To Whom It May Concern:
The Bank Policy Institute[1] welcomes the opportunity to comment on the proposal by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency to revise the Country Exposure Report (FFIEC 009) and the Country Exposure Information Report (FFIEC 009a).[2] BPI is generally supportive of the intent of the proposed revisions, however we believe that the agencies would achieve greater consistency, simplicity, and clarity in both the FFIEC 009 and FFFIEC 009a reporting requirements by making a few changes to the draft reporting instructions and further clarifying certain aspects of the proposal as described herein.
Additionally, while not related to the proposed changes, our comments also seek confirmation on CUISP netting practices for purposes of FFIEC 009 reporting.
To read the full comment letter, please click here.
[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. 3170 (January 20, 2022).
