Associations Comment on CFPB Assessment of Remittance Transfer Rule
May 23, 2017
The Clearing House (TCH), BAFT, the CBA, and the ABA, submitted a letter to the CFPB in response to the Bureau’s notice and request for information (“RFI”) regarding its planned assessment of regulations pertaining to consumer remittance transfers under the Electronic Fund Transfer Act.
TCH Submits Comments on Enhanced Cyber Risk Management Standards
Feb 17, 2017
In a letter to banking regulators TCH recommends, that before proceeding with new requirements, the agencies should focus on consolidating existing standards and work with industry stakeholders to assess and close gaps in the current regulatory framework.
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 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).
TCH Submits Comment Letter on FMI Cyber Resilience Proposal
Feb 23, 2016
The Clearing House (TCH) comment letter to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) responds to their Guidance on Cyber Resilience for Financial Market Infrastructures consultative report.
TCH Comments on Proposed ORSOM Supervisory Rating System
Jan 21, 2016
The Clearing House (TCH) submitted a comment letter to the Fed that among other things, expressed concern that the proposal would create new obligations for FMIs that go beyond existing regulatory obligations, and that that the flexibility the Board built into the proposed rating system would permit excessive supervisory discretion.
Ensuring Consistent Consumer Data Protection
Sep 15, 2015
During the past few years, the nontraditional payment provider market has experienced explosive growth. However, the legal and regulatory protections designed to protect consumers’ financial data may not cover all new payment products and could place personal data at risk.
For The Record: Reinventing Payments
Sep 15, 2015
TCH CEO Jim Aramanda calls on the industry to deliver a next generation, real-time payments platform that will serve as a foundation for payments innovation for many years to come.
Banking Brief: Ensuring Consistent Consumer Protection for Data Security: Banks vs. Alternative Payment Providers
Aug 31, 2015
Recently, The Clearing House released a White Paper that analyzes the alternative payment provider (APP) industry, identifies regulatory and enforcement gaps between banks’ payment operations and APPs, and makes recommendations on how to close those gaps in order to ensure that consumers receive a consistent level of protection.
Leveling the Playing Field: Ensuring Consumers Are Protected When Using Nonbank Payment Services
Jun 11, 2015
Consumers who use bank-provided payment services have long enjoyed wide-ranging protections Consumers of nonbank payment service providers may not have the same protections, and this needs to change.
For The Record
Jun 5, 2015
If there is a bright side to the Target, Home Depot, Anthem, and Sony data breaches, it is that virtually everyone is aware of the dangers associated with cyberattacks.
TCH’s Russ Fitzgibbons Testifies on Cyber, Calls for Information Sharing Legislation
May 19, 2015
The Clearing House’s Chief Risk Officer, Russ Fitzgibbons, testified before the House Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit, where he highlighted proactive measures to combat cyber threats taken by TCH and its Owner Banks, the financial services industry, and the government.
TCH Comments on CFPB’s Proposal to Regulate Prepaid Accounts
Mar 23, 2015
In a letter submitted to the CFPB The Clearing House recommends that consumers should receive the same protections under consumer financial laws regardless whether the products and services they obtain are provided by a depository institution or a nonbank.
TCH Comments on CSBS Model Framework for Virtual Currency Activities
Feb 13, 2015
The Clearing House Association (TCH), joined by the Independent Community Bankers of America (ICBA), submitted a letter to the Conference of State Bank Supervisors regarding the draft model regulatory framework for virtual currency activities.
TCH Files Comment Letter to NACHA Supporting Same-Day RFC
Feb 6, 2015
In a letter to NACHA TCH suggested improvements to the proposal including adopting a different indicator in the Batch Header Record to identify transactions for same day processing and settlement, rather than relying on the Effective Entry Date, and encouraged NACHA to consider leveraging additional evening settlement windows as a future enhancement to the same day ACH capabilities in light of the expanded operating hours of the Federal Reserve Banks’ National Net Settlement Service.
TCH Comments on Proposed BitLicense Regulations
Oct 20, 2014
The Clearing House Association comments to the New York Department of Financial Services on its proposed “BitLicense Regulations” for virtual currency businesses states that applying BitLicense Regulations on traditional banking entities would add duplicative regulatory burdens with no additional benefits to the public.
Mobile Payments: Ready for Primetime
Sep 15, 2014
Recent developments like Apple Pay indicate that consumers and merchants are ready to shift from plastic to mobile. However, adoption at scale will necessitate that a mobile wallet solution be able to balance customer and merchant value propositions and simultaneously gain support from incumbent stakeholders. By focusing their investments on long-term safety and soundness solutions, banks will play an instrumental role in ensuring mobile payments adoption.
TCH Comments on CFPB Proposal to Revise the Remittance Transfer Rule
Jun 6, 2014
The Clearing House Association letter strongly supports the Consumer Financial Protection Bureau's proposal to extend the temporary exception that permits insured institutions to disclose, under certain circumstances, estimates rather than exact amounts of exchange rates and the amount of covered third-party fees.
TCH Files Memo in Opposition to Proposal to Amend N.Y. Law to Facilitate Collection Actions of Foreign Affiliates of Banks
Jun 5, 2014
The memorandum that The Clearing House submitted to the New York Legislature states that the amendment to New York’s Civil Practice Law and Rules (“CPLR”) could subject banks and their affiliates to double liability, raises substantial issues under the U.S. Constitution, and will overburden NY courts.