The Clearing House Association submitted a comment letter responding to the FinCEN’s proposal to implement 104(e) of the Comprehensive Iran Sanctions, Accountability, and Divestment Act (CISADA). TCH recommended ways to improve the proposal, including, eliminating or clarifying the need for a U.S. bank to certify the foreign bank’s response, and clarifying that a foreign bank’s failure to respond to the inquiry would not, by itself, require the U.S. bank to close the foreign bank’s correspondent account. On October 11 the Treasury and FinCEN released the final CISADA reporting requirements under Section 104(e) rule. The rule requires a U.S. bank that maintains a correspondent account for a foreign bank to inquire of the foreign bank, and report to FinCEN certain information with respect to transactions or other financial services provided by that foreign bank. Under the rule, U.S. banks will only be required to report this information to FinCEN upon receiving a specific written request from FinCEN.