The Clearing House Association submitted a comment letter to the FASB on its exposure draft on credit losses. The letter encourages the U.S. and international accounting standard setters to continue their efforts to achieve convergence on impairment and believes there are significant concerns with the FASB proposal. TCH recommends that the period over which losses are estimated should be equal to the greater of 12 months or the period that is reliably estimable and predictable, rather than the remaining life of the financial assets, with appropriate disclosure of the relevant time periods. Additionally, the letter expresses concerns about the interaction of certain aspects of the FASB proposal with current and proposed regulatory capital rules, including the likely reduction in regulatory capital for advanced approaches banks and potential constraints on dividend capacity of BHCs, and recommends careful joint consideration of these unintended negative consequences by the FASB and the banking agencies.