The Clearing House Association, along with two other trade associations, submitted a comment letter to the U.S. banking agencies in response to the June 19, 2013 draft Instructions for the Preparation of the Country Exposure Report (the FFIEC 009 and 009a). In view of the delayed release of critically important templates, text guides, and testing portal capabilities, which will not be available until September, TCH requests that the effective date for the new reporting requirements be delayed until December 31, 2013 or until at least the end of the next full quarter following the close of the quarter in which such information and training is provided. TCH previously commented on the FFIEC 009/009a revisions on April 1, 2013, after which the FFIEC granted a 3-month delay in the effective implementation date, as well as several other changes and clarifications requested by TCH.