The Clearing House Association submitted a comment letter to the FDIC on a notice of interim final rule implementing certain provisions of the Dodd-Frank orderly-liquidation authority (OLA). The comment letter states that the comments made to the FDIC in our related November 18, 2010, and January 11, 2011, letters generally remain applicable. The letter urges the FDIC to consider three overarching goals as it develops OLA rules in the months ahead: (i) predictable, transparent, fair and well-integrated procedures, (ii) approaches and results reflecting those that would apply to a company under the Bankruptcy Code as well as creditor recoveries generally no less than those received thereunder, and (iii) regulations that reduce, or at least not enhance, the likelihood of failure in order to manage systemic risk while reducing moral hazard. On July 15 the FDIC published in the Federal Register a final rule under the Dodd-Frank orderly-liquidation authority. The changes from the interim final rule and the NPR affect the provisions that, with respect to a failed firm resolved under the authority, claw back compensation of an executive or director, prioritize payments, define “financial company,” and regulate the payments of claims, including the rights of secured claimants.