The Clearing House Association submitted a joint trades comment letter to the FRB responding to the Report of Selected Money Market Rates (FR 2420) Proposal, a transaction-based report that seeks to collect data on federal funds, Eurodollar, and CD transactions from domestically chartered commercial banks with over $26 billion in total assets and from U.S. branches and agencies of foreign banks with total third-party assets of $900 million or more. The proposal requests data submissions from reporting institutions by 7 a.m. daily for the prior day's transactions. The letter recommends that the daily submission occur on a two-day lag basis, and that the FRB leverage the data currently provided in the existing Liquidity 4G Monitoring Tool with certain enhancements. Additionally, the comment letter proposes an enhanced transition period and revisions to the scope of reportable data.