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Resolution and Recovery Planning

The Clearing House

U.S. and international supervisors continue to build out a comprehensive regulatory framework for large financial institution resolution and recovery planning. TCH supports policy efforts to end the risk that some institutions may be treated as TBTF and believes that the current regulatory framework provides for the effective resolution and recovery of large financial institutions, without taxpayer expense. 

Recent Highlights

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 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).

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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.

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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.

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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.

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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.”

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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.

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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.

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