The Clearing House Association submitted a comment letter to regulatory agencies regarding the proposed revisions to the Call Report and the Thrift Financial Report. These revisions include several changes to implement the FDIC rule that redefines the deposit insurance assessment base and the large bank pricing rule. TCH letter addresses serious concerns about some key definitions that underlie the proposed Call Report and TFR changes and recommends a consensus solution that significantly improves the definitions of subprime and leveraged loans. TCH also strongly recommends that the current transition reporting rules be continued until the large bank pricing rule is revised to reflect the new definitions. On September 28, the FDIC advised that the leveraged loans and subprime transition guidance has been extended until April 1, 2012 for the Call Report to allow the FDIC sufficient time to review the definitions of subprime and leveraged loans. In the interim, the FDIC will allow large institutions to continue to use their existing methodologies to report subprime and leveraged loans originated or purchased prior to April 1, 2012. On March 20, 2012 the FDIC approved a proposal with new definitions for leveraged loans, renamed “higher risk C&I loans and securities,” and subprime consumer loans, renamed “higher-risk consumer loans and securities,” which would amend the February 25, 2011 final rule on bank assessment regulations for large bank pricing. The FDIC included in the proposed amendments the following recommendations from TCH’s September 26 joint trade comment letter: (i) subprime consumer loans should be stratified by the probability of default at origination for borrowers, as determined by a credit scoring system either developed internally or by a recognized third party vendor, and (ii) the de minimis leveraged loan threshold should be raised to $5 million and factors for the original purpose should be added to the definition of leveraged loans. The proposed amendments would become effective October 1, 2012.