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TCH Comments on FR Y-15 Disclosure

The Clearing House Association joined the ABA in submitting a supplemental comment letter to the FRB on the FR Y-15. The issue of primary concern in the supplemental letter relates to the requirement of public disclosure of components of high quality liquid assets, the numerator in the LCR. The letter requests that the Fed either remove the LCR line items from the FR Y-15, or alternatively provide confidential treatment to the FR Y-15, at least until the LCR is finalized and fully implemented in the U.S. TCH previously commented on the proposed FR Y-15 on October 19, 2012 as part of a joint trade comment letter.