The Clearing House (TCH) filed a comment letter with the OCC, Fed, and FDIC, responding to a proposal to revise FFIEC 051, FFIEC 041, and FFIEC 031 Call Reports. The proposal seeks to reduce reporting burdens, address the definition of “past due” for regulatory reporting purposes, and conform the regulatory reporting of equity investments to the accounting standards applicable to such investments. While TCH appreciates the Agencies’ efforts to reduce reporting burden, TCH opposes the proposed changes to the definition of past due and the scope of the 031, and offers several constructive suggestions to more meaningfully reduce reporting burden.