The Clearing House Association filed a follow-up letter to the FASB responding to the FASB’s request for additional information with respect to (i) the volume discount approach for accounting for credit card interchange revenue and (ii) the interrelationship between fees and interest in regard to the assessment of onerous obligations for treasury management service contracts. In the March 2012 letter TCH 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.