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Trade Associations Comment on Revisions to the Consolidated Financial Statements for Holding Companies

The Clearing House (TCH) submitted a comment letter to the Fed jointly with the ABA in response to proposed revisions to the FR Y-9C. The comment letter reinforces the points that TCH and ABA had previously made in a comment letter to the FFIEC in November responding to nearly identical changes proposed to the Call Report. The letter strongly urges the Fed to delay implementing the changes, to align all revisions with the Call Report and other related reports banks are required to file, and specifically to update the threshold for the line items that currently use an outdated deposit insurance threshold.