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.
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.
TCH Responds to NYDFS’s Revised Cyber Proposal for Financial Institutions
Jan 27, 2017
The Clearing House (TCH) filed a comment letter with the NYDFS responding to its revised proposal which would establish cybersecurity requirements for financial services companies that are authorized to do business in New York under the New York banking, insurance and/or financial services laws.
TCH-IIB File Amicus in Schwab v. Bank of America
Jan 20, 2017
In a joint amicus brief TCH and the IIB argue that: (i) Schwab’s position ignores that specific personal jurisdiction exists only where the defendant personally and purposefully engaged in suit-related conduct in the forum state; and (ii) adopting Schwab’s vicarious-jurisdiction theories would violate due process and could impermissibly subject member banks to jurisdiction everywhere.
TCH Submits Letter to OCC on Proposed FinTech Charter
Jan 17, 2017
The Clearing House (TCH) joined by SIFMA and the ICBA, submitted a letter to the OCC in response to its white paper on Exploring Special Purpose National Bank (SPNB) Charters for Fintech Companies.
TCH Responds to OCC Proposed Revisions to DFAST-14A
Jan 17, 2017
The Clearing House (TCH) submitted a comment letter to the OCC in response to its proposed revisions to the DFAST-14A.
TCH Responds to BCBS ECL Proposal
Jan 13, 2017
TCH submitted a comment letter to the Basel Committee in response to its proposal on the policy considerations related to the regulatory treatment of accounting provisions under the Basel III capital framework.
TCH Files Joint-Trades Supplemental Letter on NSFR
Dec 28, 2016
The Clearing House (TCH) comment letter highlights a number of differences between the EU’s NSFR Proposal and the U.S. NSFR Proposal, highlighting ten “primary differences” between the EU proposal and U.S. proposal.
TCH Files Joint-Trades Letter Responding to FDIC NPR Restricting Terms of QFCs
Dec 12, 2016
The Clearing House (TCH), along with SIFMA, the ABA, the FSF, the FSR, and the IIB commented on an FDIC NPR relating to restrictions on the terms of QFCs entered into by state savings associations and state nonmember banks (FSIs) that are part of U.S. banking organizations identified as G-SIBs or the U.S. operations of FBOs that are G-SIBs.
TCH-EY Publish Bank Innovation White Paper
Nov 29, 2016
The Clearing House (TCH) and E&Y released a white paper entitled “The digital bank: tech innovations driving change at US banks.” The paper addresses how banks are using technological innovation to improve products and services for customers, strengthen bank controls and drive down costs. It also discusses ways in which regulators can foster and encourage innovation.
TCH Files Comment Letter to Federal Reserve on Proposed Amendments to CCAR
Nov 23, 2016
The Clearing House (TCH) filed a comment letter with the Federal Reserve on the proposed amendments to the Capital Plan and Stress Test Rules. The comment letter supported the Federal Reserve’s proposal to eliminate the qualitative portion of CCAR for “large and noncomplex” firms and the proposed transition rules for firms crossing the $50B threshold.
TCH Files Comment Letter to FASB on Hedging
Nov 22, 2016
The Clearing House (TCH) filed a comment letter with the FASB on targeted improvements to accounting for hedging activities. The letter supported (i) proposed refinements to the accounting for the hedged item in fair value hedges of interest rate risk, (ii) proposed changes that allow more risk component hedging, and (iii) proposed improvements regarding the application of current guidance related to the assessment of hedge effectiveness.
TCH Files Comment Letter to FASB on Prepayable Debt
Nov 22, 2016
The Clearing House (TCH) filed a comment letter with the FASB on callable debt securities. The comment letter supports the proposed requirement that the premiums of callable debt securities, which are purchased at a premium, must be amortized to the earliest call date.
TCH Responds to NYDFS’s Proposed Cyber Rules
Nov 14, 2016
The Clearing House (TCH) responded to proposed cyber regulations (Proposal) issued by the New York Department of Financial Services (NYDFS).
Trades File Amicus Brief in FDIC v. First Horizon
Nov 7, 2016
The Clearing House (TCH), along with the ABA and SIFMA, filed an amicus brief in support of the defendants’ petition for certiorari in FDIC v. First Horizon.
Why Have Banks' Market-to-Book Ratios Declined?
Nov 1, 2016
A new TCH research note shows that most of the decline in price-to-tangible book value of equity in the post-crisis period is driven by the fall in banks’ profitability as measured by the return on tangible common equity (ROTCE). The TCH note also shows that both the decline in P/TBV and ROTCE is particularly pronounced for banks above $10bn in total consolidated assets. The note then explores possible explanations for this finding, including the role of major changes in regulatory policies.
TCH Submits Comment Letter Regarding SEC Disclosure Update and Simplification Amendments
Oct 28, 2016
The Clearing House (TCH) has submitted a comment letter to the SEC on its proposed disclosure update and simplification amendments.
TCH Joins Trade Comment Letter to CFPB Re: ‘Amendments Relating to Disclosure of and Records and Information,’ Including Confidential Supervisory Information
Oct 24, 2016
In the letter, The Clearing House (TCH), along with the FSR (and the FSR’s Housing Policy Council), the ABA, the CBA and the CCMC (Associations) express concerns with the proposed expansion of the Bureau’s ability to share Confidential Supervisory Information (CSI), including that the proposed expansion could increase litigation and reputational risk for financial institutions, undermine the vitality of the bank examination privilege, and potentially breach a supervised institution’s legal privileges should the materials be shared beyond the scope contemplated by Section 1828(x) of the FDI Act.
TCH Joins Trade Comment Letter to FSB on Essential Aspects of CCP Resolution Planning
Oct 21, 2016
In the letter, The Clearing House (TCH) long with the FIA, GFMA, the IIF, and ISDA express support for the Discussion Note, recognizing it as an important step towards addressing the financial disruption that could occur in the unlikely event that a CCP fails.
TCH and Other Associations Submit Comments to CPMI-IOSCO to Further the Safety and Soundness of CCPs
Oct 18, 2016
The Clearing House (TCH), along with the FIA, GFMA, the IIF, ISDA (Associations) filed a comment letter responding to a CPMI-IOSCO consultation on the Resilience and recovery of central counterparties (CCPs): Further guidance on the PFMI. The Associations support the Consultative Report as another important step towards enhancing the safety and soundness of CCPs, and provide recommendations to further the goal of effective resilience, recovery, and resolution mechanisms for CCPs.