TCH Responds to BCBS Step-in Risk Proposal
May 15, 2017
The Clearing House letter is supportive of the Basel Committee’s revisions to the proposed guidelines for the identification and management of step-in risk. However the letter notes numerous aspects of the proposal that need to be updated in order to achieve the Basel Committee’s objectives of sensitivity to residual step-in risk and simplicity of the framework.
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.
TCH Files Comment Letter to the BCBS on Its Proposal Reducing Variation in Credit RWAs
Jun 24, 2016
In the letter, TCH discusses the importance of providing banking organizations with the opportunity to evaluate holistically the entire package of revisions to the Basel III capital framework and the data upon which the revisions are based.
TCH Publishes Research Note on the Methodology Used to Calibrate the Single-Counterparty Credit Limit
Jun 3, 2016
In order to achieve conceptual and intellectual consistency across the single-counterparty credit limit and GSIB surcharge frameworks, either the inter-GSIB credit limit would have to be increased substantially or the GSIB surcharges would have to be cut roughly in half for the majority of GSIBs.
Trades Support Appropriately Calibrated Standardized Measurement Approach to Operational Risk
Jun 3, 2016
In the letter, the Associations affirmed their support for the proposed withdrawal of the Advanced Measurement Approach framework in favor of a more stable and less complex standardized measure of operational risk that both promotes greater comparability and is appropriately risk-sensitive.
TCH Files Comment Letter on Fed’s SCCL Reproposal
Jun 3, 2016
The letter to the Federal Reserve on its reproposal of the single-counterparty credit limit (SCCL) requirement of the Dodd-Frank Act, notes substantial improvements included in the March 2016 reproposal, and details some problematic aspects that still remain that could make the rule needlessly difficult to implement and in some instances unworkable.
TCH Publishes Empirical Analysis of BCBS-Proposed Revisions to the Standardized Approach for Credit Risk
May 20, 2016
Recently, The Clearing House (TCH) released empirical analysis (TCH Study) utilizing data from large U.S. bank holding companies to analyze the impact that could result from the implementation of the BCBS-proposed revisions to the Standardized Approach for credit risk with respect to credit conversion factors (CCFs) for off-balance sheet commitments.
TCH Submits Comment Letter on Basel’s Step-In Risk Proposal
Mar 17, 2016
The Clearing House (TCH) has submitted a comment letter to the Basel Committee in response to their Identification and Measurement of Step-In Risk consultative document.
TCH Comments on Basel Committee’s Revisions to the Standardized Approach to Credit Risk
Mar 11, 2016
The Clearing House (TCH), joined by SIFMA and FSR, filed comments to the Basel Committee in response to their second consultative document to revise the standardized approach to credit risk.
TCH Files Comment Letter with International Policymakers on CCP Risk Governance Issues
Sep 18, 2015
The Clearing House Association (TCH) submitted a letter to CPMI/IOSCO recommending enhancements to current central counterparty (CCP) risk governance practices and clearing member consultation processes.
TCH Comments on BCBS Interest Rate Risk in the Banking Book Consultative Document
Sep 11, 2015
The Clearing House Association (TCH) letter supports the Basel Committee’s principal underlying policy goal, and expresses deep concern that the Pillar 1 approach to IRRBB described in the Proposal would be counterproductive and is based on a fundamentally flawed framework.
TCH Provides Recommendations to the Basel Committee on Its Proposed Revisions to the Standardized Approach for Credit Risk and Capital Floors
Mar 26, 2015
In a letter to the Basel Committee The Clearing House identifies areas where the proposed revisions to the standardized approach for credit risk and capital floors should be modified to better achieve the Committee’s stated objectives of making the Standardized Approach more risk-sensitive, reducing reliance on external credit ratings and strengthening the comparability of risk-weighted asset calculations across jurisdictions.
The Clearing House Calls on FSOC to Address CCP Systemic Risk
Jan 9, 2015
The Clearing House Association (TCH) submitted a letter to the Financial Stability Oversight Council (FSOC) urging it to lead a coordinated effort of its member regulatory agencies to address and mitigate systemic risk arising from increasing market reliance on central counterparties (CCPs). In the letter, TCH details a set of concrete recommendations that would subject CCPs to more stringent standards and help ensure that their risks are more carefully managed and mitigated.
TCH Comments on Margin and Capital Requirements for Covered Swap Entities
Nov 24, 2014
In the letter, the Associations urge the regulators to use their statutory discretion to exclude inter-affiliate swap transactions from margin requirements, consistent with the risk-based approach to implementation contemplated by the relevant statute.
TCH Comments on SEC Standards for Covered Clearing Agencies
May 27, 2014
The Clearing House Association’s comment letter to the SEC highlights key areas of concern and offers a range of recommended changes intended to further minimize the potential systemic risks that CCPs may pose.
Banking Brief: OCC Proposed Guidelines Establishing Heightened Standards for Risk Governance
Apr 16, 2014
The Clearing House strongly supports the OCC’s overall Heightened Expectations program for large banks but is concerned that particular aspects of the Proposed Guidelines may require substantial changes to a bank’s risk management practices that would be unnecessary and potentially counterproductive to sound risk management practices.
TCH Comment Letter to OCC on Proposed Heightened Standards Offers Support, Suggests Clarification of Certain Aspects of Proposed Guidelines
Mar 28, 2014
The Clearing House Association’s letter to the Office of the Comptroller of the Currency (OCC) reiterates its strong support for the primary objective of the guidelines – a strong and effective risk management framework for banks – but recommends clarification of certain key aspects of the proposed guidelines in order to ensure that they achieve their stated purpose.
TCH Study Highlights Problematic Aspects of Basel Committee’s Proposed Large Exposure Limits
Nov 26, 2013
The Clearing House Association released a quantitative study on the Basel Committee’s proposed standards for large exposures finding that, on an aggregate basis, participating banks’ exposures would exceed the prescribed limits by $732 billion.
TCH Comments on How Risk Retention Would Apply to CLOs
Oct 30, 2013
TCH letter explains that the revised proposal’s shift of risk retention requirements to the lead arrangers of eligible commercial loans would be neither workable nor actually used in practice.