The Clearing House Association submitted a joint comment letter to the U.S. banking agencies responding to the proposed revisions to the Instructions for the Preparation of the Country Exposure Report (the FFIEC 009 and 009a). While the letter generally supports the FFIEC’s efforts, TCH specifically requests a number of clarifications to the proposal to provide more accurate, consistent and comparable reporting. In view of the requested clarifications and volume and granularity of other changes included in the proposal, TCH requests a delay in the effective date of the proposal for at least 90 days to September 30, 2013.