The Clearing House Association filed a comment letter that urged the FTC not to adopt its proposed rule to ban telemarketers from using remotely created checks and remotely created payment orders, as the rule would be overly broad and potentially harmful to the U.S. payment system. TCH expressed that the proposed rule would not deter bad actors from initiating fraudulent transactions and would create an unrealistic regulatory expectation that financial institutions or payment system operators police the ban when there is no technical means to do so.