The Clearing House Association filed a comment letter with the FSOC in response to an ANPR regarding the criteria that should be applied under § 804 of Dodd-Frank to designate financial-market utilities as systemically important. In the letter TCH indicates its support for the purposes of Title VIII but also sets forth its belief that only the largest interbank-payment systems pose the type of systemic risk contemplated by Title VIII. The designation of lower-value payment systems, such as PayCo’s EPN and IPN under Title VIII, would only add additional layers of regulatory oversight without commensurate benefits in mitigating systemic risk and would be beyond the scope of Title VIII.