In the News

• The Clearing House Files Comment Letter on Proposed Bank Secrecy Act Customer Due Diligence Requirements

  October 06, 2014

  Late Friday, The Clearing House Association (TCH) submitted a comment letter to the Financial Crimes Enforcement Network (FinCEN) on its proposal to adopt rules under the Bank Secrecy Act to specify customer due diligence requirements for banks and other financial institutions. In the letter, TCH reaffirmed its longstanding support for thoughtful, well-tailored customer due diligence requirements designed to detect and prevent financial crimes, and recognized many of the improvements FinCEN made since the rule was originally considered in 2012. The letter also details a number of suggestions on how to further improve and clarify the proposed rule for maximum effectiveness.

• TCH Files Comment Letter on Proposed Changes to the FDIC’s Deposit Insurance Assessments

  September 22, 2014

  The Clearing House Association (TCH) today filed a comment letter with the Federal Deposit Insurance Corporation (FDIC) on its proposed rule regarding changes to the deposit insurance assessment calculation methodology.  In the letter, TCH reiterates its support for maintaining a robust federal deposit insurance fund (DIF), but expresses concern that the proposed rule is inconsistent with the statutory requirement that assessments be based on actual risk to the DIF.

• TCH Appoints Paige Pidano as Managing Director and Associate General Counsel

  September 15, 2014

  The Clearing House Association (TCH) today announced that Paige Pidano is joining the organization as Managing Director and Associate General Counsel. In her new role she will serve on TCH’s legal and regulatory affairs team and assist in the development of bank regulatory policy, strategy and advocacy.

• TCH Updates Guiding Principles on Corporate Governance and Anti-Money Laundering

  September 10, 2014

  The Clearing House Association (TCH) today released two updated guiding principles drafts as part of an effort to assist banks as they work to address two timely issues facing the industry. The first, Guiding Principles for Enhancing Banking Organizations’ Corporate Governance, updates TCH’s previous guiding principles on the issue published in 2012.  The guiding principles are intended to provide banking organizations direction on core corporate governance issues. The second, Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking, last published in 2002, is intended to provide guidance to U.S. banks engaged in foreign correspondent banking and to assist U.S. banks in implementing key anti-money laundering (AML) obligations.

• The Clearing House Comments on Liquidity Coverage Ratio Rule

  September 03, 2014

  The Clearing House appreciates the agencies’ effort to provide greater clarity in today’s final rule on implementing the Basel III liquidity coverage ratio (LCR), which is intended to ensure that banks have sufficient short-term liquidity to survive a period of stress.

• TCH Files Comment Letter on Proposed Amendments to the Capital Plan and Stress Test Rules

  August 11, 2014

  The Clearing House Association comment letter to the U.S. banking agencies reiterates TCH’s continued support for strong capital planning, and welcomes the agencies’ revisions to important aspects of the capital plan and stress test rules in a manner that resolves several areas of on-going industry concern.

• TCH Association President Paul Saltzman Calls for Greater Individual Accountability in Banking

  August 06, 2014

  At the event, co-sponsored by The Clearing House Association (TCH) and the Center for Financial Policy at the Robert H. Smith School of Business at the University of Maryland, Mr. Saltzman called for a collective renewed focus on clear, prescriptive, and transparent rules that effect behaviors and produce substantive outcomes.

• TCH President Paul Saltzman Responds to GAO Testimony Concluding Large Bank Funding Advantages Have Been Significantly Reduced or Reversed

  July 31, 2014

  The GAO appears to confirm what The Clearing House Association and others who have carefully considered this issue already knew -- cost of funding differences among banks of different sizes have significantly declined or been reversed, suggesting that TBTF perceptions have substantially diminished.

• TCH Research Assesses Funding Costs for Large Banks

  July 28, 2014

  In the third paper in its Working Paper Series on the Value of Large Banks, The Clearing House examines existing academic literature on bank funding costs, noting the significant decline in large bank funding advantages post implementation of Dodd-Frank reforms.

• TCH Files Comment Letter on Fed’s Proposed Rule for the Dodd-Frank Financial Sector Concentration Limit

  July 08, 2014

  The Clearing House Association, joined by the American Bankers Association and Financial Services Roundtable, submitted a comment letter to the Federal Reserve on its proposed rule to implement Section 622 of the Dodd-Frank Act. The letter stresses the practical importance of ensuring that Section 622 is implemented in a manner that is transparent, predictable and, most importantly, avoids unnecessary and unintended restrictions on ordinary course business activity that falls outside of Section 622’s intended scope.