In a letter to the Fed, the RMA group argues that including legal reserve information in the CCAR submissions would subject banks to significant prejudice, and that there is no assurance such information would remain confidential. The group believes that requiring banks to disclose legal reserves would be "unwise, unsound, and highly prejudicial."
In particular, RMA notes the severe risk of inadvertent disclosure; legal discovery by other agencies and third parties, including potential plaintiffs such as the U.S. government; and unfair damage to banks' reputations.
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