Board of Governors of the Federal Reserve System

Data Dictionary

Item Number 9057

Call confidentiality applies to FFIEC 031/041.

Data Description:

An indicator of whether a U.S. domiciled bank holding company is a complex or a noncomplex organization. For small bank holding companies with total consolidated assets of $5 billion or less, attributes rows with dt_start on or after 20020101 must use values 3 - 8 for complex institutions. A value of 2 should be used for any size company to indicate noncomplex institutions, unless there are factors that indicate complexity and that have been overridden by supervisory judgment, in which case a value of 9 should be used.

0 = Not applicable (not a BHC)

1 = Complex institutions with material credit-extending activities either of the parent bank holding company or its nonbank subsidiaries or debt outstanding to the general public. Note: In the case of small bank holding companies with total consolidated assets of $5 billion or less, this definition of complex is only valid for attributes rows with dt_start prior to 20011231. Select from values 3 - 8 for rows with dt_start on or after 20020101.

2 = Noncomplex. Effective 1/1/2002, SR 02-01 defines factors to be considered in determining complexity for small bank holding companies. Note: For historic rows for the risk-focused supervision program through 12/31/2001, small bank holding companies are defined as those companies with less than $1 billion in consolidated assets that do not have debt outstanding to the public, and that do not engage in significant nonbank activities. A nonbank activity could be considered significant based on the scope or type of activity. For example, credit extending activities as well as investment and trading activities where the holding company acts as a principal would generally be considered significant. The provision of services on a fee basis such as the provision of data processing services to affiliated and/or unaffiliated banks or the sale of instruments on an agency basis may also, in certain instances, be considered significant, depending on the scale of the activity or other factors that may pose direct or indirect risk to the holding company or any insured depository institution subsidiary.

3 = Complex: Nonbank Financial Factors. Nature and scale of nonbank activities warrant designation as complex for supervisory purposes.

4 = Complex: High Risk Activities. Company engages, either directly or through its subsidiaries, in significant non-banking activity having an inherently high risk profile. Examples include securities broker/dealer activities, insurance underwriting, and merchant banking; other activities may also trigger this designation if identified by the supervisory Reserve Bank as high-risk in nature.

5 = Complex: Public Debt. Company issues significant debt to the general public such that unsophisticated investors may be at risk of loss.

6 = Complex: Management Factors. Management practices such as the nature of inter-company transactions or centralized risk management policies and procedures warrant designation as complex for supervisory purposes.

7 = Complex: Multiple Factors. Company meets two or more criteria for the complex designation, more than one of which are material in the judgment of the supervisory Reserve Bank. While the intensity of the supervisory approach may not differ from other complex companies, this designation alerts examiners to the presence of more than one factor.

8 = Complex: Supervisory Judgment. Company does not appear to be complex as described in SR 02-01, however, at the discretion of the supervisory Reserve Bank, it is designated a complex organization for supervisory purposes.

9 = Noncomplex: Supervisory Judgment. Company appears to be complex as described in SR 02-01, however, at the discretion of the supervisory Reserve Bank, it is designated a noncomplex organization for supervisory purposes.