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  • 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.

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