The IIF, IBFed, GFMA and TCH (the “Associations”) submitted comments on the BCBS’s proposed Principles for Effective Risk Data Aggregation and Risk Reporting. The Associations recognize the benefits of improving banks’ risk data aggregation and risk reporting capabilities and assured the BCBS that firms are working toward that goal. However, the challenges firms are facing with regard to the demands imposed on them by numerous new regulatory requirements, which may lead to operational risk issues, are emphasized. The Associations also cautioned the BCBS about the quite detailed role that the proposed Principles seem to expect from the boards. This could divert boards’ time from more pressing issues facing their firms and from boards’ primary responsibility of providing strategic guidance and direction. Moreover, the Associations raised the issue of the use of an appropriate level of approximation particularly during a stress or crisis situation where quick management response is needed.