The Clearing House Association submitted a comment letter to the Board of Governors (the Board) and OMB recommending that the Board delay changes relating to troubled debt restructurings (TDRs) until after the Financial Accounting Standards Board has finalized its accounting for TDRs under U.S. GAAP; the effective date of the proposed new Schedule HC-V, Variable Interest Entities be delayed until the September 30, 2011 FR Y-9C Report; the maturity and repricing data for assets and liabilities at contractual ceilings and floors instructions should remain unchanged; urging the Board to combine the FR Y-11 and FR 2314 into a single report; and requesting the opportunity to discuss with the Board a comprehensive review of the FR Y-9C Report.