The Clearing House Association sent a comment letter to the FDIC in response to the FDIC's notice of proposed rulemaking implementing certain orderly-liquidation-authority provisions of the Dodd-Frank Act. The Association requests that the FDIC provide clear confirmation that it stands fully behind the statutory mandate that creditors and counterparties of a covered financial company fare no worse in a Dodd-Frank liquidation than they would in a Chapter 7 bankruptcy proceeding. TCH also stresses the importance that the regulations be fully coordinated with the other terms and goals of Dodd-Frank and the vast array of regulations that the various agencies are adopting to govern the conduct of business under the Act, particularly the heightened regulatory regime for systemically important financial institutions (SIFIs). On January 18 the FDIC Board of Directors approved an interim final rule clarifying how it will treat certain creditor claims under the new Dodd-Frank orderly liquidation authority. The interim final rule differs from the FDIC's October 19, 2010, proposed rule in that it clarifies the standard for valuation for collateral on secured claims and revises the provision relating to treatment of contingent claims.