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  • The Clearing House Publishes New Anti-Money Laundering Report

    The Clearing House released a report entitled A New Paradigm: Redesigning the U.S. AML/CFT Framework to Protect National Security and Aid Law Enforcement.  The paper analyzes the current effectiveness of the AML/CFT regime, identifies fundamental problems with that regime, and proposes a series of reforms to remedy them.

  • New Research Estimates Credit Allocation Encouraged by CCAR Stress Tests

    The Clearing House research note finds that the Federal Reserve’s CCAR stress test is imposing dramatically higher capital requirements on certain asset classes – most notably, small business loans and residential mortgages – than Basel standardized models and banks’ internal models that are approved by the Federal Reserve.

  • Financial Trade Associations Ask Bank Regulators to Reconsider NSFR

    The Clearing House, along with the Securities Industry and Financial Markets, Financial Services Roundtable, American Bankers Association, Institute of International Bankers and  CRE Finance Council submitted a comment letter to bank regulators Friday on the proposed Net Stable Funding Ratio (“NSFR”) rule.  In the letter, the Associations express continued support for the maintenance of stable funding and liquidity profiles by banks, but urge that the NSFR not be implemented in the United States without an analytically sound rationale that considers its marginal benefits and economic costs.

  • Custody Services Provided by Banks are Important to the Safekeeping and Management of Investments

    The Clearing House today issued a white paper, The Custody Services of Banks, which describes the role of bank-chartered custodians.  The paper discusses the services provided by bank-chartered custodians, their relationships with financial market utilities (FMUs), and describes the different risks associated with custody services in comparison to those associated with other banking activities.

  • Single-Counterparty Credit Limit Reproposal Could Be Further Improved

    The letter to the Federal Reserve on its reproposal of the single-counterparty credit limit (SCCL) requirement of the Dodd-Frank Act, notes substantial improvements included in the March 2016 reproposal, and details some problematic aspects that still remain that could make the rule needlessly difficult to implement and in some instances unworkable.

  • Industry Files Comment Letter on Standardized Measurement Approach to Operational Risk

    In the letter, to the Basel Committee on Banking Supervision, the associations affirmed their support for the proposed withdrawal of the Advanced Measurement Approach framework.  The letter also offered recommendations on changes that would make the proposed standardized measurement approach more risk-sensitive and reflective of the current banking operational risk environment.


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