BPI submitted a comment letter on October 24 responding to the Federal Reserve’s proposal requiring the reporting of substantial data regarding assets, liabilities and off-balance-sheet exposures of U.S. GSIBs by instrument, currency, maturity and sector. BPI advised that the proposed March 31, 2019, reporting start date presented significant challenges to develop the appropriate internal control and review processes for a new report and recommended several technical changes should be made to the proposal to permit more accurate and timely reporting of the information requested.
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