The Clearing House Association filed a comment letter responding to the Financial Stability Board’s consultative document on effectively resolving systemically important financial institutions. The letter strongly supports the underlying conclusion that reforms of domestic resolution regimes and cross-border resolution frameworks need to accelerate to ensure that, within a reasonable timeframe, SIFIs can be resolved without systemic disruption or exposing taxpayers to the risk of loss. The associations address a number of the FSB’s recommendations, including duties of the relevant authorities, rules governing creditor rights, resolution planning, cross-border cooperation and consensus, confidentiality of plans and transparency of processes and actions, resolvability assessments, local-depositor preference laws, implications for G-SIFI surcharges, implementation timelines and various resolution tools such as recapitalization.