To Whom it May Concern:
The Bank Policy Institute[1] appreciates the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System to revise the Structure Reporting and Recordkeeping Requirements for Domestic and Foreign Banking Organizations (FR Y-6, FR Y-7, FR Y-10, and FR Y-10E; OMB No. 7100-0297).[2] One key aspect of the proposal is the proposed change to the definition of “control” in the glossary of the FR Y-10. While we are supportive of definitional alignment across reports and with the final rule on control,[3] we have concerns with the proposed implementation timing of the proposed change and believe there are other aspects of the definitional change that require clarification. We are also supportive of the Federal Reserve’s efforts to create an electronic process for FR Y-6 reporting; however, the proposal and supporting documents do not provide clear guidance on how these new processes and data sourcing for the corresponding reconciliations will function and additional details will be required to implement these revisions. Our comments contained herein also include other recommendations and requests for clarification related to the proposed revisions to the FR Y-10 and FR Y-6 reports.
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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] 87 Fed. Reg. 27639 (May 9, 2022).
[3] 85 Fed. Reg. 12398 (March 2, 2020).
