The Clearing House Association (TCH) submitted a comment letter to the Board of Governors of the Federal Reserve System (Fed) in response to the Fed’s advanced notice of proposed rulemaking (ANPR) guiding financial holding companies (FHCs) physical commodities activities – specifically the portion that provides for merchant banking activities. TCH’s letter argues that based on the longstanding success of FHCs at managing the risks associated with all types of merchant banking activities, the existing prudential framework for these activities is robust and effective and thus provides no reason for a fundamental revision of this framework.