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Trades Comment on Agencies Proposed Rule Implementing Section 205 of DFA May 02, 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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Amicus Brief Supporting the United States Patent and Trademark Office's Use of the Broadest Reasonable Construction Standard in Inter Partes Reviews Mar 30, 2016

The Clearing House’s amicus brief in Cuozzo v. Lee asks the U.S. Supreme Court to uphold the United States Patent and Trademark Office’s rule requiring application of the broadest reasonable construction to claims in inter partes review proceedings in order to maintain the effectiveness of those proceedings as an efficient alternative to district court litigation for addressing low quality patents.

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TCH Submits Letter to NYDFS on BSA/AML and CCO Certification Proposal Mar 21, 2016

In a letter to the New York Department of Financial Services (NYDFS), The Clearing House (TCH) comments on its proposed regulation that would specify the required attributes of BSA/AML Transaction Monitoring and Filtering Programs for NYDFS-regulated institutions and require senior compliance officers (CCOs) of those institutions to certify that those programs comply with the proposed regulation.

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TCH Calls on the Fed to Rethink and Add Procedural Protections to Proposed CCyB Mar 21, 2016

In a letter to the Fed, The Clearing House calls for the proposal for implementing a countercyclical capital buffer (CCyB) to be revised to ensure that any future decision to establish a CCyB is subject to notice-and-comment rulemaking, as required by the Administrative Procedure Act.

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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.

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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.

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TCH Files Comment Letter Arguing Against the OCC’s Proposed MLR System Expansion Mar 04, 2016

The Clearing House (TCH) submitted a comment letter to the OCC on its proposed extension of its Bank Secrecy Act/Money Laundering Risk Assessment reporting requirement, also known as the Money Laundering Risk (MLR) System, to large and midsize banks within its jurisdiction.

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TCH Comments on FASB Proposal for Fair Value Measurement Disclosures Feb 29, 2016

The Clearing House (TCH) has submitted a comment letter to the FASB in response to the consultative document, Changes to the Disclosure Requirements for Fair Value.

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TCH Submits Comment Letter on FMI Cyber Resilience Proposal Feb 23, 2016

The Clearing House (TCH) comment letter to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) responds to their Guidance on Cyber Resilience for Financial Market Infrastructures consultative report.

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TCH Leads Industry Response to Fed’s TLAC-LTD Proposal Feb 19, 2016

The Clearing House (TCH), joined by SIFMA, ABA, FSR, and FSF (Associations), filed comments with the Fed in response to its proposal to impose a total loss absorbing capacity (TLAC), long-term debt (LTD) and related “clean holding company” requirements on G-SIBs. The comment letter expresses the industry’s strong support for an appropriately calibrated TLAC requirement for G-SIBs, which is a crucial aspect of ending TBTF by helping ensure that these institutions have enough loss absorbing resources to be resolved in an orderly way.

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Associations File Letter Addressing Basel Committee’s TLAC Holdings Consultation Feb 17, 2016

The Clearing House (TCH), SIFMA, FSR, and the IIB (Associations) commented on the Basel Committee’s November 2015 consultation addressing the treatment under the Basel III capital framework of internationally active banks’ holdings of TLAC instruments of G-SIBs.

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Associations File Comment Letter to the OCC Responding to Its Part 30 Large Bank Recovery Plan Guidance Feb 16, 2016

The Clearing House (TCH), SIFMA, and the FSR (Associations) filed a comment letter responding to the OCC’s proposal for formal Part 30 guidelines on large bank recovery planning requirements.

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TCH Finalizes Updated Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking Feb 16, 2016

The Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking are intended to provide guidance to U.S. banks engaged in foreign correspondent banking and to assist U.S. banks in implementing key anti-money laundering (AML) procedures.


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TCH Comments on FASB Proposal for Government Assistance Disclosures Feb 09, 2016

The Clearing House (TCH) comment letter to the FASB on their exposure draft, Disclosures by Business Entities about Government Assistance expresses a number of concerns with the proposed disclosures.


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TCH Comments on Proposal for LCR Public Disclosure Requirements Feb 04, 2016

The Clearing House (TCH) letter expresses support of the LCR as a supervisory tool, but expresses concern that granular disclosure of the LCR’s components may increase the very types of risks to systemic stability and to financial institutions that the LCR is designed to mitigate


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TCH Files Joint-Trades Amicus in Support of Huntington Bank’s 6th Circuit Appeal Feb 04, 2016

The Clearing House (TCH) filed a joint-trades amicus brief in support of Huntington Bank’s 6th Circuit appeal in Meoli v. The Huntington National Bank.

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Trade Associations Comment on Revisions to the Consolidated Financial Statements for Holding Companies Feb 01, 2016

The Clearing House (TCH) submitted a comment letter to the Fed jointly with the ABA in response to proposed revisions to the FR Y-9C.

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TCH Comments on Proposed ORSOM Supervisory Rating System Jan 21, 2016

The Clearing House (TCH) submitted a comment letter to the Fed that among other things, expressed concern that the proposal would create new obligations for FMIs that go beyond existing regulatory obligations, and that that the flexibility the Board built into the proposed rating system would permit excessive supervisory discretion.

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TCH and SIFMA File Amicus Brief in FDIC v. RBS Securities, Inc. Jan 19, 2016

The Clearing House (TCH) and SIMFA filed an amicus brief with the Supreme Court of the U.S. (SCOTUS) in support of a petition for a writ of certiorari in connection with FDIC v. RBS Securities Inc

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TCH Requests Extension of Countercyclical Capital Buffer Policy Statement Comment Period Jan 14, 2016

The Clearing House (TCH) submitted a letter to the Fed requesting an extension of the comment period to respond to the Federal Reserve Board’s Proposed Policy Statement implementing the U.S. Basel III Countercyclical Capital Buffer. As currently proposed, comments must be received by February 19th. 

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