The Clearing House Association filed an amicus brief in Federal Housing Finance Agency v. JPMorgan Chase & Co. in support of JPMC’s motion for a protective order in the FHFA’s attempt to obtain files relating to mortgages sold to Fannie Mae and Freddie Mac from JPMC’s financial integrity unit, which examines transactions and accounts for possible criminal activity. TCH’s brief takes the position that the plain language of FinCEN and OCC regulations supports a broad exemption for any work product related to a decision of whether or not to file a SAR and that these rules serve important public policy concerns in that disclosing such work products could tip off criminals that their transactions are subject to scrutiny or give criminals information on what banks are looking for and thus enable them to avoid detection.