The Clearing House Association supports the OCC’s approach to measuring credit exposures arising from derivative and securities financing transactions – an approach which generally allows a bank to choose between a regulator-approved internal model or a non-model measurement methodology. However, TCH urges the OCC to clarify how internal models will be approved, and to provide banks with additional flexibility as to which non-model methodology they choose to apply. In addition, TCH believes that an extension of the compliance date until October 1, 2013 is necessary and appropriate for various reasons, including that banks need time to incorporate the rule into bank systems and to develop necessary compliance programs and policies.