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.

This working paper says payments systems need to evolve to deliver new value to users, support appropriate risk management, and reward innovation and investment.

The Clearing House (TCH) today announced that it is teaming with FIS^TM to deliver a ubiquitous real-time payment system for the United States.

Today, The Clearing House (TCH) announced it has entered into a letter of intent with VocaLink, the UK-based international payment systems provider, to help build and deliver core elements of TCH’s new real-time payment system for the United States. 

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.

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. 

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 (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.

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’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 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. 

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.

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.

The Clearing House submitted a comment letter to FinCEN requesting guidance that will better enable banks to share suspicious activity reports (SARs) within their international organizations for enterprise-wide AML compliance purposes.

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.

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.

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.”

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 welcomed NACHA’s proposal to move toward a ubiquitous, same-day ACH settlement capability. Together with today's already efficient ACH, Same Day ACH and real-time payments will provide distinct payment options for customers.

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.

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 Association (TCH) submitted a comment letter to the U.S. banking agencies expressing general support for the agencies’ proposed revisions to the supplementary leverage ratio and providing suggestions for additional improvements.