The Clearing House Association filed a comment letter with the FRB, FDIC, OCC, SEC, FHFA, and HUD in response to the recently re-proposed risk retention rule under §941 of Dodd-Frank. In the comment letter, which focuses exclusively on how the risk retention requirement would apply to CLOs, TCH explains that the revised proposal’s shift of risk retention requirements to the lead arrangers of eligible commercial loans would be neither workable nor actually used in practice. Additionally, it argues that the proposal could result in a contraction of credit available to non-investment grade commercial borrowers that in turn could cause the sort of economic harm that §941 was crafted to avoid.