The Clearing House Association and its trade association partners filed a letter with the CFTC to address its separate NPR implementing the Volcker Rule. This letter reiterates and references previous comments made in joint-trade letters, while also focusing on the sizeable cost-benefit issues that were improperly assessed in the Volcker Rule proposal, the effect of the CFTC’s proposal on swaps markets with a particular emphasis on the fact that the proposal does not fully account for the market making activity of swap dealers, the importance of interaffiliate transactions to risk management, and the overly broad definitions for key terms that are incorporated into the proposal. Based on these serious concerns, the Associations have asked the CFTC to repropose this rule.