The Clearing House Association filed a comment letter to the Fed in response to its proposed rule pursuant to §318 of Dodd-Frank, which would call for an annual assessment of BHCs with $50B or more in assets and designated nonbank SIFIs in order to cover the Fed’s costs to carry out its supervisory and regulatory responsibilities for these companies. 

TCH is concerned about a lack of transparency and disclosure of the Fed’s supervision expenses, which are the basis for the proposed assessments, and has asked the Fed to release the procedures, accounting, and methodology it employs to determine the assessment basis. 

Additionally, TCH has asked the Fed to ensure that expenses incurred to supervise functionally regulated subsidiaries are not included in the assessment bases. Finally, TCH seeks to ensure that the costs associated with supervising nonbank SIFIs, as well as the costs of designating them, are not borne by banks. Similarly, the letter asks the Fed to recognize, as part of its development of future assessments, the disproportionately higher cost that would be incurred in the supervision of nonbank SIFIs relative to banks. 

TCH recommends that the Fed consider postponing the commencement of the assessment program until 2014 in order to provide adequate time for the development, production, and possible public comment of further clarifying details about the Fed’s expenses and assessment methodology.