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TCH Comments on Proposed Data Collection Schedule Revisions

The Clearing House Association submitted a joint trade comment letter to the FRB on the revisions to the proposed annual, quarterly, and monthly data schedules. The associations generally support the revisions to the proposed schedules but have concerns with several components of the schedules. The letter addresses broader concerns regarding the data collection process and specific problems with the schedules and worksheets, including the requirements for extensive supporting documentation to be filed in connection with the mid-year company-run stress test.