The Clearing House Association along with five other trade associations filed a letter with the FRB urging the Board to extend the deadline for comments on its proposed rule implementing the enhanced prudential standards and early remediation requirements mandated by Sections 165 and 166 of Dodd-Frank, for foreign banking organizations and foreign nonbank financial companies. As a result of the tremendous breadth, complexity, potential interrelationships and importance of the proposed rule the trade associations asked the Board to extend the comment period for 60 days, from March 31 to May 30. The associations are concerned that the existing deadline for comments does not provide sufficient time to perform the level of analysis that this proposal merits, or to achieve an adequate understanding of the implications and potential consequences of the proposed rules.