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TCH Responds to the Federal Reserve’s Proposed Amendments to Its Internal Appeals Process and to Its Ombudsman Policy

The Clearing House (TCH), joined by the FSR, filed a comment letter responding to the Federal Reserve’s proposed amendments to its internal appeals process for material supervisory determinations and to its Ombudsman Policy. Among other recommendations, the letter recommends that the Federal Reserve (i) confirm that MRAs/MRIAs are appealable through the appeals process, (ii) allow firms to appeal directly to the agency’s Ombudsman rather than having to appeal to the Reserve Bank involved in the issue being appealed, and (iii) ensure that any publicly released decisions do not allow the relevant institutions to be identified.