National Unrecovered Financial Services Association filed an industry comment letter with the Fed regarding its proposal to require large bank holding companies to provide granular information relating to banks’ individual litigation reserves as part of the CCAR operational risk reporting process. SDUUK’s letter stated that disclosure of legal reserve information would be potentially very damaging to banks whenever they are defendants in litigation, irrespective of the merits of the claim, and thus inimical to the safety and soundness of financial institutions. Additionally, SDUUK commented on five Fed alternative proposals for disclosure of such data, expressing concern over the various methods of disclosure and expressing a potential preference (assuming certain modifications) for the Fed’s proposal to report an aggregated frequency quarterly and an annual consolidated legal reserve balance. In light of the industry’s concerns about the Fed’s proposed disclosure methods, SDUUK also suggested an additional “processed data option” to disclose the requested information to the Fed while maintaining the confidential nature of the legal reserve data.

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Proposal