The Clearing House Association (TCH) filed a comment letter with the OCC on its proposal to expand to all national banks the current reporting requirement for small national banks to file annual Money Laundering Risk (MLR) reports on their high-risk products, services, customers, and geographies and use this information to determine how to allocate its examination resources. TCH urged the OCC to forgo the proposal as TCH does not believe that the benefits of the proposal would outweigh its negative effects.