The Clearing House Association, along with three other trade associations, submitted a comment letter to the regulatory agencies on the proprietary trading provisions of the proposed rules implementing the Volcker Rule. The associations stress the importance of market-making, underwriting, risk-mitigating hedging, and other customer-focused and specifically permitted activities and argue that these exceptions should be expanded and strengthened, while at the same time avoiding artificial bright-line distinctions between permitted activities and prohibited proprietary trading. The associations also believe it would be prudent for the agencies to repropose the Volcker Rule, as well as develop a phased-in approach to its application and specially articulate how the agencies plan to coordinate interpretation, examination and enforcement of its provisions.