To Whom It May Concern:
The Bank Policy Institute1 appreciates the opportunity to comment on the Board of Governors of the Federal Reserve System’s Temporary approval of information collection; notice, request for comment related to the Capital Assessments and Stress Testing Reports (FR Y-14 A/Q/M).2 BPI understands the need for timely data from reporting firms and appreciates the Federal Reserve’s goal with respect to many of the proposed revisions to collect data “to better understand the evolving effects of the COVID–19 pandemic on bank positions and the broader economy.” However, given the short lead-time for firms to implement revisions, including modifications to a schedule to be reported monthly that has thus far only been provided on a quarterly basis, the condensed timeframe prior to initial reporting creates significant issues for responding firms. Our recommendations presented herein would alleviate some of the burden associated with these temporary revisions, while still providing the Federal Reserve with necessary and useful data. We also request clarification on a number of items that would assist firms in providing the granular data requested in the Proposal.
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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. 41040 (July 8, 2020).
