The Clearing House (TCH), jointly with the ABA, submitted a comment letter to the FFIEC regarding proposed modifications to the Consolidated Reports of Condition and Income (the Call Report). The letter is very supportive of the FFIEC’s decision to accelerate the start of the next review of the Call Report and the FFIEC’s initiative to stream line the Call Report by better aligning it with recently implemented rules and standards. The comment letter specifically recommends that the FFIEC: (i) establish an industry advisory committee to provide the FFIEC with advice and guidance on issues related to FFIEC reports; (ii) work to ensure other required regulatory reporting forms are updated simultaneously; (iii) allow sufficient time for institutions to implement any reporting changes; (iv) release finalized instructional updates at least a quarter prior to implementation; and (v) provide enhanced, on-going, training opportunities both to introduce new line items as well as review those which were previously established.
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