The Clearing House (TCH) submitted a joint trades comment letter to the FRB on the July 15 revisions to the Instructions and Forms of the Capital Assessments and Stress Testing information collections (FR Y-14A/Q/M). Although TCH reiterated its support for strong capital planning and stress testing, the letter asked that certain aspects of the proposal be reconsidered, as these areas could potentially create serious implementation difficulties and require technical corrections and clarifications. Specifically, TCH requested that: (i) the effective dates (September 30 for the majority of the proposal) be postponed until six months after the final rule is published, (ii) the FRB better align changes in the proposal with proposed changes to the Form FR Y-9C and (iii) the FRB not adopt the proposed changes to the operational risk schedule requiring additional reporting of litigation reserve information.
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