Ladies and Gentlemen:
The Bank Policy Institute1 welcomes the opportunity to comment on the March 2020 proposal by the Board of Governors of the Federal Reserve System to revise the FR Y-14A/Q/M reports.2 We support the Federal Reserve’s ongoing efforts to reduce reporting burden for firms and to clarify reporting instructions and requirements. For example, the Federal Reserve’s proposed removal of the PPNR Metrics worksheets from the FR Y-14A is a welcome change as PPNR results are already available on the PPNR Projections and Net Interest Income worksheets, and thus would significantly reduce burden and duplicative reporting for respondents. However, we believe that there are a number of proposed revisions that would require systems changes that would ultimately contradict this objective and therefore should be reconsidered. We have also included other recommendations and requests for clarification on the proposed changes in Appendix A.
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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] 85 Fed. Reg. 15776 (March 19, 2020).
