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TCH Comments on CCAR Data Collection Schedules Proposal

The Clearing House Association submitted a comment letter to the FRB on the proposed changes to the Comprehensive Capital Analysis and Review (the CCAR) data collection schedules. The letter addresses substantive concerns related to (i) the proposed operational risk data collection schedule; (ii) proposed changes to the wholesale schedule and (iii) proposed increases in frequency of reporting for three retail portfolios from quarterly to monthly (FR Y-14M).TCH urges the Board to provide all banks sufficient time to develop systems to capture the requested data items. On June 27 the Fed published in the Federal Register an announcement extending the comment period for the CCAR information collection (FR Y-14A/Q/M) from July 5 to August 6, 2012. The extension was granted at the request of TCH in order to allow additional time to analyze and discuss with the Fed acceptable alternatives to the original proposal regarding production of legal reserve information.