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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 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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Trades File Merchant Banking Comment Letter

Feb 21, 2017

The Clearing House (TCH) along with the ABA, the Financial Services Forum, FSR and IIB filed a comment letter with the Federal Reserve on its proposed rule that would, among other things, impose increased risk-based capital charges on merchant banking investments in companies engaged in physical commodities activities.

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TCH Publishes New Anti-Money Laundering Report

Feb 16, 2017

The Clearing House (TCH) released a report entitled A New Paradigm: Redesigning the U.S. AML/CFT Framework to Protect National Security and Aid Law Enforcement. The paper analyzes the current effectiveness of the AML/CFT regime, identifies fundamental problems with that regime, and proposes a series of reforms to remedy them.

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TCH Releases Guiding Principles for Sanctions Issues Related to Shipping and Financial Products

Feb 10, 2017

Guiding Principles for Sanctions Issues Related to Shipping and Financial Products is the product of the BAFT/TCH Sanctions Working Group, which is comprised of sanctions experts in the world’s leading U.S. and international financial institutions regulated in the United States.  The principles seek to assist financial institutions by distinguishing between types of shipment-related transactions that should and should not be considered to be prohibited by OFAC regulations due to their nexus to sanctioned countries or ports.  The principles also recommend practical compliance practices for financial institutions that deal with such issues.

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