The Clearing House Association submitted a comment letter to the IASB and the FASB on IASB’s exposure draft on hedge accounting. TCH recommends that (i) the IASB and FASB align hedge accounting with the economics of hedging transactions in a converged model; (ii) the Board permit dedesignation of hedge accounting relationships and hedge accounting if the risk component is separately identifiable and reliably measurable; (iii) the Board reconsider the accounting for hedging credit derivatives and the hedge accounting model for macro-hedging; and (iv) the proposed disclosures remain principles-based. Additionally, TCH objects to the proposed hedge effectiveness requirements and does not support the proposed presentation changes for fair value hedges.