The Clearing House Association submitted a joint trade comment letter in response to the IRS Notice 2013-35 on Conclusive Presumption Regulations. TCH's letter requests that the IRS extend the conformity election to banks, BHCs and their non-bank subsidiaries, and certain other regulated financial institutions, examined by such institutions' primary supervisory authority or regulator and that the IRS follow the determinations made by such regulators. Additionally, the letter provides comprehensive responses to the questions set forth under Section 4 of the Notice.