On February 24, BPI submitted a comment letter to the Fed responding to proposed reporting revisions to the FR Y-9. The letter does not support the proposed change in reporting of home equity lines of credit that convert from revolving to non-revolving status in view of the potential significant operational challenges associated with these proposed changes and encourages the Fed to create a new memorandum item for these lines of credit consistent with the recently finalized changes to the Call Reports. The letter also suggests that the Fed make other revisions to the reporting of derivatives in the FR Y-9C to conform to changes recently made to the Call Reports. Finally, the letter requests that the Fed provide clarification regarding the reporting of standardized approach for counterparty credit risk (SA-CCR) notionals and that notional reporting in the FR Y-9C be based on the contractual notional, consistent with current practice.
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