TCH Association filed an unsolicited comment letter with the FRB, FDIC and OCC on certain calculation issues raised by Basel III with respect to the treatment of deferred tax assets (“DTAs”). TCH recommends that: (i) the rules for the treatment of DTAs previously adopted by a bank’s regulator be retained, except to the extent they have been specifically overridden by Basel III; (ii) DTAs realizable via loss carrybacks do not rely on the future profitability of the bank and therefore should be treated as valid assets for regulatory capital purposes; (iii) an election be permitted to net deferred tax liabilities (“DTLs”) associated with mortgage servicing rights (“MSRs”) against the MSRs before the MSRs are subjected to the 10% and 15% “threshold calculations”; (iv) (a) the 10% threshold calculation be made separately for each item, without reduction for any of them and (b) during the transition period, the 15% calculation be made without reduction for each item; and (v) that the transition framework ensure consistent treatment across jurisdictions.