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TCH Comments on Sections 165/166 of the Dodd-Frank Act

The Clearing House Association filed its comment letter with the Federal Reserve Board, in conjunction with other financial trades, on the Board’s proposed rule to implement Sections 165/166 of the Dodd-Frank Act. The proposed rule covers single-counterparty credit limits, capital surcharges, liquidity requirements, early remediation, stress testing, and risk management. The data-driven letter offers technical corrections to avoid unintended consequences and achieve the shared goal of enhanced risk management. The associations also encourage regulators to take the necessary time to conduct a holistic review of these critical rules including the impact to consumers and the competitiveness of firms operating in the United States, and a cost/benefit analysis.