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TCH Opposes Additional D-SIB Surcharge

The Clearing House (TCH) submitted a comment letter to the Basel Committee on its proposal addressing domestic systemically important banks (D-SIBs). While TCH believes that the negative externalities associated with banks perceived as too big to fail can be effectively addressed without the imposition of a punitive add-on capital surcharge for D-SIBs, TCH supports the principled approach contained in the proposal, particularly the inclusion of significant national discretion in the application of any D-SIB surcharge. Additionally, TCH requests that any surcharge contain calibration methodologies that are transparent and available for public review and comment, and that size not receive a disproportionate weighting as a factor for any D-SIB surcharge.