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TCH Comments on OCC Stress Testing Information Collection Proposal

The Clearing House Association filed a joint trade comment letter with the OCC on its recent Stress Testing Information Collection Proposal. The letter requests: (i) transparency on the intended use of the data collected, (ii) that the OCC conform its Basel III data collection template to those of the other agencies, and (iii) more detailed instructions for the schedules as well as a formal process for clarifying uncertainties.