The Clearing House Association submitted a comment letter to the Fed in response to its proposed revisions to the FR Y-6, FR Y-10, FR Y-7 and FR Y-10E reports (the “Reports”) to collect a Legal Entity Identifier (“LEI”) for all banking and nonbanking legal entities. While TCH expressed continued support for the development of a uniform global LEI solution as a tool to help enhance financial stability, the letter discusses industry concerns with several technical and administrative aspects of the proposal. TCH suggests that the one-time collection to populate existing FR Y-10s with LEI information (which the Proposal would require by September 30, 2015), be due concurrently with the initial FR Y-6/FR Y-7 submission; essentially a six month delay. 

The letter also provides a recommendation for the format of the one-time collection that would be mutually beneficial for both the Fed and the reporters.  Lastly, TCH provided comments on several other outstanding issues with the Reports which were not addressed in the proposal, including: (i) clarification for “Business Organizational Types” in the FR Y-10; (ii) how to report interests in LLCs on the FR Y-10 when legal agreements do not designate a “Managing Member”; (iii) enhancements for withdrawing Reports, and (iv) other technical issues related to the submission of the Reports.