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TCH Submits Comment Letter on FSB Data Gaps Phase 3 Instructions

The Clearing House (TCH) submitted a comment letter to the Chairman of the FSB Data Requirements Workstream regarding the revised guidelines for reporting institution-to-aggregate granular data on assets and liabilities on an immediate counterparty basis. TCH requests that the version of the report implemented in the U.S. be definitionally consistent with existing U.S. reporting definitions (i.e., specific line items should fully reconcile to the same items that exist in the FR Y-9C and FFIEC 009). The letter also requests five additional days for year-end reporting and for the U.S. Agencies to provide a comprehensive mapping document similar to those provided for other similar reports.