The Clearing House Association submitted a joint letter with ABA to the OCC regarding its interim final rule proposal to amend lending limits rule to include credit exposures arising from derivative and securities financing transactions. The letter clarifies the Member Banks’ positions on the methods for measuring securities financing transactions contained in the rule, expressed in the joint trades’ August 6 letter. The clarification letter argues that when measuring securities financing transactions, banks should be allowed to use the Basel Collateral Haircut Approach.