TCH Comments on Proposed Capital Assessments and Stress Testing Report
The Clearing House Association submitted a comment letter in response to the FRB’s proposed information collection of the bank holding companies annual (the “FR Y-14A”) and quarterly (the “FR Y-14Q”) Capital Assessments and Stress Testing reports. The letter addresses substantive concerns with the schedules and worksheets and issues that require further clarification. TCH recommends a robust FAQ process and raises specific technical issues where clarifications are needed. The Clearing House urges the Board to consider the transition cost and burdens that will weigh on institutions as systems are constructed to track and report the data sought by the proposed data templates.