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TCH Comments on Revisions to the Banking Organization Systemic Risk Report (FR Y-15)

The Clearing House (TCH) submitted a comment letter to the Fed on their proposal to revise the FR Y-15 systemic risk report to increase the frequency of reporting, collect information on short-term wholesale funding (STWF), and update the report generally to conform the FR Y-15 with the U.S. supplementary leverage ratio and the G-SIB capital surcharge rule. TCH’s letter expresses concern that the proposal does not allow sufficient time for banks to revise their reporting and internal control systems to properly report the additional data or to perform proper reconciliation following quarter-end. Specifically, TCH requests that: (i) quarterly reporting be delayed until at least 2017 for all banks with semi-annual reporting in 2016; (ii) the first report on the new FR Y-15 be submitted on a reasonable estimates basis; and (iii) certain FBOs be granted an additional year for the first submission of their IHC. Other issues addressed in the comment letter include: (i) confidentiality for non-year-end quarterly data and STWF data; (ii) a proper mapping of all data elements in the report that are derived from other Fed reports; and (iii) clarification for certain aspects of the instructions.