The Clearing House Association, along with five other trade associations, submitted a comment letter to the FRB, FDIC, and OCC addressing the agencies’ proposal to incorporate into their proposed market risk capital rules alternative methodologies for calculating specific risk capital requirements for debt and securitization positions that do not rely on credit ratings. The comment letter addresses (i) the associations’ concerns with respect to the proposed rule’s methodologies applicable to exposures other than securitizations and to securitizations, (ii) substantive concerns with the treatment of correlation trading positions under the proposed rule, and (iii) additional concerns with respects to the potential consequences of the proposed rule.