The Clearing House (TCH) filed a comment letter with the Fed in response to its proposed changes to the FR Y-14 and the application of the global market shock (GMS) to certain IHCs. In the letter, TCH urges the Fed to reconsider applying the GMS to certain IHCs, with the caveat that if the Fed nevertheless decides to apply the GMS in 2018 to such IHCs, it should do so through a confidential supervisory process to provide an appropriate transition period for first time filers. Although the proposal did not address the applicability of the counterparty default scenario component, TCH argues that such component should be treated in the same manner as the GMS should the Fed determine to apply it to certain IHCs. The comment letter also includes specific comments and requests for clarification regarding proposed changes to the FR Y-14A/Q/M reports.
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