Federal Deposit
Insurance Corporation

Office of the Comptroller of the Currency
Public Information Room
Mailstop 1-5, Attention: 1557-0100
250 E Street, S.W.
Washington, DC 20219

Jennifer J. Johnson, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, DC 20551
Attention: OMB No: 7100-0035

Robert Feldman, Executive Secretary
Federal Deposit Insurance Corporation
550 17th Street, N.W.
Washington, DC 20429
Attention: Comments

Re: Joint Notice and Request for Comment on Country Exposure Report/Country Exposure Information Report (FFIEC 009 and FFIEC 009a Reports)

Ladies and Gentlemen:

PNC Financial Services Group, Inc, (“PNC”) appreciates the opportunity to comment on the proposed revisions to the Country Exposure Report and the Country Exposure Information Report, collectively, “the FFIEC 009 Reports” by the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Board”), and the Federal Deposit Insurance Corporation (“FDIC”), collectively, “the Agencies”.

The PNC Financial Services Group, Inc. is one of the largest diversified financial services organizations in the United States with $83.4 billion in total assets as of March 31, 2005. Our major businesses include community banking, corporate banking, real estate finance, asset-based lending, wealth management, asset management and global fund services. PNC’s lead bank,

PNC Bank National Association, Pittsburgh, Pennsylvania, has branches in Indiana, Kentucky, New Jersey, Ohio, Pennsylvania and most recently, the District of Columbia, Virginia and Maryland.

PNC’s concerns relative to the proposed changes to the FFIEC 009 Reports relate to timing. PNC recommends to the Agencies that the effective date of reporting changes to the FFIEC 009 Reports be delayed from September 30, 2005 to March 31, 2006 based on the following rationale:

• Proposed Changes not Finalized: It is very difficult to initiate a request to implement systems and programming changes for these reports until the final format and instructions for the FFIEC 009 Reports have been received. The shorter the time frame between the final format and the effective date, the greater the burden becomes for banks.

• Significant System Changes and Testing: The final reporting format will require significant programming changes and testing to achieve the same accuracy that we currently deliver for our existing FFIEC 009 Reports. Our MIS resources are still implementing and testing recent regulatory reporting changes that were announced earlier in 2005, in particular, TIC D for derivatives’ reporting which is being rolled out through September 30, 2005. PNC’s MIS resources have been challenged to work on these proposals while maintaining normal work responsibilities. A March 31, 2006 effective date would allow a more reasonable time frame to complete the significant program changes and testing needed to properly implement the final changes to the FFIEC 009 Reports.

• Time and Staffing Constraints: The July through August time frame is a difficult time for banks to allocate regulatory reporting personnel to assist MIS resources in the design and testing of programming changes. We believe that in order to maintain data integrity, during peak reporting preparation periods, our regulatory reporting resources should be fully dedicated to the filing of our quarterly regulatory reporting requirements (i.e., Call Reports, FR Y-9Cs, FR Y-12, FR Y-8s, FR Y-11s, etc.). A delay in the implementation of the proposed changes to the FFIEC 009 Reports will assist in this endeavor.

Thank you for considering the concerns expressed in this letter. If you have any questions or are in need of any further information, please contact one of us.

Sincerely yours,

Patricia J. Jablonski
Thomas M. Doody