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The Clearing House Association (TCH) submitted a comment letter to the U.S. banking agencies expressing general support for the agencies’ proposed revisions to the supplementary leverage ratio and providing suggestions for additional improvements.
An independent research report commissioned by The Clearing House Association and released today measures too-big-to-fail (TBTF) effects from 2009-2013 based on differences in market spreads for senior unsecured bonds issued by U.S. bank holding companies. Authored by John Lester and Aditi Kumar of Oliver Wyman, the report finds no evidence of TBTF effects on large bank funding costs.
The Clearing House Association (TCH) submitted a comment letter to the Office of the Comptroller of the Currency (OCC) today in response to the agency’s January 2014 proposed guidelines that would establish minimum standards for risk governance and bank boards of directors for banks with $50 billion or more in total consolidated assets. In its letter, TCH reiterates its strong support for the primary objective of the guidelines – a strong and effective risk management framework for banks – but recommends clarification of certain key aspects of the proposed guidelines in order to ensure that they achieve their stated purpose.
An independent research report, commissioned by The Clearing House Association, and authored by a leading global management consulting firm Oliver Wyman, found that money market deposit rate advantages for the largest banks were just four basis points at the end of 2012. Further, the study found evidence that this small difference may not be attributable to TBTF perceptions – that is, potential perceptions among market participants that the government would intervene to prevent the failure of a large financial institution.
The Clearing House applauds the Administration’s call to the nation’s community of key innovators to enhance and support the USPTO. In response, The Clearing House pledges to develop educational materials and host education sessions with USPTO patent examiners with a focus on the most critical components of our financial infrastructure.
The Clearing House is proud to be a part of a new partnership between the financial services trade associations and retailer groups to address cyber-criminal attacks on the payments system.
TCH led a joint industry effort to comment on the U.S. LCR proposal, authoring a comprehensive comment letter that strongly supports U.S. implementation of the LCR as an important step in strengthening the resiliency of banks and the stability of the financial system.
The Clearing House Association (TCH) submitted a comment letter to the Bank of England (BOE) in response to the BOE’s October 2013 discussion paper outlining a proposed stress testing framework for the UK banking system.
The Clearing House Association (TCH) today released a quantitative study on the Basel Committee’s proposed standard to regulate large counterparty exposures, which finds that the proposal would impose significant constraints on important bank counterparty relationships, thereby impacting the ability of banks to service their customers.
The Clearing House finds that U.S. and Basel proposals would make leverage ratio the binding constraint for the banking industry.