The Clearing House Association submitted a comment letter to the OCC, FRB, and FDIC on the proposed Call Report revisions. TCH disagrees with the proposed changes insofar as they require a disaggregation of the loan loss allowance that is inconsistent with the business model banks use to estimate their allowance. TCH recommends that the agencies collect information on loan origination activity only at the bank holding company level, using the data reported for CCAR purposes (FR Y-14Q). TCH also sent a comment letter to the FRB on the FR Y-9C, Financial Statements for Bank Holding Companies, mirroring the comments in the TCH letter on the proposed Call Report revisions.On March 16, 2012 the FRB issued revisions to its proposed FR Y-9C changes. The final revisions incorporate the following changes expressly requested by TCH in our January 20 comment letter: (i) the FRB will re-evaluate the proposed new schedules on (a) disaggregated data on the allowance for loan and lease losses (ALLL) and (b) loan origination activity, and (ii) collection of disaggregated ALLL data would not take effect before the September 30, 2012, report date.