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TCH Responds to Comment Request Regarding Regulation J Proposal

The Clearing House (TCH) submitted a joint letter with the ABA, NAFCU, and CUNA regarding the recent proposal to revise Regulation J. The proposal would align Regulation J (Subpart A), which governs check collection through the Federal Reserve Banks, with the revisions to Regulation CC that reflect the virtually all electronic check collection system. Additionally, the proposal would revise Regulation CC (Subpart B) to clarify that messaging standards used in Fedwire do not confer legal status or responsibilities. The comment letter generally supported both aspects of the proposal, as they are consistent with the approach TCH has taken to revise the ECCHO Rules that govern private sector check image exchange, and a rule TCH has adopted regarding the messaging standards used in RTP.