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  • The Clearing House Urges Better Public-Private Coordination to Bolster Anti Money Laundering Efforts

    The Clearing House (TCH) provided recommendations to the Committee on Payments and Market Infrastructures (CPMI) in response to CPMI’s recent report on concerns about the safe and efficient functioning of the correspondent banking market and potential measures to improve the correspondent banking environment.  In its letter, TCH agreed that technical improvements to information sharing and similar anti-money laundering and counterterrorism financing tools may be helpful in improving access to correspondent banking services.  However, TCH also stressed that it is just as important that policymakers and banks work together to better and more clearly define the roles and responsibilities of various stakeholders.

  • The Clearing House Reiterates Support for NACHA Same-Day ACH Settlement

    The Clearing House welcomes the Federal Reserve’s decision to adopt NACHA’s rules for same-day ACH.   Under the terms of NACHA’s ballot, the effective date of NACHA’s rules was contingent upon NACHA receiving written confirmation from the Federal Reserve Board that it will support the rules.  By confirming its support, NACHA’s same-day ACH rules will begin to take effect as of September 23, 2016, as indicated in NACHA’s ballot.

  • The Clearing House Urges International Regulators to Establish Global Risk Governance Standards to Address Systemic Risks Posed by CCPs

    On September 18, The Clearing House Association (TCH) submitted a letter to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) recommending that global supervisory authorities require central counterparties (CCPs) to adopt four key enhancements to CCP risk governance and member consultation processes. 

  • The Clearing House Reacts to the Federal Reserve’s GSIB Surcharge Rule

    In his statement, The Clearing House CEO Jim Aramanda noted that  although the final rule appears to include some improvements to the proposal, The Clearing House (TCH) remains concerned that the final rule failed to address a number of significant flaws identified in our comment letter. These remaining flaws will have meaningful and negative consequences, especially for the robustness and liquidity of markets served by activities disproportionately impacted by the final rule, and will result in adverse impacts to customers and the real economy.

  • The Clearing House Welcomes Release of CFPB’s Consumer Protection Principles for Faster Payment Systems

    The Clearing House (TCH) welcomed the Consumer Financial Protection Bureau’s (CFPB) release of its “Consumer Protection Principles” for faster payment systems. TCH agrees with the CFPB’s views on the importance of protecting consumers that use faster payments, and strongly supports making consumers’ interests a key consideration as the industry works to build a new real-time payment system.

  • TCH Publishes Updated Guiding Principles on Enhancing U.S. Banks’ Corporate Governance

    The Clearing House Association (TCH) released its updated Guiding Principles for Enhancing U.S. Banking Organization Corporate Governance (Governance Principles). TCH’s Governance Principles aim to help provide a framework for bank corporate governance that seeks to facilitate more effective board oversight, enhance bank safety and soundness, promote confidence in banks and encourage consistent supervisory guidance. 

  • The Clearing House Calls for Comprehensive Cyber Threat Information-Sharing Legislation at House Financial Services Subcommittee Hearing

    The Clearing House’s (TCH) Chief Risk Officer Russell Fitzgibbons stressed the importance of continued improvement in collaboration between the private sector and the government in combating cyberattacks and emphasized the need for comprehensive cyber threat information-sharing legislation at a House Financial Services subcommittee hearing on protecting critical financial services infrastructure. 

  • The Clearing House Lauds House Passage of Critically Important Cyber Security Bills

    The Protecting Cyber Networks Act (H.R. 1560) and the National Cybersecurity Protection Advancement Act (H.R. 1731), will help better protect Americans’ sensitive personal information by facilitating more effective information sharing between the government and private sector which is critical to detecting and preventing cybercrime. The Clearing House is, however, disappointed that the House adopted amendments to both bills that will require them to sunset in seven years. These threats will not sunset and we need to ensure certainty and consistency for the long term. 

  • Financial Industry Associations Submit Comment Letter on Proposed Capital Surcharge for U.S. GSIBs

    The Clearing House Association (TCH), joined by the Securities Industry and Financial Markets Association (SIFMA) and the Financial Services Roundtable (FSR), filed a comment letter with the Federal Reserve in response to its proposal to impose an additional capital surcharge requirement on U.S. global systemically important bank holding companies suggesting that the proposal be revised to better reflect the actual systemic risk posed by U.S. G-SIBs.

  • TCH Provides Recommendations to Basel Committee on its Proposed Revisions to the Standardized Approach for Credit Risk and Capital Floors

    In a comment letter filed with the Basel Committee on Banking Supervision in response to its “Revisions to the Standardized Approach for Credit Risk and Capital Floors: The Design of a Framework Based on Standardized Approaches” The Clearing House identifies areas where the Proposals should be modified to better achieve the Committee’s stated objectives of making the Standardized Approach more risk-sensitive, reducing reliance on external credit ratings and strengthening the comparability of risk-weighted asset calculations across jurisdictions.

