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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 and SIFMA Raise Financial Stability Concerns Created by the EU’s Proposed ‘Payments Moratorium’

Oct 31, 2017

The Clearing House and Sifma on October 31, 2017 submitted a letter to US Treasury Secretary Steven Mnuchin as chairman of the US Financial Stability Oversight Council raising financial stability concerns created by the EU’s proposed “payments moratorium,” and asking Treasury and the US banking agencies to raise these concerns at the FSB and the EU-US regulatory dialogue scheduled for early November 2017. 

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TCH Files Joint Association Letter to the DOL on Its Overtime Pay Rule

Sep 25, 2017

The Clearing House (TCH) letter to the Department of Labor asserts that: using a uniform nationwide salary test promotes simplicity and reduces administrative burden; permitting all bonuses and incentive payments to count toward salary levels is appropriate; avoiding automatic updating to the salary level helps ease compliance burdens; and modernizing the test for highly compensated employees makes sense, as does permitting part-time employees to satisfy a prorated salary-level test.

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TCH Offers Recommendations for Volcker Rule Reform

Sep 21, 2017

In a comment letter filed with the OCC, the Clearing House (TCH) made recommendations regarding how to more effectively implement the Volcker Rule to better promote lending, banking services, and vibrant capital markets while still ensuring it meets its objective of reducing risk and enhancing bank safety and soundness by restricting excessive risk-taking activities by banks and their affiliates.

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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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