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Advocacy

The Clearing House

The Clearing House Association is a nonpartisan organization that engages in research, analysis, advocacy and litigation focused on financial regulation that supports safe, sound and competitive banking and payment systems.  





Recent Highlights

TCH Files Comment Letter with FSB on Its Compensation Practices Consultation

Aug 30, 2017

In a response to the FSB’s consultation entitled Supplementary Guidance to the Principles and Standards on Sound Compensation Practices, The Clearing House (TCH) recommends that if the FSB proceeds with issuing internationally endorsed guidelines in this area, it should issue a revised consultation that recognizes the successful implementation of various public sector compensation frameworks, avoids the introduction of any new, specific standards, and provides bank boards and management with appropriate flexibility to maintain dynamic compensation practices that evolve over time to keep pace with legal, market, and risk-management developments.

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TCH Files Comment Letter on Proposal Revising Call Reports

Aug 22, 2017

The Clearing House (TCH) filed a comment letter with the OCC, Fed, and FDIC, responding to a proposal to revise FFIEC 051, FFIEC 041, and FFIEC 031 Call Reports. While TCH appreciates the Agencies’ efforts to reduce reporting burden, TCH opposes the proposed changes to the definition of past due and the scope of the 031, and offers several constructive suggestions to more meaningfully reduce reporting burden.

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TCH and FSR Submit Letter to Treasury on FinCEN and OFAC Regulations as Part of Review

Jul 31, 2017

The Clearing House (TCH) and FSR filed a letter with the Treasury Department on its Review of Regulations, which was issued under Executive Orders 13771 and 13777 to facilitate public review and recommendations regarding Treasury regulations and guidance, including those promulgated by FinCEN and OFAC, that could be “eliminated, modified, or streamlined in order to reduce burdens.”

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TCH Responds to SEC Proposal on Guide 3

Jun 29, 2017

TCH urges the SEC to significantly streamline Guide 3 so that it acts as a “gap filler” for U.S. BHCs, whereby items that provide meaningful information and are not otherwise required in SEC filings be retained and items that duplicate or overlap with U.S. GAAP, Regulation S-K or Regulation S-X disclosures, or do not provide meaningful information, be eliminated.

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TCH Responds to BCBS G-SIB Surcharge Assessment Methodology Proposal

Jun 27, 2017

The Clearing House (TCH) filed a comment letter with the BCBS in response to its Consultative Document on proposed changes to the G-SIB surcharge assessment framework.  In the letter, TCH expresses serious concerns about the proposed change to the substitutability category, which would disproportionately and adversely affect four U.S. banks.  TCH also details the broader framework’s conceptual and methodological flaws and calls for the BCBS to comprehensively revise the framework to reflect the actual systemic risks posed by G-SIBs, and thereby align it with its stated objectives. 

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TCH Files Comment Letter on LCR Disclosure Requirement

Jun 2, 2017

In the letter to the Federal Reserve, The Clearing House (TCH) requested that the Federal Reserve postpone the applicability of the disclosure requirements to any company for one-year to April 1, 2018 in order to avoid the potential negative effects of the requirements and to allow stakeholders additional time to further review and consider whether any such public disclosure requirements are necessary.

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TCH Responds to BCBS Step-in Risk Proposal

May 15, 2017

The Clearing House letter is supportive of the Basel Committee’s revisions to the proposed guidelines for the identification and management of step-in risk. However the letter notes numerous aspects of the proposal that need to be updated in order to achieve the Basel Committee’s objectives of sensitivity to residual step-in risk and simplicity of the framework. 

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TCH Files Amicus Briefs in State of Colorado v. Avant and State of Colorado v. Marlette

May 3, 2017

The Clearing House (TCH), joined by the ABA and the LSTA, filed two amicus briefs in U.S. District Court for the District of Colorado in connection with two cases brought by the State of Colorado against two marketplace lenders, Avant and Marlette, each of which purchases loans from a respective state-chartered bank partner. The amicus briefs argue (similar to our Madden amicus briefs) that: (i) Madden contradicts important, long-settled expectations concerning usury law, and (ii) adopting Madden would have harmful economic consequences. 

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TCH Submits Comment Letter on Capital Treatment for Fronting Commitments

Feb 28, 2017

In the letter to the Fed, OCC and FDIC, The Clearing House proposed that a fronting bank should include only the exposure amount corresponding to its pro rata share of the fronting commitment as an off-balance-sheet exposure for both risk-based capital purposes and for its total leverage exposure in calculating its supplementary leverage ratio.

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TCH & SIFMA Respond to the FDIC‘s NPR Re: QFCs Recordkeeping Requirements

Feb 27, 2017

The Clearing House (TCH) letter expresses support for harmonizing Part 371 (which requires troubled IDIs to maintain records related to their QFCs) with a similar QFC recordkeeping rule for large financial groups recently adopted by the Treasury Secretary, but identifies specific areas where the FDIC’s rules would continue to diverge from the Treasury’s Final Rule.

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