The Clearing House Association submitted a joint comment letter with SIFMA, ABA and FSR responding to an NPR on implementing claims, processes and executive-compensation provisions under OLA. 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.