The Clearing House Association submitted a comment letter to the FASB on its lease accounting proposal, recommending that the Board not proceed with the Proposal, but instead engage in additional outreach with the investor community to develop a new, simplified approach that is more clearly acceptable to investors. TCH is concerned that the Proposal is overly complex, does not give investors and analysts the information they need to determine a company’s financial health, and is not an improvement over current financial reporting.