The Clearing House Association filed a comment letter with the Financial Stability Board on its consultative document, Application of the Key Attributes of Effective Resolution Regimes to Non-Bank Financial Institutions, which would specify how the bank-like orderly resolution regime advocated by the FSB should be applied to non-bank financial institutions, including payment systems and other financial market infrastructures (“FMIs”).  TCH stated that (i) troubled FMIs should be placed into extraordinary resolution regimes only if their failure could cause financial instability, (ii) owners of FMIs should not be required to pay in additional capital other than what they have agreed to in advance, and (iii) if an FMI is expected to continue to provide services to a SIFI in resolution, it must be assured that the SIFI will be able to meet its obligations to the FMI as they come due, and that this may require that the SIFI continue to have access to central bank payment and liquidity services.