The Clearing House filed a comment letter with CPSS and IOSCO commenting on their Assessment Methodology for the Oversight Expectations Applicable to Critical Service Providers.  The letter opposes adoption of the proposal on the grounds that: (i) U.S. regulators have no authority to enforce the standards on critical service providers; (ii) FMIs do not have the market power to enforce these standards on their critical service providers; (iii) the proposed assessment methodology is too rigid and inflexible; and (iv) FMIs already monitor key performance metrics of critical service providers.