The Clearing House Association submitted a comment letter to FASB and IASB on FASB’s proposal on Consolidation: Principal versus Agent. TCH supports the proposal’s requirement to perform a qualitative analysis that requires the use of judgment to determine whether a decision maker is a principal or an agent, as well as certain other aspects of the proposal. TCH also made several recommendations to improve the proposal including (i) FASB issue guidance to state that no consolidation is required for certain securitization entities where there is no ongoing decision making ability, and (ii) that if an entity determines it is acting as an agent, no further analysis is required.