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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 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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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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