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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.
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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.The Clearing House Comments on Liquidity Coverage Ratio Rule
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TCH Files Comment Letter on Regulators’ Proposed Revisions to the Supplementary Leverage Ratio
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.
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TCH Letter to OCC on Proposed Heightened Standards Offers Support, Suggests Clarification of Certain Aspects of Proposed Guidelines
The Clearing House Association (TCH) submitted a comment letter to the Office of the Comptroller of the Currency (OCC) today in response to the agency’s January 2014 proposed guidelines that would establish minimum standards for risk governance and bank boards of directors for banks with $50 billion or more in total consolidated assets. In its letter, TCH reiterates its strong support for the primary objective of the guidelines – a strong and effective risk management framework for banks – but recommends clarification of certain key aspects of the proposed guidelines in order to ensure that they achieve their stated purpose.
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Financial Industry Associations Submit Comments to US Regulators on Liquidity Coverage Ratio
TCH led a joint industry effort to comment on the U.S. LCR proposal, authoring a comprehensive comment letter that strongly supports U.S. implementation of the LCR as an important step in strengthening the resiliency of banks and the stability of the financial system.
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TCH Expresses Support for Bank of England Efforts to Develop UK Stress Testing Framework
The Clearing House Association (TCH) submitted a comment letter to the Bank of England (BOE) in response to the BOE’s October 2013 discussion paper outlining a proposed stress testing framework for the UK banking system.
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TCH Study Highlights Significant Impact of U.S. and Basel III Leverage Ratio Proposals' Inappropriate Treatment of Certain Exposures
The Clearing House finds that U.S. and Basel proposals would make leverage ratio the binding constraint for the banking industry.
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TCH Study Highlights Significant Impact of U.S. and Basel III Leverage Ratio Proposals' Inappropriate Treatment of Certain Exposures
The Clearing House finds that U.S. and Basel proposals would make leverage ratio the binding constraint for the banking industry.
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America’s Leading Financial Institutions to Collaborate on the Safety and Soundness of Digital Payments
The Clearing House is working with the nation’s leading financial institutions to develop an industry-wide credentialing solution designed to help improve the future safety and soundness of digital payments.
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New Oxford Economics Study Confirms Negative Impact of Increased Bank Capital Levels on U.S. Economic and Job Growth
The Clearing House Association releases a study by Oxford Economics that reaffirms the expert consensus that increased capital and liquidity requirements on banks will have a negative impact on U.S. economic growth and future employment.