The Clearing House Association filed an industry comment letter with the Fed on the proposed Banking Organization System Risk Report (FR Y-15). The letter requests, among other things, (i) additional information as to the purpose of the information collection, (ii) an exclusion for FBOs, (iii) additional time for companies to submit the requested information, (iv) the removal of the CFO attestation requirement, (v) the Fed to maintain the confidentiality of the data submitted, and (vi) that the initial submission be on a “best efforts” basis.