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TCH Comments on the Proposed Supplementary Leverage Ratio Revisions Jun 13, 2014

In a letter filed in response to the Agencies’ April 8 proposed revisions to the denominator of the Supplementary Leverage Ratio, The Clearing House continues to support the fundamental notion of a leverage capital ratio that is intended and functions as a backstop floor to a risk-based approach to capital, and therefore generally supports the U.S. proposed revisions to the extent they promote a consistent leverage ratio calculation across jurisdictions. 

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TCH Comments on CFPB Proposal to Revise the Remittance Transfer Rule Jun 06, 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.

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TCH Files Memo in Opposition to Proposal to Amend N.Y. Law to Facilitate Collection Actions of Foreign Affiliates of Banks Jun 05, 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.

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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.

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TCH Submits Unsolicited Letter to Agencies on LCR Daily Reporting May 19, 2014

TCH led an industry joint-trades effort to submit an unsolicited comment letter to the U.S. banking agencies requesting guidance as early as possible indicating that the LCR Proposal’s daily calculation requirement will not be effective as of the proposed January 1, 2015 implementation date.

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TCH Comments on NACHA’s Proposal to Improve Network Quality May 02, 2014

The Clearing House submitted a letter to NACHA regarding the RFC to Improve Network Quality. TCH supports the proposal to lower the unauthorized return rate threshold to 0.5%, however, it emphasized that the 3% erroneous data return rate and 15% overall return rate should not function as return limits but as triggers for additional review of the origination and business practices of originators that exceed the rates.

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Banking Brief : 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. 

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TCH Comments on Merchant Banking Activities Proposal Apr 16, 2014

TCH’s comment letter submitted to the Fed argues that based on the longstanding success of FHCs at managing the risks associated with all types of merchant banking activities, the existing prudential framework for these activities is robust and effective and thus provides no reason for a fundamental revision of this framework.

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TCH Submits Statement for HFSC Hearing on Regulatory Costs Apr 08, 2014

The statement that The Clearing House submitted to the record of the Committee’s April 8 hearing entitled “Who’s in Your Wallet: Examining How Washington Red Tape Impairs Economic Freedom” urges policymakers to consider the cumulative impact of new regulations rather than evaluating any one particular regulation in isolation.


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TCH Comments on Targeted Improvements to FASB Financial Instruments ED Apr 01, 2014

In an unsolicited letter to the FASB, TCH made the following suggestions on targeted areas of improvement: (i) the fair value option is not in need of improvement and should not be limited, (ii) all purchased loans should be treated the same, (iii) the TDR disclosures are no longer meaningful and should be eliminated, (iv) sales of loans from the “Held-for-Investment” portfolio should not be further restricted, and (v) foreign currency gains and losses on debt securities measured at fair value through other comprehensive income (FVOCI) should be recognized in net income.

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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.

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TCH Testifies on Tokenization and Secure Cloud Mar 05, 2014

The Clearing House’s Dave Fortney, SVP for Product Development and Management, testified before the House Financial Services Subcommittee on Financial Institutions and Consumer Credit on data security. Fortney discussed the significant roles that EMV and tokenization will play in protecting against future threats.

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TCH Files Brief in Argentine Debt Case Mar 03, 2014

The Clearing House (TCH) filed an amicus brief with the U.S. Supreme Court in Republic of Argentina v. NML Capital, Ltd.


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TCH Files Brief in Clemente Bros. Constr. Corp. v. Capital One Feb 24, 2014

The Clearing House (TCH) filed an amicus brief before the New York Court of Appeals in Clemente Bros. Constr. Corp. v. Hafner-Milazzo and Capital One on the question of whether a bank and its customer should be permitted to agree to shorten the one-year period set out in Article 4 of the UCC for the customer to notify the bank of a forged or altered check.


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TCH Opposes CPSS-IOSCO Method for Assessment of FMI Servicers Feb 20, 2014

The Clearing House urges CPSS and IOSCO not to adopt the assessment methodology proposed in their Assessment Methodology for the Oversight Expectations Applicable to Critical Service Providers report.

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Banking Brief: Bank Liquidity Regulation - The Proposed U.S. LCR Feb 19, 2014

The U.S. LCR should deviate from the Basel LCR only when unique circumstances in the U.S. warrant such differences.  A U.S. LCR that otherwise differs from international standards in material ways detracts from international goals of clarity and transparency across markets, competitive equality, and minimizing opportunities for regulatory arbitrage.

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Banking Brief: Bank Liquidity Regulation - An Overview of the Proposed U.S. LCR Feb 18, 2014

The LCR is a key component of the post-crisis U.S. liquidity framework and an important step in strengthening the resiliency of banks and the stability of the financial system. The U.S. banking agencies have proposed an LCR in the United States that is more stringent than the LCR agreed to internationally.

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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.

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TCH Submits Comment Letter in Response to Fed Posting Rules Proposal Feb 06, 2014

The Clearing House Association filed a comment letter in response to the Federal Reserve Board proposed changes to the posting times for ACH debit transactions and check transactions.

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TCH Files Brief on “Ponzi-Scheme Presumption” Feb 03, 2014

The Clearing House (TCH) filed an amicus brief with the Minnesota Supreme Court in Finn v. Alliance Bank.

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