essential 

for the Federal Reserve to maintain the ability to keep abreast of important market developments.

Survey responses are tabulated and summarized at the Board. Summary data are 

forwarded to Reserve Banks for distribution to respondents and also are available to other 

members of the public.

Legal Status

The FR 2023 is a voluntary survey. Section 2A of the Federal Reserve Act (FRA) 

requires that the Board and the Federal Open Market Committee (FOMC) maintain long-run 

growth of the monetary and credit aggregates commensurate with the economy’s long run 

potential to increase production, so as to promote effectively the goals of maximum employment, 

stable prices, and moderate long-term interest rates (12 U.S.C. 225a). In addition, under section 

12A of the FRA, the FOMC is required to implement regulations relating to the open market 

operations conducted by Federal Reserve Banks. Those transactions must be governed with a 

view to accommodating commerce and business and with regard to their bearing upon the 

general credit situation of the country (12 U.S.C. 263). The Board and the FOMC use the 

information obtained from th Senior Financial Officer Surveys (FR 2023e FR 2023 to help fulfill 

these obligations. 

The questions asked on each survey will vary, so the ability of the Board to maintain the 

confidentiality of information collected must be determined on a case by case basis. It is likely 

that much of the information collected would constitute confidential financial information 

obtained from a person and would thus be protected from disclosure under exemption 4 to the 

Freedom of Information Act (FOIA) (5 U.S.C. 552(b)(4)). Exemption 8 to FOIA, which protects 

information related to examination, operating, or condition reports prepared for the use of an 

agency supervising financial institutions, may also occasionally apply (5 U.S.C. 552(b)(8)).

Consultation Outside the Agency

On May 15, 2018, the Board published a notice in the Federal Register (83 FR 22490) 

requesting public comment for 60 days on the extension for three years, without revision, of the 

Senior Financial Officer Surveys (FR 2023). The comment period for this notice expires on July 

16, 2018.

Estimate of Respondent Burden

As shown below, the total annual burden for the FR 2023 is estimated to be 960 hours,

based on four surveys per year.3 The reporting requirements represent less than 1 percent of 

total Federal Reserve System annual paperwork burden.

 

3

 Actual burden underlying the average per hour response time varies considerably, not only from survey to survey, 

depending on the number and nature of the questions, but also among respondents for any one survey.
5

Number of

respondents4

Annual

frequency

Estimated

average hours

per response

Estimated

annual burden

hours

FR 2023 80 4 3 960

The total cost to the public is estimated to be $53,808.

5

Sensitive Questions

This information collection contains no questions of a sensitive nature, as defined by 

OMB guidelines.

Estimate of Cost to the Federal Reserve System

While the FR 2023 has not been conducted in some time, it is expected to be collected in

a manner very similar to the FR 2018, with a substantially overlapping respondent 

panel. Therefore we estimate the cost to the Federal Reserve System for collecting and 

processing to be the same as for the FR 2018, $132,600 per year. 

 

4

 Of these respondents required to comply with this information collection, none are considered small entities as 

defined by the Small Business Administration (i.e., entities with less than $550 million in total assets),

www.sba.gov/contracting/getting-started-contractor/make-sure-you-meet-sba-size-standards/table-small-businesssize-standards 5

 Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual 

burden hours, multiplied by hourly rates (30% Office & Administrative Support at $18, 45% Financial Managers at 

$69, 15% Lawyers at $68, and 10% Chief Executives at $94). Hourly rates for each occupational group are the 

(rounded) mean hourly wages from the Bureau of Labor and Statistics (BLS), Occupational Employment and Wages 

May 2017, published March 30, 2018, www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined using 

the BLS Occupational Classification System, www.bls.gov/soc/.