The Clearing House Association filed a comment letter with the FDIC on its proposal implementing assessment rate adjustment guidelines for large and highly complex institutions. The letter raised several concerns with the proposal and suggested that the FDIC use its discretionary authority for upward adjustments rarely and only in clearly compelling circumstances and that any upward adjustment should require concurrence by an institution’s primary regulator. TCH also asked the FDIC to explain the rationale for any upward adjustment and to adjust downward the assessments for firms that pose less risk to the insurance fund.