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TCH Files Joint-Trades Supplemental Letter on NSFR Dec 28, 2016

The Clearing House (TCH) comment letter highlights a number of differences between the EU’s NSFR Proposal and the U.S. NSFR Proposal, highlighting ten “primary differences” between the EU proposal and U.S. proposal.

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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 Amicus Brief in Support of Petitioners in Bank of America v. Gelboim Dec 09, 2016

The brief argues that (i) noncompetitive benchmarks, such as LIBOR, should not be treated as prices under antitrust laws, (ii) the Second Circuit expanded potential antitrust liability for standard setting programs by holding that mere participation in setting a benchmark was sufficient to infer participation in an antitrust conspiracy, and (iii) the combination of expanded price-fixing and conspiracy liability will chill efficiency-enhancing benchmarks and other standard-setting agreements.

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TCH-EY Publish Bank Innovation White Paper Nov 29, 2016

The Clearing House (TCH) and E&Y released a white paper entitled “The digital bank: tech innovations driving change at US banks.” The paper addresses how banks are using technological innovation to improve products and services for customers, strengthen bank controls and drive down costs. It also discusses ways in which regulators can foster and encourage innovation.

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TCH Files Comment Letter to Federal Reserve on Proposed Amendments to CCAR Nov 23, 2016

The Clearing House (TCH) filed a comment letter with the Federal Reserve on the proposed amendments to the Capital Plan and Stress Test Rules. The comment letter supported the Federal Reserve’s proposal to eliminate the qualitative portion of CCAR for “large and noncomplex” firms and the proposed transition rules for firms crossing the $50B threshold.

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TCH Files Comment Letter to FASB on Hedging Nov 22, 2016

The Clearing House (TCH) filed a comment letter with the FASB on targeted improvements to accounting for hedging activities. The letter supported (i) proposed refinements to the accounting for the hedged item in fair value hedges of interest rate risk, (ii) proposed changes that allow more risk component hedging, and (iii) proposed improvements regarding the application of current guidance related to the assessment of hedge effectiveness.

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TCH Files Comment Letter to FASB on Prepayable Debt Nov 22, 2016

The Clearing House (TCH) filed a comment letter with the FASB on callable debt securities. The comment letter supports the proposed requirement that the premiums of callable debt securities, which are purchased at a premium, must be amortized to the earliest call date.

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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).

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Trades File Amicus Brief in FDIC v. First Horizon Nov 07, 2016

The Clearing House (TCH), along with the ABA and SIFMA, filed an amicus brief in support of the defendants’ petition for certiorari in FDIC v. First Horizon. 

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TCH Submits Comment Letter Regarding SEC Disclosure Update and Simplification Amendments Oct 28, 2016

The Clearing House (TCH) has submitted a comment letter to the SEC on its proposed disclosure update and simplification amendments. 

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TCH Joins Trade Comment Letter to CFPB Re: ‘Amendments Relating to Disclosure of and Records and Information,’ Including Confidential Supervisory Information Oct 24, 2016

In the letter, The Clearing House (TCH), along with the FSR (and the FSR’s Housing Policy Council), the ABA, the CBA and the CCMC (Associations) express concerns with the proposed expansion of the Bureau’s ability to share Confidential Supervisory Information (CSI), including that the proposed expansion could increase litigation and reputational risk for financial institutions, undermine the vitality of the bank examination privilege, and potentially breach a supervised institution’s legal privileges should the materials be shared beyond the scope contemplated by Section 1828(x) of the FDI Act.

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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. 

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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.

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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).

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TCH Files Comment Letter Regarding Changes to FR Y-14A/Q/M and LISCC IHC Attestation Sep 26, 2016

The Clearing House (TCH) filed a comment letter responding to a Fed rule proposal that would extend for three years the CCAR information collection applicable to bank holding companies with total consolidated assets of $50 billion, or more, and U.S. intermediate holding companies established by foreign banking organizations. TCH’s comment letter identifies several specific areas where additional clarifications would be beneficial and recommends a process to better facilitate timely implementation.

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TCH Files Comment Letter to FSB on Its Peer Review on Corporate Governance Sep 09, 2016

The Clearing House (TCH) filed a comment letter responding to the FSB’s request for feedback on the implementation of the G20/Organization for Economic Co-Operation and Development (“OECD”) Principles of Corporate Governance (“OECD Principles”) as they relate to financial institutions.

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TCH Files Joint-Trades Amicus Brief in Support of Petitioners in Visa Inc. et al. v. Osborn Sep 08, 2016

 The Clearing House (TCH), along with the ABA, CBA, FSR, NACHA, and ICBA (the Associations) filed an amicus brief with the SCOTUS in support of petitioners in Visa et al v. Osborn.

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TCH Submits Comment Letter on OCC’s Proposed MLR System Expansion Sep 07, 2016

 The Clearing House (TCH) submitted a comment letter responding to the OCC’s second notice on its proposed expansion of the BSA Money Laundering Risk Assessment (MLR System) to large and midsize institutions under its supervision.

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TCH Urges Passage of Bipartisan Beneficial Ownership Legislation Aug 08, 2016

The Clearing House sent a letter to House and Senate sponsors of the Incorporation Transparency and Law Enforcement Assistance Act expressing support for the legislation and its intent to help combat terrorist financing activities through the use of shell companies. The letter suggests that banks could also potentially benefit from having access to the information for their due diligence efforts and requests clarification in the bill to ensure that access.

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TCH Files Joint-Trades Letter Responding to Fed’s NPR Relating to QFCs Aug 05, 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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