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Financial Trade Associations Ask Bank Regulators to Reconsider NSFR Aug 05, 2016

In a letter to bank regulators, TCH, SIFMA, the FSR, CRE Finance Council, the IIB, and the ABA urge that the NSFR not be implemented in the U.S. without an analytically sound rationale that takes into account the unique aspects of the U.S. financial system.

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Custody Services Provided by Banks Are Important to the Safekeeping and Management of Investments Jul 28, 2016

The Clearing House (TCH) white paper, The Custody Services of Banks  discusses the services provided by bank-chartered custodians, their relationships with financial market utilities (FMUs), and describes the different risks associated with custody services in comparison to those associated with other banking activities.

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TCH Responds to Interagency Incentive Compensation Reproposal Jul 22, 2016

TCH has filed a comprehensive comment letter on the joint interagency proposal of incentive-based compensation restrictions under Section 956 of the Dodd-Frank Act. The letter highlights a range of legal and substantive concerns with the Agencies’ proposal, noting that whereas the statute directs the joint agencies to proscribe certain compensation arrangements (i.e., those that encourage inappropriate risk-taking that could lead to material financial loss, or by providing excessive compensation), the proposal would instead prescribe specific and detailed requirements that effectively amount to mandatory incentive compensation structures across covered firms. 

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TCH Files Comment Letter Responding to SEC’s Regulation S-K Jul 21, 2016

The Clearing House (TCH) has filed a comment letter responding to the SEC concept release regarding disclosure under Regulation S-K. 

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TCH Responds to BCBS Proposal Defining Problem Assets Jul 15, 2016

TCH has filed a comment letter responding to the Basel Committee on Banking Supervision’s (BCBS) proposal on prudential treatment of problem assets – definitions of non-performing exposures and forbearance.

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TCH Joins Joint Trade Comment Letter on Revisions to the Basel III Leverage Ratio Framework Jul 06, 2016

TCH has joined a trades comment letter along with, GFMA, IIF, ISDA, and the JFMC (Associations) responding to the BCBS proposed revisions to the Basel III leverage ratio framework.

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TCH Joins Trade Comment Letter on Adverse Tax Consequences for IHCs of Fed’s TLAC Proposal Jul 01, 2016

The Clearing House (TCH) joined with SIFMA and IIB to submit a supplemental comment letter on the Fed’s Internal TLAC proposal for IHCs. The letter recommends changes to the TLAC rule to help mitigate against the risk that the internal long-term debt issued by an IHC to its foreign parent will be treated as equity for U.S. tax purposes.

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TCH Responds to FDIC’s NPR Imposing New Deposit Insurance Recordkeeping Requirements on Large Banks Jun 27, 2016

The ABA, TCH, the CBA, and SIFMA (Associations), filed a joint-trades comment letter responding to the FDIC’s NPR on record keeping for timely deposit insurance determination.

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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.

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TCH Files Comment Letter to the Fed’s Proposed Revisions to FR Y-6, FR Y-7 and FR Y-10 Jun 23, 2016

The Clearing House June 23 comment letter is a formal re-submission of comments from The Clearing House’s May 19, 2015 letter.


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TCH and ABA File Letter to BCBS on Its Pillar 3 Disclosure Requirements Proposal Jun 10, 2016

In the letter, The Clearing House and the ABA agree that robust Pillar 3 disclosure requirements are appropriate and necessary, but they identify several concerns with the proposed enhancements.

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Trades File Amicus Brief in FDIC v. Credit Suisse Jun 09, 2016

The Clearing House (TCH), ABA and SIFMA filed an amicus brief in the Second Circuit in support of a request for a rehearing in FDIC v. Credit Suisse. This case is one of the many “extender” statute cases that poses the question whether the FDIA displaces both preexisting statutes of limitations and statutes of repose when it sets the “applicable statute of limitations” for the FDIC to bring suit as a receiver.

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TCH Files Comment Letter on Fed’s SCCL Reproposal Jun 03, 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.

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Trades Support Appropriately Calibrated Standardized Measurement Approach to Operational Risk Jun 03, 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.

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TCH Files Comment Letter Highlighting Concerns with Incorporation of G-SIB Surcharge into CCAR Jun 02, 2016

The Clearing House (TCH) has filed an unsolicited comment letter identifying significant analytical, policy and practical problems that strongly caution against any incorporation of the capital surcharge for U.S. GSIBs into CCAR. 

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TCH Request for Extension of the Incentive Compensation Comment Period Jun 01, 2016

The Clearing House (TCH) has submitted a comment period extension request asking the agencies charged with incentive compensation rulewriting authority under Section 956 of the Dodd-Frank Act to provide for a comment period of no less than 90 days from the date of publication of the re-proposal in the Federal Register.  

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TCH Comments on OCC’s ‘Responsible Innovation’ White Paper May 31, 2016

The Clearing House comment letter commends the OCC for its willingness to evaluate and develop its own infrastructure and policies in order to foster well-informed engagement with banks and nonbanks on FinTech issues, but cautioned the OCC that FinTech innovation is rapidly evolving and that flexibility and timeliness of execution are critical components of the needed regulatory framework.

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TCH Submits Letter in Support of Treaty Re: Intermediary Securities Rights Stemming from 2006 Hague Securities Convention May 19, 2016

The Clearing House (TCH) letter to Sens. Corker (R-TN) and Cardin (D-MD) expresses support for the Senate Foreign Relations Committee’s consideration and approval of the 2006 Hague Securities Convention on the Law Applicable to Certain Rights in Respect of Securities held with an Intermediary.

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TCH Files Comment Letter Requesting a Broader Exemption to FinCEN’s Proposed FBAR Requirements May 09, 2016

The Clearing House (TCH) has filed a comment letter requesting a broader exemption to FinCEN’s proposed Report of Foreign Bank and Financial Accounts (FBAR) requirements.

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TCH Publishes the Role of the Board of Directors Report May 05, 2016

The TCH report, The Role of the Board of Directors in Promoting Effective Governance and Safety and Soundness for Large U.S. Banking Organizations, serves as a resource to both banks and their supervisors about the respective roles of directors and management. The report highlights the growing responsibilities and emphasis being placed on banking organizations’ board of directors by U.S. regulators. It also provides recommendations to regulators on how best to address what is often seen as a divergence between the role of the board, which is one of oversight, and regulatory compliance-related expectations for directors which at times may overlap with management’s responsibility.

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