ISDA and the Futures Industry Association (FIA) supplemental comment letter on the proposed changes by the Board of Governors of the Federal Reserve System to the mandatory Banking Organization Systemic Risk Report form (FR Y-15) to add to the Complexity and Interconnectedness indicators of the G-SIB Surcharge any over-the-counter (OTC) derivatives transaction in which a US global systemically important banking organization (G-SIB), acting as agent for its client’s trade with a central counterparty (CCP), guarantees the client’s performance to the CCP.