The Clearing House Association submitted an industry comment letter to the FDIC on the proposed definitions of higher-risk consumer and commercial and industrial loans and securities used in the large bank pricing (LBP) rule for assessments. The Associations commended the FDIC for their willingness to work with the industry on these definitions, but also provided recommendations to add to the clarity and workability of the definitions. The FDIC’s final rule, approved on October 9, incorporates the definitions used to identify concentrations in higher-risk assets to better reflect the risk to institutions and the FDIC, accommodating many changes requested by TCH in our joint trade comment letter, including: (i) that a $5 million threshold be part of the purpose test, (ii) the look back at purpose and materiality of debt should apply only when currently outstanding debt is refinanced, and (ii) the look back period is only five years.