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TCH Files Comment Letter Regarding the Banking Agencies’ Proposal to Simplify Regulatory Capital Rules

The Clearing House (TCH) filed a comment letter with the Fed, FDIC, and OCC on its proposal to extend the existing transitional regulatory capital treatment of certain items for banking organizations that are not subject to the advanced approaches capital rules until the agencies finalize a related rulemaking to simplify the regulatory capital treatment of these items. TCH strongly supports the agencies’ efforts, but argues that the proposed extension of the current regulatory capital treatment of the affected items should be extended to all banking organizations for purposes of calculating all relevant regulatory capital ratios (i.e., under both the standardized and advanced approaches capital rules) until the agencies have completed a comprehensive review of the regulatory capital rules.