The Clearing House (TCH) filed a comment letter to the Fed on its proposed revisions to FR Y-6, FR Y-7 and FR Y-10 and the instructions thereto (the “Reports”) by, inter alia, revising the FR Y-10 by removing the legal authority paragraph in the General Instructions, clarifying the instructions regarding the interest in sole partnership and sole member LLCs, and adding several new Glossary entries. TCH previously submitted on May 19, 2015 written comments to a notice of proposed rulemaking, Proposal to Collect the Legal Entity Identifier for Banking and Nonbanking Legal Entities Reportable on the FR Y-10, FR Y-6 and FR Y-7 Reports (OMB Control Number 7100-0297)(the “Prior Proposal”). In the May 19, 2015 letter, TCH addressed several outstanding issues with the Reports, particularly with the FR Y-6 and FR Y-10, which were not addressed in the Prior Proposal but had been previously communicated to Federal Reserve staff. The comment letter is a formal re-submission of these comments from our May 19, 2015 letter (pages 3-7 and Annex A).
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