The Clearing House Association led a coalition of fellow trade associations in responding to the Fed’s capital planning NPR. The comment letter advocates for: (i) changes to the proposed process, (ii) clarifications that would permit firms to make uninterrupted capital distributions, and (iii) related substantive requests pertaining to the timing and amount of distributions. On November 29, 2011 the Federal Reserve Board published in the Federal Register a final rule requiring top-tier U.S. bank holding companies with total consolidated assets of $50 billion or more to submit annual capital plans for review.