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FEDERAL RESERVE BANK
OF NEW YORK
fit

2^

January 9, 1984

PROPOSED CHANGES IN COUNTRY EXPOSURE REPORT

To All State Member Banks, and Others Concerned,
in the Second Federal Reserve District:

The following statement has been issued by the Federal Financial Institutions Examination
Council:
The Examination Council has announced that it is seeking public comment on proposed new report­
ing requirements to implement the provisions of the International Lending Supervision Act of 1983. The
Act requires public disclosure of material foreign country exposures by commercial banks. A proposed
new “Country Exposure Information Report” would be prepared on a “net” basis, i.e ., after adjust­
ments for reallocation of transfer risk. The report would be filed quarterly as a supplement to the Country
Exposure Report.
The Council also is seeking comment on a proposed new memorandum item in the Country Expo­
sure Report that would reflect amounts of exposure that are covered by guarantees from the U.S. Gov­
ernment and its agencies. The current memorandum item showing foreign office non-local currency
claims would be deleted.

*

*

*

Printed on the reverse side is an excerpt from the F e d e r a l R e g i s t e r of December 23, 1983,
containing the text of the Council’s notice. Comments on the Council’s proposals should be
submitted by January 23, 1984 and may be sent to Thomas P. McQueeney, Assistant Chief
Examiner in our Bank Examinations Department.




A n t h o n y M. S o l o m o n ,
P r e s id e n t.

(OVER)

F E D E R A L FIN A N C IA L IN STITU TIONS
EXAM IM ATIQM CO U N CIL
Quarterly Report of Country Exposure
by U.S. Banking Organizations
A G E N C Y : Federal Financial Institutions
Examination Council (FFIEC).
a c t i o n : Notice of request for comments
on reporting requirements.

SUMMARY: The FFIEC proposes to revise
the Country Exposure Report effective
March 31,1984 in order to implement
certain public disclosure provisions of
the International Lending Supervision
Act of 1983. A new two-part summary
report, the Country Exposure
Information Report, is being proposed.
This new report would be filed as an
attachment to the present Country
Exposure Report, and the information in
the new report would be disclosed to the
public upon request. In addition, the
FFIEC proposes to replace the current
memorandum item in the Country
Exposure Report with a memorandum
item that would show for each country
the amounts of exposure that are
covered by guarantees from the U.S.
Government and its agencies.
d a t e : Comments must be received on or
before January 23,1984.

A D D R E S S : Comments may be mailed to
Robert J. Lawrence, Executive Secretary,
Federal Financial Institutions
Examination Council, 490 L’Enfant
Plaza, SW, Eighth Floor, Washington,
DC 20219.
F O R F U R T H E R IN F O R M A T IO N C O N T A C T :

Robert R. Bench, Office of the
Comptroller of the Currency,
Washington, DC 20219, [202] 447-1699;
Frederick R. Dahl, Federal Reserve
Board, Washington, DC. 20551, (202)
452-2726; Edward T. Lutz, Federal
Deposit Insurance Corporation,
Washington, DC 20429, (202) 389-4512.
S U P P L E M E N T A R Y IN F O R M A T IO N : The
FFIEC, pursuant to section 1006 of the
Federal Financial Institutions

Examination Council Act of 1978 (12
U.S.C. 3305), proposes to revise the
Country Exposure Report, form FFIEC009, effective March 31,1984. The report
is authorized by section 11a of the
Federal Reserve Act (12 U.S.C. 248a),
section 5(c) of the Bank Holding
Company Act of 1956 (12 U.S.C. 1844c),
the National Bank Act as amended (12
U.S.C. section 1 et seq.: 12 U.S.C. 161),
section 7 and 10 of the Federal Deposit
Insurance Act (12 U.S.C. 1817 and 1820),
and section 907 of the International
Lending Supervision Act of 1983.
The FFIEC is proposing two changes
in the reporting requirement. First, a
new two-part summary report, the
Country Exposure Information Report
(see below), is being proposed. Part A of
this report would provide certain
information on foreign country
exposures to any country that exceeds 1
percent of the reporting bank’s assets.
Part B would provide less detailed
information on such exposures that
exceed 0.75 percent, but do not exceed 1
percent, of the reporting bank’s assets.
This information w’ould be disclosed to
the public on request and is similar to
new disclosure requirements recently
adopted by the Securities and Exchange
Commission. The new information
report would be filed as an attachment
to the present Country Exposure Report.
The second proposed change relates
to the memorandum item in FFIEC-009.
The present memorandum item shows
foreign office non-local currency claims
and has been collected to allow
adjustments to the data for international
statistical purposes. That information
will no longer be needed after December
and deletion of the item is proposed.
Another memorandum item is proposed
as a replacement. The new
memorandum item would show for each
country the amounts of exposure that
are covered by guarantees from the U.S.
Government and its agencies. This
information has not been readily
available, which has hampered analysis
of problem debt situations.
The International Lending Supervision

Act of 1983 states that the Federal
banking agencies shall require banking
institutions to submit at least four times
a year information on their foreign
country exposures. It further states that
the Federal banking agencies shall
require banking institutions to disclose
to the public material foreign country
exposures. The agencies are required to
implement these provisions within 120
days after enactment of the legislation.
.The FFIEC has already approved
changes in the instructions to the
Country Exposure Report to require that
the report be submitted quarterly,
instead of semi-annually, beginning in
March 1984. To improve the timeliness
of the information, the FFIEC has also
approved a reduction in the filing time
from 60 days after the reporting date to
45 days. These changes have not yet
been approved by the Office of
Management and Budget.
A new, two-part summary report, the
Country Exposure Information Report
(see below), is being proposed as a
means of meeting the second statutory
requirement cited. The standard of
materiality chosen for reporting foreign
country exposures for public disclosure
purposes is 1 percent of total assets.
This corresponds to the standard
recently adopted by the Securities and
Exchange Commission for its disclosure
requirements on international lending.
Comments are invited on the choice of
this standard.
The proposed report requests that
aggregate data, and information on its
sectoral and maturity distribution, be
supplied on a net basis—that is, after
adjustments for reallocation of transfer
risk. Detailed information has not
previously been reported on this basis,
but the Council believes that such data
would provide the most meaningful
measure of exposure. Comments are
especially invited on this aspect of the
proposed report.
Dated: D ecem b er 20,1983.

Robert J. Lawrence,

Executive Secretary, FFIEC.

Country Exposure Information Report
Part A. Information on exposures (after adjustments for guarantees) to any country that exceed 1 percent of total assets.
Adjusted cross-border and foreign office non-local currency dams
Amount of net local
currency claims
included in column (1)

(D

Country

Claims outstanding
after mandated
adjustments for transfer
of exposure

(2)

Amount maturing
in

Total
Column 1 minus 2
(3)

To banks

To public sector entities

To other

Less
than 1
year

More
than 1
year

(4)

(5)

(6)

(7)

(8)

Part B. Information on exposures (after adjustments for guarantees) to any country that exceed 0.75 percent, but do not
exceed 1 percent, of total assets.
List of countries where exposure is
within these R its
m

[FR Doc. 83-34154 Filed 12-22-83; 8:45 am]
BILUW CODS 6210-01-M
G




Total amount of exposure to all countries listed