The Clearing House Association submitted a comment letter to the FASB and IASB in response to their proposal on netting. TCH believes that (i) net presentation provides a superior presentation of an enterprise’s liquidity and credit risk for derivatives and certain securities financing contracts than gross presentation; (ii) there is no compelling reason to further limit the availability of net presentation; and (iii) the Boards should consider the effect of the proposal on financial ratios and other charges that are based on total assets and total liabilities. TCH also encourages the Boards to consider the significant operational costs of compliance, as well as two alternative approaches, netting for certain derivatives and the linked presentation approach.