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.
Joint-Trades Letter to OCC Re: Restrictions on the Terms of QFCs
Oct 18, 2016
The Clearing House (TCH), along with SIFMA, the ABA, the FSF, the FSR, and the IIB (Associations) filed a comment letter to the OCC on its NPR relating to restrictions on the terms of qualified financial contracts (QFCs).
TCH Files Joint-Trades Letter Responding to Fed’s NPR Relating to QFCs
Aug 5, 2016
The Clearing House (TCH) along with SIFMA, the ABA, the FSR and the IIB (Associations) filed a comment letter responding to the Fed’s NPR relating to restrictions on the terms of qualified financial contracts (QFCs) entered into by U.S. G-SIBs and the U.S. operations of foreign G-SIBs (together with U.S. G-SIBs, Covered Entities).
Trades Comment on Agencies Proposed Rule Implementing Section 205 of DFA
May 2, 2016
The Clearing House Association (TCH), along with SIFMA and the FSR (Associations) commented on a proposed rulemaking issued by the FDIC and SEC which would implement Section 205 of Dodd-Frank. Section 205 contains special provisions for the orderly liquidation of certain U.S. brokers and dealers, and paragraph (h) of Section 205 requires the Agencies, in consultation with the Securities Investor Protection Corporation (SIPC), to jointly issue rules to implement Section 205.
Associations File Comment Letter to the OCC Responding to Its Part 30 Large Bank Recovery Plan Guidance
Feb 16, 2016
The Clearing House (TCH), SIFMA, and the FSR (Associations) filed a comment letter responding to the OCC’s proposal for formal Part 30 guidelines on large bank recovery planning requirements.
TCH Submits Comment Letter to the PRA on Contractual Resolution Stays
Aug 26, 2015
TCH broadly supports the PRA’s proposal on resolution stays and also requests certain adjustments.
TCH Joins ABA and CBA in Comment Letter on the FDIC's Deposit Insurance Determination Modernization ANPR
Jul 27, 2015
The Clearing House letter asserts that covered banks will ultimately be prepared to meet the FDIC’s policy objectives as set forth in the ANPR.
TCH Comments on Recordkeeping Requirements Related to Orderly Liquidation Authority
Apr 7, 2015
The Clearing House Association and SIFMA, joined by the ABA, FSR, and ISDA, submitted a comment letter in response to the January 7 FSOC notice of a proposed rulemaking that would implement the qualified financial contract (QFC) recordkeeping requirements outlined in the Dodd-Frank Act related to the FDIC’s receivership authority under Title II. The letter noted that the proposal is a necessary step in the implementation of effective OLA resolution strategies, but that certain aspects of the proposal are inconsistent with its purpose and statutory authority and may actually impede the FDIC’s decision making during a resolution scenario.
Banking Brief: Overview of Total Loss Absorbing Capacity
Feb 20, 2015
In November 2014, the Financial Stability Board (“FSB”) proposed international standards for total loss absorbing capacity (“TLAC”) that a global systemically important bank (“G-SIB”) would be required to maintain to facilitate its orderly resolution should it fail.
TCH Supports TLAC to Help Ensure G-SIBs Can Be Resolved in an Orderly Manner without Taxpayer Assistance
Feb 2, 2015
The Clearing House Association, in coordination with ABA, FSR, and SIFMA, filed a letter with the Financial Stability Board in response to its proposal to impose a total loss absorbing capacity (TLAC) requirement on global systemically important banking groups (G-SIBs). The letter expresses the industry’s strong support for a TLAC requirement for G-SIBs to help ensure that these institutions can be resolved in an orderly way at creditor rather than taxpayer expense, bringing us one final step closer to ending “Too Big to Fail.”
Banking Brief: Resolution Strategies for Bankruptcy and Orderly Liquidation Authority
Oct 9, 2014
This Banking Brief will discuss different strategies, including single-point-of-entry (“SPOE”) and multiple-point-of-entry (“MPOE”), that can be used under both provisions of the law to facilitate the orderly resolution of financial institutions.
Banking Brief: Living Will Requirements for Banking Organizations
Oct 9, 2014
The Dodd-Frank Act requires banking organizations with $50 billion or more of consolidated assets to file resolution plans annually with the Federal Reserve and FDIC. Each resolution plan, also known as a “living will,” must describe the organization’s strategy for rapid and orderly resolution under the U.S. Bankruptcy Code in the event of the organization’s material financial distress or failure.
TCH Files Comment Letter on FDIC's Single-Point-Of-Entry
Feb 18, 2014
The Clearing House Association, in coordination with ABA, FSR, and GFMA, filed a letter with the FDIC supporting its single-point-of-entry (SPOE) strategy for resolving a U.S. G-SIB under Title II.
TCH Recommends Different Approach to FDIC’s Interpretation of “Deposit Liability”
Apr 22, 2013
TCH filed a comment letter on the FDIC’s proposed rule to address the depositor preference issue.
TCH Releases Title II Resolution Simulation Exercise Materials
Feb 11, 2013
The Simulation exercise—which took place on November 8 and 9, 2012, and was attended by over 160 industry leaders, former regulators and legal experts—simulated the failure of a large U.S.-based global banking organization and its resolution under the Title II single-point-of-entry approach.
TCH White Paper Finds Single-Point-of-Entry Can End “Too-Big-To-Fail”
Jan 17, 2013
The Clearing House Association white paper provides a more detailed analysis of the workability and benefits of a Title II single-point-of-entry approach.
TCH Comments to FDIC on Enforcements of Contracts Belonging to Resolved Financial Companies
May 29, 2012
The Clearing House Association, along with other trade associations, sent a letter to the FDIC to comment on an NPR relating to section 210(c)(16) of the orderly liquidation authority provisions of Dodd-Frank.
TCH Comments on Sections 165/166 of the Dodd-Frank Act
Apr 27, 2012
The Clearing House Association filed its comment letter in conjunction with other financial trades on Sections 165/166 of the Dodd-Frank Act.
TCH Recommends Recapitalization, Other Resolution Suggestions to FDIC
Nov 18, 2011
TCH Association submitted a letter to the FDIC commenting on its interim final rule requiring living wills for insured depository institutions with $50 billion or more in total assets.
TCH Urges UK to Adopt Single-Resolution-Plan Approach, Cross-Border Coordination
Nov 9, 2011
The letter recommends a single-plan approach, cross-border cooperation and coordination agreements, harmonized informational elements and a cooperative, iterative process.