On April 11, 2013, the LSTA and the ABA filed a joint letter in response to the Interagency Guidance on Leveraged Lending published by the Office of the Comptroller of the Currency, the Federal Reserve Board and the FDIC (see Legal Update, US Bank Regulators Release Supervisory Guidance on Leveraged Lending). In the letter, the LSTA and ABA request, on behalf of their members, that the agencies revise the guidance by removing the compliance date of May 21, 2013, and providing an extension of up to 12 months to implement the suggestions. The letter points out that in order to fully implement all the changes involved in the new guidance, the members will need more time than the current eight week compliance period. The substantial changes involved will require much additional work including the revision of banks' risk management framework and policies and procedures. The implementation of these changes will be a time consuming process, requiring interpretation of various points in the guidance, raising many new challenges and requiring more time than was initially allocated.