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TCH Responds to OCC Proposed Revisions to DFAST-14A

The Clearing House (TCH) submitted a comment letter to the OCC in response to its proposed revisions to the DFAST-14A. In the letter TCH expressed support for aligning the DFAST-14A with the recently finalized changes to the FR Y-14A and urged the OCC to not implement the new OCC Supplemental Schedule, which would collect information not submitted as a part of the FR Y-14A. TCH requested, in the event that the OCC nevertheless decides to adopt the new OCC Supplemental Schedule, that the OCC delay the effective date and revise the schedule to provide additional clarity. TCH urged the OCC to extend similar relief and clarification to institutions subject to the DFAST-14A as discussed in TCH’s comment letter submitted to the Federal Reserve in November 2016.