  • TCH Strongly Supports Regulatory Capital Rules Proposal

    The Clearing House Association filed a comment letter with U.S. bank regulators on proposed revisions to the U.S. Basel III capital rules for banks with consolidated total assets of at least $250 billion and consolidated on balance sheet foreign assets of at least $10 billion, expressing its strong support for the proposed revisions.

  • TCH Recommends Liquidity Monitoring Report Proposals be Revised to be More Consistent with the Liquidity Coverage Ratio

    The Clearing House Association, in coordination with ABA, FSR, and IIB, filed a letter with the Federal Reserve on its proposed revisions to two important supervisory liquidity reports, the Complex Institution Liquidity Monitoring Report (FR 2052a) and the Liquidity Monitoring Report (FR 2052b). In the letter, the associations suggest a number of recommendations that would more closely conform these liquidity reports with the requirements of the Liquidity Coverage Ratio (LCR) and international standards.

  • Industry Supports Total Loss Absorbency Requirement to Help Ensure G-SIBs Can Be Resolved in an Orderly Manner without Taxpayer Assistance

    Today, The Clearing House Association (TCH), in coordination with ABA, FSR, and SIFMA, filed a letter with the Financial Stability Board in response to its proposal to impose a total loss absorbing capacity (TLAC) requirement on global systemically important banking groups (G-SIBs). The letter expresses the industry’s strong support for a TLAC requirement for G-SIBs to help ensure that these institutions can be resolved in an orderly way at creditor rather than taxpayer expense, bringing us one final step closer to ending “Too Big to Fail.”

  • TCH Provides Recommendations to Basel Committee on its Updated Bank Corporate Governance Principles

    Late last Friday, The Clearing House Association (TCH) filed a comment letter with the Basel Committee on Banking Supervision in response to its “Corporate Governance Principles for Banks” consultative document, which the Basel Committee published for public comment in October 2014.  In the letter, TCH recommends certain changes designed to better delineate the board of directors’ responsibility for oversight of the business of a bank as distinct from management’s responsibility for the day-to-day operations, clarify the nature of director fiduciary duties, and reinforce the importance of giving each banking organization sufficient flexibility to tailor its governance practices to its business and risk profile.

  • The Clearing House to Undertake a Multi-Year Effort to Design and Develop a Secure, Real-Time Payment System

    On October 22, TCH and its Owner Banks announced plans to undertake a multi-year effort to build a real-time payment system to better meet consumers’ and businesses’ expectations in an increasingly digital economy. The real-time payment system will be designed to address gaps in payment options and will enable consumers and businesses to securely send and receive immediate payments directly from their accounts at financial institutions. Implementing ubiquitous real-time payments is a comprehensive multi-year endeavor, requiring coordination among financial institutions of all sizes and their service and technology providers. The innovative real-time system will be designed to address unmet customer needs and allow them to initiate payments directly from their bank accounts in a safe and secure manner.

  • TCH Comments on ISDA Announcement Concerning Progress on Cross-Border Bank Resolutions

    On October 11, The Clearing House welcomed the International Swaps and Derivatives Association’s (ISDA) announcement that large global banks with significant cross-border trading activities have voluntarily agreed to implement contractual changes that, in a resolution context, will provide for temporary restrictions (or stays) on early termination rights of derivatives counterparties.  These contractual changes are contained in a new protocol that the industry developed through ISDA.
  • The Clearing House Files Comment Letter on Proposed Bank Secrecy Act Customer Due Diligence Requirements

    Late Friday, The Clearing House Association (TCH) submitted a comment letter to the Financial Crimes Enforcement Network (FinCEN) on its proposal to adopt rules under the Bank Secrecy Act to specify customer due diligence requirements for banks and other financial institutions. In the letter, TCH reaffirmed its longstanding support for thoughtful, well-tailored customer due diligence requirements designed to detect and prevent financial crimes, and recognized many of the improvements FinCEN made since the rule was originally considered in 2012. The letter also details a number of suggestions on how to further improve and clarify the proposed rule for maximum effectiveness.
  • TCH Updates Guiding Principles on Corporate Governance and Anti-Money Laundering

    The Clearing House Association (TCH) today released two updated guiding principles drafts as part of an effort to assist banks as they work to address two timely issues facing the industry. The first, Guiding Principles for Enhancing Banking Organizations’ Corporate Governance, updates TCH’s previous guiding principles on the issue published in 2012.  The guiding principles are intended to provide banking organizations direction on core corporate governance issues. The second, Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking, last published in 2002, is intended to provide guidance to U.S. banks engaged in foreign correspondent banking and to assist U.S. banks in implementing key anti-money laundering (AML) obligations.

  • The Clearing House Comments on Liquidity Coverage Ratio Rule

    The Clearing House appreciates the agencies’ effort to provide greater clarity in today’s final rule on implementing the Basel III liquidity coverage ratio (LCR), which is intended to ensure that banks have sufficient short-term liquidity to survive a period of stress.

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