The Clearing House Association, joined by several trade association partners, submitted a comment letter on the Federal Reserve Board’s Dodd-Frank Sections 165/166 proposal for foreign bank organizations (FBOs). The letter focuses on concerns with the basic policy approach to host-country regulation of international banks. The letter recommends, among other things, that international bank regulation be based on a general policy of international regulatory cooperation while avoiding a ring-fenced, balkanized approach to FBO regulation in the United States. Furthermore, the Board should adopt a more flexible approach for global institutions based on deference to effective home-country regulators and regulatory schemes.