The Clearing House Association (TCH) submitted a joint-trade comment letter to the FRB regarding the September 16 NPR which proposed adding a CFO-level attestation to the FR Y-14 report series for LISCC banks. For U.S. LISCC BHCs, the letter requests that the implementation of the attestation for effectiveness of internal controls and material correctness of data be extended to April 2018. For FBO LISCC BHCs, the letter requests delay in implementation of all aspects of the proposed attestation until April 2018 given the additional burdens faced with creating IHCs. Additionally, among other things, the letter request that (i) the attestation for conformance with the instructions should include qualifiers to limit the attestation to a “good faith, reasonable efforts” basis; (ii) the attestation for effectiveness of internal controls should only be required on the annual submissions of the FR Y-14A; and (iii) the attestation should be modified such that the CFO attests that senior management is responsible for internal controls, and not the CFO individually.
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