The Clearing House Association joined IIF, GFMA, and FFI in a letter to the Financial Stability Board on its G-SIB Common Data Template. The FSB has created common templates for global systemically important banks to report consolidated data over a series of phases to an international data hub that will pool the information and share the data with national supervisory authorities. The FSB implemented Phase 1 in March 2013, requiring banks to submit their bilateral counterparty credit exposures and aggregate exposures to relevant risk factors, but is still revising Phase 2 (a common data template for bilateral funding sources) and Phase 3 (a common data template for a harmonized consolidated balance sheet). 

Building on points raised at a workshop with the industry on October 2-3, the letter urges the FSB to modify the timing and sequencing of the implementation of the Phase 2 and 3 templates by, for example, creating additional sub-phases to be implemented over a longer timeframe or allowing certain sub-phases to be conducted on a best-efforts basis, due to the significant IT and other operational challenges presented by the new requirements. Further, the letter urges the FSB to give additional consideration to materiality considerations and to work with the industry to determine the scope of the data elements included in the Phase 2 and Phase 3 templates so as to maximize the usefulness of the data requested, and to minimize the burden on the banks as much as possible.