The Clearing House Association submitted an unsolicited comment letter to the FSB Data Requirements Workstream regarding the proposed collection of granular and comparable G-SIB balance sheet data. The letter expresses concerns that the proposal and template contain a number of impractical elements and insufficiently balance the costs of obtaining such data with the potential supervisory benefits. Amongst other things, the letter urges the FSB to phase in the reporting requirements so that G-SIBs would only be required to report exposures to five countries and two currencies for the first two years of reporting. The comment letter also supports the required number of countries never exceeding a maximum of 10 (the proposal currently requires 35) and also supports the notion of banks being permitted to report on the basis of their respective local accounting standards.
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