What’s Reported on Schedule G-1?

What’s Reported on Schedule G-1?

1. Overview

Schedule G-1 is one of the most important components of the Federal Reserve's FR 2590 reporting form. It plays a central role in enforcing the Single-Counterparty Credit Limits (SCCL) rule by requiring covered banking organizations to report detailed information about their credit exposures to their largest counterparties.

The goal of the SCCL rule is to reduce systemic risk by limiting how much credit exposure a large bank can have to any single counterparty. Schedule G-1 helps the Federal Reserve monitor whether institutions are staying within those limits.

This schedule focuses on general gross credit exposures to the top 50 counterparties, broken down into specific categories. While it may seem straightforward, preparing this schedule accurately requires attention to detail, reliable data, and a solid understanding of what the regulators expect.

2. Regulatory Requirement

Under 12 CFR Part 252, Subpart H, covered companies must monitor and limit their credit exposures to individual counterparties in relation to their Tier 1 capital. The SCCL rule sets exposure limits to prevent concentration risk that could threaten financial stability.

Schedule G-1 is designed to collect data that supports the calculation of aggregate net credit exposure—the key metric used to determine whether a bank is in compliance. The exposures reported on G-1 feed directly into this calculation, making accuracy critical.

For each counterparty, exposures are split into seven required categories:

  • Deposits: Funds placed with the counterparty, including those in bank accounts and other deposit arrangements.
  • Loans and Leases: Credit exposures from loans, leases, or other direct lending activities.
  • Debt Securities or Investments: Holdings of bonds or other debt instruments issued by the counterparty.
  • Equity Securities or Investments: Holdings of common or preferred stock, or other equity instruments.
  • Committed Credit Lines: Undrawn amounts of credit lines or facilities that the bank has committed to provide.
  • Guarantees and Letters of Credit: Contingent liabilities such as financial guarantees or standby letters of credit that could become exposures.
  • Securitization Arising from Look-Through Approach: Exposures to underlying issuers within investment funds or special purpose vehicles (SPVs), if those exposures meet certain thresholds.

The last category—look-through securitization exposures—can be especially complex. If a bank holds its gross credit exposure to any underlying issuer of assets in an SPV, due to an SPV exposure, is at least 0.25% of Tier 1 capital, it must separately attribute that exposure to the issuer. If the issuer is not identifiable, the exposure must be assigned to an "unknown entity."

Regulatory Reference: 12 CFR § 252.75 – Treatment of SPV Exposures under SCCL

§ 252.75 – Investments in and exposures to securitization vehicles, investment funds, and other special purpose vehicles that are not subsidiaries of the covered company

(a) In general:

(1) For purposes of this section, the following definitions apply:

  • SPV means a securitization vehicle, investment fund, or other special purpose vehicle that is not a subsidiary of the covered company.
  • SPV exposure means an investment in the debt or equity of an SPV, or a credit derivative or equity derivative between the covered company and a third party where the covered company is the protection provider and the reference asset is an obligation or equity security of, or equity investment in, an SPV.

(2) A covered company must determine whether the amount of its gross credit exposure to an issuer of assets in an SPV, due to an SPV exposure, is equal to or greater than 0.25 percent of the covered company's tier 1 capital using one of the following two methods:

  • (A) The sum of all of the issuer’s assets (with each asset valued in accordance with § 252.73(a)) in the SPV; or
  • (B) The application of the look-through approach described in paragraph (b) of this section.

[Emphasis added]

Source: 12 CFR § 252.75 – Code of Federal Regulations (eCFR)

3. Common Challenges

Despite the clear reporting structure, many institutions face significant challenges in preparing Schedule G-1. These include:

  • Data Sourcing Complexity: Exposure data often comes from multiple systems—loan management, treasury, investment platforms, and others. Aggregating this information into a single, reliable dataset can be difficult.
  • Data Consistency: Ensuring that reported exposures align with internal records and other regulatory filings is a constant concern. Inconsistencies can trigger questions from regulators.
  • Classification Accuracy: Misclassifying an exposure into the wrong category can lead to errors in the net credit exposure calculation. Staff must understand both internal asset structures and regulatory definitions.
  • Timeliness: The FR 2590 report is due 40 to 45 calendar days after quarter-end. Institutions must compile, validate, and submit a large volume of data in a short window.

All of these factors make Schedule G-1 one of the more demanding parts of SCCL compliance.

4. Peer Approaches

To address these challenges, many firms have adopted best practices that improve accuracy, efficiency, and repeatability:

  • Integrated Data Warehousing: Centralizing exposure data into a unified data warehouse helps streamline reporting and reduces manual reconciliation.
  • Specialized Regulatory Reporting Tools: Many institutions use software specifically designed to handle regulatory reporting, including SCCL requirements. These tools often include validation rules and audit trails to assist with compliance.
  • Cross-Functional Collaboration: Finance, risk, IT, and compliance teams work together to ensure that data is complete and accurate. Regular communication between functions is essential.
  • Periodic Reconciliations: Regularly comparing internal credit risk systems with regulatory outputs helps identify and resolve discrepancies before submission.

Firms that invest in these capabilities are generally better equipped to handle the complexity of Schedule G-1 and the broader SCCL rule.

5. GLOBAL ABAS View

At GLOBAL ABAS, we see Schedule G-1 reporting as more than a compliance checkbox. When done properly, it is a powerful tool for improving a firm's overall approach to credit risk management.

We advise our clients to focus on three core areas:

  • Robust Data Governance: Strong data controls, ownership, and validation processes ensure that the exposures reported on G-1 are accurate and reliable.
  • Automation: Automating the data pipeline reduces the risk of manual errors and accelerates reporting cycles. It also frees up staff to focus on exception handling and analysis.
  • Continuous Training: Staff who understand the regulations and how to apply them are better able to classify exposures correctly and respond to regulatory changes.

We also stress the importance of treating Schedule G-1 as a strategic asset. The insights gained from organizing and analyzing credit exposures at this level of detail can inform better decision-making across the enterprise.

6. Final Thoughts

Schedule G-1 of the FR 2590 report plays a critical role in monitoring compliance with the SCCL rule. It requires covered companies to report detailed gross credit exposures across a variety of asset types and counterparties. While preparing this schedule can be complex, it is also an opportunity to strengthen internal risk management practices.

Institutions that invest in high-quality data, effective systems, and knowledgeable staff are better positioned to meet regulatory expectations and manage their credit risk proactively.

To learn more about how GLOBAL ABAS can support your SCCL compliance program, visit our website or subscribe for future updates.

Disclaimer: This blog post is for informational purposes only and reflects our understanding of the SCCL rule and FR 2590 reporting as of the date of publication. It does not constitute legal, regulatory, or professional advice. Institutions should consult with internal and external advisors and refer directly to the SCCL rule (12 CFR Part 252, Subpart H) and FR 2590 instructions for specific guidance. GLOBAL ABAS disclaims any liability for actions taken or not taken based on this information.

Consult a GLOBAL ABAS Consulting, LLC professional regarding your specific issues and questions. Your feedback will help us improve the SCCL Compliance Lab. Please let us know what you think in the Comment below. Copyright © 2025 GLOBAL ABAS Consulting, LLC. All rights reserved.

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