[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-303096-105":53,"doc-detail-303096-en":126},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":119,"head_meta":121,"extra_data":123,"updated_unix":125},105,"en","20150519-comment-letter-on-lei-reporting","20150519 - Comment Letter on LEI Reporting","","May 19, 2015, a comment letter addresses the Federal Reserve Board of Governors on proposed revisions to FR Y-6, FR Y-7, FR Y-10, and FR Y-10E/related reports tied to collecting Legal Entity Identifiers (LEIs). The author supports the goal of a global LEI to improve oversight, monitoring, and systemic risk evaluation, but raises technical and administrative concerns—especially timing, format, and submission mechanics for a one-time collection using existing LEI data. It also notes practical issues affecting reporters and matching processes.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/20150519-comment-letter-on-lei-reporting/303096/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/20150519-comment-letter-on-lei-reporting/303096.png","ImageObject",442,249,{"name":88,"@type":89},"Logic","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-06","2026-09-19",true,{"@type":98,"interactionType":99,"userInteractionCount":76},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"What action is requested or discussed in the letter?","Question",{"text":108,"@type":109},"The letter responds to a comment request regarding proposed revisions to FR Y-6, FR Y-7, FR Y-10, and FR Y-10E to collect LEIs for banking and nonbanking legal entities.","Answer",{"name":111,"@type":106,"acceptedAnswer":112},"What is the core policy support expressed by the author?",{"text":113,"@type":109},"The author supports developing a uniform, global LEI solution to help monitor and evaluate systemic risk and enhance financial stability.",{"name":115,"@type":106,"acceptedAnswer":116},"What main concern does the author raise about the One-Time Collection?",{"text":117,"@type":109},"The author is concerned the implementation date is too early, citing practical issues such as limitations in existing LEI-checking infrastructure, manual matching burdens, and the need to coordinate with majority interest holders.","https://schema.org",{"og:url":78,"og:type":120,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":122,"canonical":78},"index,follow",{"doc_id":124,"site_id":56},303096,1791170286,{"code":4,"msg":5,"data":127},{"doc_id":124,"user_id":128,"nickname":88,"user_avatar":129,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":76,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":135,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":76},1099513958762,"https://ap-avatar.wpscdn.com/avatar/1000023916a998db790?x-image-process=image/resize,m_fixed,w_180,h_180&k=1784791008015729253","May 19, 2015  \nMr. Robert deV. Frierson Secretary  \nBoard of Governors of the Federal Reserve System 20th Street & Constitution Avenue, N.W.  \nWashington, D.C. 20551  \nRe:  Proposed Agency Information Collection Activities; Comment Request: Proposal to Collect the Legal Entity Identifier for Banking and Nonbanking Legal Entities  \nReportable on the FR Y-10, FR Y-6 and FR Y-7 Reports. (OMB Control Number: 7100-0297) .  \nMr. Frierson:  \nThe Clearing House Association L. L.C.1 (“The Clearing House”) appreciates the opportunity to comment on the Board of Governors of the Federal Reserve System’s (the “Federal Reserve”) proposed revisions (the “Proposal”) to the Annual Report of Holding Companies (“FR Y-6”), the Annual Report of Foreign Banking Organizations (“FR Y-7”), the Report of Changes in Organizational Structure (“FR Y-10”), and the Supplement to the Report of Changes in Organizational Structure (“FR Y-10E”, and together, the“Reports”) . The proposed changes to the Reports would collect the Legal Entity Identifier (the “LEI”) for all banking and nonbanking legal entities to the extent that an LEI has already been issued for thereportable entity at the time of collection.  \nThe Clearing House continues to be very supportive of the development of a uniform, global LEI solution as a tool to help promote industry and supervisory efforts to monitor and evaluate systemic risk and to enhance financial stability.2 Similarly, The Clearing House appreciates and supports the Federal  \n1 Established in 1853, The Clearing House is the oldest banking association and payments company in the United States. It is owned by the world’s largest commercial banks, which collectively hold more than half of all U.S. deposits and which employ over one million people in the United States and more than two million people worldwide. The Clearing House Association L.L.C. is a nonpartisan advocacy organization that represents the interests of its owner banks by developing and promoting policies to support a safe, sound and competitive banking system that serves customers and communities. Its affiliate, The Clearing House Payments Company  \nL. L.C., which is regulated as a systemically important financial market utility, owns and operates payments technology infrastructure that provides safe and efficient payment, clearing and settlement services to financial institutions, and leads innovation and thought leadership activities for the next generation of payments. It clears almost $2 trillion each day, representing nearly half of all automated clearing house, funds transfer and checkimage payments made in the United States. See The Clearing House’s web page [at](at www.theclearinghouse.org)[ ](at www.theclearinghouse.org)[www.theclearinghouse.org](at www.theclearinghouse.org).  \n2 See, April 2011 comment letter “Enhancing Supervisory and Industry Ability to Monitor and Evaluate Systemic Risk” available at, [https://www.theclearinghouse.org/issues/banking-regulations/international-](https://www.theclearinghouse.org/issues/banking-regulations/international-)  \nReserve’s efforts to implement a line item for the LEI on the Reports, as we agree with the Proposal’s assertion that “as the usage of LEI becomes more prominent, it would enable examiners, economists, and financial analysts to perform improved analyses, particularly during stressed market conditions.”3  \nAs more fully described below, however, The Clearing House is concerned with several technical and administrative aspects of the Proposal, including the timing of the one-time information collection exercise to populate existing LEI data for all FR Y-10 reportable entities (the “One-Time Collection”) and the means for submitting such collection. In addition, we would like to use this opportunity to address several other outstanding issues with the Reports, particularly with the FR Y-6 and FR Y-10, which are not addressed in the Proposal but have been communicated to Federal Reserve staff in the past. ","cbCaioACQP1fCCoG","https://ap.wps.com/l/cbCaioACQP1fCCoG","pdf",427628,9,"English","# Proposed LEI collection under FR Y reports\n## Overall support for LEI policy and purpose\n## Concerns about timing and submission for the One-Time Collection\n## Required alignment with initial FR Y-6/FR Y-7 LEI submissions\n## Administrative and technical challenges in matching LEIs","[{\"question\":\"What action is requested or discussed in the letter?\",\"answer\":\"The letter responds to a comment request regarding proposed revisions to FR Y-6, FR Y-7, FR Y-10, and FR Y-10E to collect LEIs for banking and nonbanking legal entities.\"},{\"question\":\"What is the core policy support expressed by the author?\",\"answer\":\"The author supports developing a uniform, global LEI solution to help monitor and evaluate systemic risk and enhance financial stability.\"},{\"question\":\"What main concern does the author raise about the One-Time Collection?\",\"answer\":\"The author is concerned the implementation date is too early, citing practical issues such as limitations in existing LEI-checking infrastructure, manual matching burdens, and the need to coordinate with majority interest holders.\"}]","20150519 - Comment Letter on LEI Reporting | PDF",1789799951]