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TCH Joins Trades in Responding to FDIC’s Proposal to Impose DIF Assessment Surcharge on Large Banks Jan 05, 2016

The Clearing House Association joined the ABA and FSR (the Associations) in a comment letter responding to the FDIC’s NPR on assessments.

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TCH Submits Joint-Trades Letter to FDIC on Its Brokered Deposits FAQs Dec 28, 2015

In the letter The Clearing House (TCH) along with the ABA, FSR, ICBA and IIB  argues that while the FDIC’s proposal alleviated some member concerns around the FDIC’s original January 2015 guidance, there are still a number of issues that need to be addressed in order for it to truly adhere to the purpose and intent behind the statute – Section 29 of the FDIA – which governs brokered deposits.

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TCH Submits Comment Letter on FSB Data Gaps Phase 3 Instructions Dec 21, 2015

TCH submitted a comment letter to the Chairman of the FSB Data Requirements Workstream regarding the revised guidelines for reporting institution-to-aggregate granular data on assets and liabilities on an immediate counterparty basis.

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TCH Comments on Revisions to Internal Revenue Code Section 367 Dec 15, 2015

The Clearing House (TCH) submitted a comment letter on proposed Treasury regulations under Section 367 of the Internal Revenue Code which would, in a significant departure from existing law, tax certain outbound transfers of foreign goodwill and going concern value in otherwise tax-free transactions.

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TCH Association President Responds to Bloomberg View Editorial on Capital Requirements Dec 14, 2015

In a letter to the editor, Greg Baer, President of The Clearing House Association responded to a Bloomberg View editorial titled “Outlawing Bailout Won’t End Them.” In the response Mr. Baer rebuts the editorial’s assertions that enough hasn’t been done to make the financial system more resilient. The response was published on Bloomberg Terminals on December 14, 2015.

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TCH Files Joint-Trades Amicus in Support of Midland Funding’s Cert Petition Dec 10, 2015

The Clearing House (TCH) filed a joint-trades amicus brief in support of Midland Funding’s cert petition to the SCOTUS asking the Court to decide whether The National Bank Act, which preempts state usury law regulating the interest a national bank may charge on a loan, continues to have preemptive effect after the national bank has assigned the loan to another entity. 


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TCH Urges Better Public-Private Coordination to Bolster AML Efforts Dec 07, 2015

The Clearing House (TCH)  filed a comment letter with the BIS Committee on Payments and Market Infrastructures (CPMI) responding to its recent report providing technical measures to address reductions in correspondent banking. In the letter, TCH agreed that technical improvements to information sharing and similar anti-money laundering (AML) and counterterrorism financing tools may be helpful in improving access to correspondent banking services.

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TCH Submits Supplemental FR Y-15 Comment Letter Nov 20, 2015

The Clearing House (TCH) submitted a supplemental comment letter containing technical clarification questions regarding the proposed revisions to the Banking Organization Systemic Risk Report (FR Y-15). TCH also submitted an October 19 industry comment letter on this proposal.

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TCH Submits Comment Letter on Revisions to the Call Report Nov 17, 2015

The Clearing House (TCH), jointly with the ABA, submitted a comment letter to the FFIEC regarding proposed modifications to the Consolidated Reports of Condition and Income (the Call Report). The letter is very supportive of the FFIEC’s decision to accelerate the start of the next review of the Call Report and the FFIEC’s initiative to stream line the Call Report by better aligning it with recently implemented rules and standards.

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TCH Submits FR Y-14 Comment Letter Nov 16, 2015

The Clearing House Association (TCH) submitted a joint-trade comment letter to the FRB regarding the September 16 NPR which proposed adding a CFO-level attestation to the FR Y-14 report series for LISCC banks.

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TCH Comments on Highway Funding Bill Nov 12, 2015

TCH joined more than 20 trade associations expressing support for the House's position that would reject a reduction to the Fed dividend and an increase to the guarantee-fee.

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TCH and SIFMA File Amicus Brief in FHFA v. Nomura Oct 29, 2015

TCH and SIFMA filed an amicus brief supporting defendants’ appeal in FHFA v. Nomura Holding America Inc.

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TCH Comments on Revisions to the Banking Organization Systemic Risk Report (FR Y-15) Oct 19, 2015

The Clearing House (TCH) submitted a comment letter to the Fed on their proposal to revise the FR Y-15 systemic risk report to increase the frequency of reporting, collect information on short-term wholesale funding (STWF), and update the report generally to conform the FR Y-15 with the U.S. supplementary leverage ratio and the G-SIB capital surcharge rule.


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TCH Submits Comments on FASB Proposals on Novations Oct 02, 2015

The Clearing House Association, jointly with the ABA, submitted a comment letter to the FASB supporting Proposed Accounting Standards Updates to clarify whether a novation requires de-designation.

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TCH Submits Comments on FASB Proposal on Contingent Put and Call Options in Debt Instruments Oct 02, 2015

The Clearing House Association, jointly with the ABA, submitted a comment letter to the FASB in response to a Proposed Accounting Standards Updates issued on August 6 to simplify evaluating puts/calls.

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TCH Comments on Amendments to Capital Plan and Stress Test Rules Sep 24, 2015

The Clearing House (TCH) generally supports the Proposal to amend certain aspects of the U.S. capital planning and stress testing regime and welcomes the Federal Reserve’s efforts to make targeted adjustments and technical amendments to the capital planning and stress testing framework.

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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.

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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.

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TCH Comments on Contemplated FR Y-14 Attestation Requirement Sep 11, 2015

The letter provides initial concerns given the serious and significant problems regarding the potential introduction of a CFO and/or Chief Auditor attestation requirement.

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TCH Files Comment Letter to the DOL on Proposed Rule to Change Overtime Compensation Requirements Sep 01, 2015

The Clearing House Association (TCH), along with the FSR, ICBA, MBA and ABA (the Trades), filed a comment letter with the Department of Labor (DOL) on its proposed rulemaking to change overtime compensation requirements for certain employees. 

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