The Clearing House Association (TCH) submitted an unsolicited joint-trades comment letter regarding the potential introduction of a CFO and/or Chief Auditor attestation requirement for Forms FR Y-14A, FR Y-14Q and/or FR Y-14M that may be under consideration by the Fed. The letter provides initial concerns given the serious and significant problems associated with attestation in this context. The Fed previously proposed and ultimately decided not to adopt an attestation requirement for the FR Y-14 Forms in 2012. TCH will lead the industry effort in response to any NPR requiring attestation for the FR Y-14 report series.