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TCH Files Comment Letter Regarding Changes to FR Y-14A/Q/M and LISCC IHC Attestation

The Clearing House (TCH) filed a comment letter responding to a Fed rule proposal that would extend for three years the CCAR information collection applicable to bank holding companies with total consolidated assets of $50 billion, or more, and U.S. intermediate holding companies established by foreign banking organizations. TCH’s comment letter identifies several specific areas where additional clarifications would be beneficial and recommends a process to better facilitate timely implementation.