The Clearing House Association and Payments Company filed a comment letter responding to the FSOC NPR on the criteria, processes, and procedures for the designation of FMUs as systemically important. While not taking specific issue with the criteria, processes, and procedures outlined, The Clearing House provided additional information on why EPN and IPN do not fit the criteria for designation as systemically important under Title VIII and the FSOC proposed rule. On July 18 the FSOC approved a final rule addressing the criteria and process for designation of financial-market utilities (FMUs) under Title VIII of Dodd-Frank. Under the rule the FSOC will use a two-step process to designate FMUs. In the first stage the FSOC will use quantitative data to identify a preliminary set of FMUs, and in the second stage it will conduct a closer examination of quantitative data and particular characteristics to designate FMUs.