The Clearing House Calls on the Federal Reserve to Rethink and Add Procedural Protections to Proposed Countercyclical Buffer
In a letter to the Federal Reserve Board, The Clearing House (TCH) calls for the proposal for implementing a countercyclical capital buffer to be revised to ensure that any future decision to establish a countercyclical capital buffer is subject to notice-and-comment rulemaking, as required by the Administrative Procedure Act. The letter also suggests that the proposal be empirically grounded.