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 revise the Government Securities Dealers Reports (FR 2004; OMB No. 7100–0003).2 We understand the Federal Reserve’s need to monitor and analyze developments in the government securities markets and identify changing market practices through the FR 2004 reports.3 However, a number of the proposed changes to the FR 2004 reports would afford banks and their third-party vendors insufficient time to complete their initial assessments, make the necessary systems changes, and to perform the necessary testing and subject the reporting to firms’ existing control and review processes to meet the proposed implementation timing. Therefore, and as discussed in more detail below, we recommend extending the timeline for these proposed changes such that they are made effective no earlier than the December 29, 2021 report date.
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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. 80786 (December 14, 2020).
[3] See Board of Governors of the Federal Reserve System, Supporting Statement for the Government Securities Dealers Reports (FR 2004; OMB No. 7100-0003), available at https://www.federalreserve.gov/reportforms/formsreview/FR%202004%20OMB%20SS.pdf.
