BPI Comments on Banking Agencies’ Proposed Revisions to Call Reports and FR Y-9

To Whom It May Concern:

The Bank Policy Institute[1] welcomes the opportunity to respond to the joint notice and request
for comment by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency, regarding revisions to the Consolidated Reports of Condition and Income (Call Reports),[2] as well as the notice and request for comment by the Federal Reserve regarding revisions to the Financial Statements for Holding Companies (FR Y-9). [3]

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[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost two million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

[2] 88 Fed. Reg. 10644.

[3] 88 Fed. Reg. 18315.