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TCH Comments on FR 2028 Surveys

The Clearing House Association filed a comment letter with the FRB on the Surveys on Terms of Lending (FR 2028 Surveys) objecting to the proposed revisions to add a column (i) to the Surveys to collect the RSSD ID of the branch that originated each loan and (ii) to the FR 2028A to collect the amount of the loan origination fees. The data for reporting the RSSD ID would not be meaningful since business and farm loans are not typically originated in traditional branches; therefore, TCH has offered to work with the FRB to develop an alternative proposal to achieve the FRB’s objectives. TCH also requested that the effective date of any of the proposed additions be delayed until after the May 2012 survey week.