The Clearing House Association submitted a comment letter to the FRB in response to their proposed revisions to the FR Y-10 and FR Y-6 Reports. TCH recommends that (i) changes to Item 1.a. (Event Types) on the 4(k) Schedule to the FR Y-10 be limited to reporting that large merchant banking investment entities either (a) are no longer reportable or (b) have changed their name; (ii) entities holding debts previously contracted should be excluded from being reported on the FR Y-10; and (iii) that the requirement to report the state and country of incorporation on the FR Y-6 should be limited (a) to entities that are reportable on the FR Y-10 and (b) only required on a prospective basis. If the Board decides to require the reporting of the state and country of incorporation on a retrospective basis on the FR Y-6, The Clearing House recommends that the Board delay implementation until the December 31, 2012 FR Y-6 Reports to allow BHCs sufficient time to collect the information for all existing entities. On November 21 the FRB issued a final approval of the revisions to the FR Y-10 and FR Y-6 Reports that includes these changes specifically requested by The Clearing House: (i) addition to event types of the 4(k) Schedule selections for ‘‘No Longer Reportable’’ and ‘‘Name Changes’’ and removal of the selection for ‘‘Changes to Initial Investment” and (ii) the implementation of the requirement to add the state and country of incorporation to the FR Y-6 would be delayed until fiscal years beginning December 31, 2012.