The Clearing House Association submitted a comment letter to FASB and IASB on their joint proposal on revenue recognition. In the comment letter, TCH requests a meeting with the FASB and IASB Boards to discuss the potential application of the proposal to the credit card reward programs, and to understand the relevance of contract assets to the commercial banking industry. TCH also recommended that: (i) financial instruments be excluded from the proposal, (ii) netting of underwriting revenues and expenses be continued, (iii) onerous contracts be assessed at the customer level, (iv) the onerous loss calculation be based on incremental direct costs to fulfill the obligation, and (v) the boards adopt a principles-based approach to disclosures.