The Clearing House filed a comment letter on the Federal Reserve Board’s proposal to adopt the CPSS-IOSCO Principles for Financial Market Utilities as the standards applicable to systemically important financial market utilities, such as The Clearing House Payments Co. In general, the letter supports the proposed standards but takes strong exception to the proposed requirement that FMUs regulate their participants’ relationships with their correspondent banking customers under the guise of managing the risks associated with “tiered participation arrangements.” In addition, TCH opposes requiring FMUs to support vaguely defined “other public interest considerations,” suggests some clarifications to the requirements for minimum capital and liquidity standards, and supports a more extended implementation period.