The Clearing House Association submitted a joint-trades comment letter to the Federal Reserve Board responding to the proposed revisions to the Banking Organization Systemic Risk Report (FR Y-15). TCH previously commented on this report in March 2013, with the primary issue of concern being the requirement to publicly disclose components of high quality liquid assets – the numerator in the LCR. TCH reasserted that disclosing the majority of the data that comprises the FR Y-15 is premature and may create significant market and supervisory confusion and competitive harm, as it is unclear how market participants will reconcile the FR Y-15 numbers with those reported in the FR Y-9C and elsewhere. Additionally, the comment letter opposes the shortening of the time frame for reporting from 90 days to 60 days and also requests that the CFO attestation requirement be removed until such times as the items noted in the comment letter have been addressed.