BPI Comments on Fed Proposal to Extend the Report of Institution-to-Aggregate Granular Data on Assets and Liabilities on an Immediate Counterparty Basis

To Whom it May Concern:

The Bank Policy Institute1 appreciates the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System to extend for three years the Report of Institution-to- Aggregate Granular Data on Assets and Liabilities on an Immediate Counterparty Basis (FR 2510; OMB No. 7100–0376).2 While we understand that the Federal Reserve is not proposing revisions to the FR 2510, we offer recommendations herein intended “to enhance the quality, utility, and clarity of the information collected ” and “to minimize the burden of information collection on respondents,”3 as requested by the notice. Specifically, our comments outline areas of the FR 2510 that would benefit from revisions to better align the report with the Country Exposure Report (FFIEC 009) and the Consolidated Financial Statements for Holding Companies (FR Y-9C).

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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 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

[2] 86 Fed. Reg. 57672 (October 18, 2021).

[3] Id.