The Clearing House Association filed a comment letter in response to FinCEN’s proposal to impose two special measures on JSC CredexBank under Section 311 of the USA PATRIOT Act: (i) reporting requirements under the first special measure, and (ii) restrictions on the use of U.S. bank correspondent accounts by Credex. TCH does not object to the imposition of the special measures, and recommend that the first special measure provide that: (i) covered financial institutions be required to report only those transactions in which Credex or an affiliate of Credex specifically identified by FinCEN appears in the transaction instruction as a party; and (ii) the report consist of a copy of the transaction instruction and a statement of how the institution disposed of the transaction. TCH does not object to the imposition of the fifth special measure, but asked FinCEN to move expeditiously to adopt the final rule.