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Banking Brief: Ensuring Consistent Consumer Protection for Data Security: Banks vs. Alternative Payment Providers Aug 31, 2015

Recently, The Clearing House released a White Paper that analyzes the alternative payment provider (APP) industry, identifies regulatory and enforcement gaps between banks’ payment operations and APPs, and makes recommendations on how to close those gaps in order to ensure that consumers receive a consistent level of protection.

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TCH Submits Comment Letter to the PRA on Contractual Resolution Stays Aug 26, 2015

TCH broadly supports the PRA’s proposal on resolution stays and also requests certain adjustments.


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

TCH letter to the FSB Data Requirements Workstream expresses concerns that the proposal and template contain a number of impractical elements and insufficiently balance the costs of obtaining such data with the potential supervisory benefits.

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TCH Requests That FDIC Clarify ‘Brokered Deposits’ Guidance Aug 11, 2015

TCH letter to FDIC expresses concern about the potential over-breadth of the guidance and requests that the FDIC clarify various items.

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TCH Joins ABA and CBA in Comment Letter on the FDIC's Deposit Insurance Determination Modernization ANPR Jul 27, 2015

The Clearing House letter asserts that covered banks will ultimately be prepared to meet the FDIC’s policy objectives as set forth in the ANPR.

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Trades Request Extension of Comment Period on DOL Minimum Wage and Overtime Proposal. Jul 21, 2015

The Clearing House Association joined by five other banking trade associations filed a letter requesting a 60-day extension of the Department of Labor’s comment period.

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Trades Fight Effort to Reduce Fed Dividend Payment Jul 16, 2015

The Clearing House (TCH) joined the ABA, FSF, FSR, and the ICBA (Trades) in a letter to Sens. Inhofe (R-OK) and Boxer (D-CA) expressing strong opposition to the proposal.


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TCH Joins Trades Amicus in Spokeo Inc. v. Thomas Robins Jul 09, 2015

The Clearing House Association (TCH) argues that “injury in law” claims are incompatible with separation of powers principles and the protections they provide.


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TCH Files Joint-Trades Amicus in Madden v. Midland Funding Jun 26, 2015

The Clearing House Association (TCH) filed a joint-trades amicus brief with the Second Circuit requesting that the Court grant a rehearing or rehearing en banc of its decision in Madden v. Midland Funding.


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TCH Updates Its Guiding Principles for Enhancing U.S. Banking Organization Corporate Governance Jun 24, 2015

The Clearing House (TCH) released its 2015 edition of Guiding Principles for Enhancing U.S. Banking Organization Corporate Governance (Governance Principles), which aims to provide a framework for bank corporate governance that seeks to facilitate more effective board oversight, enhance bank safety and soundness, promote confidence in banks and encourage consistent supervisory guidance.

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TCH Files Joint-Trades Amicus in FDIC v. Barclays Capital Jun 11, 2015

The Clearing House Association (TCH) and SIFMA filed an amicus brief with the U.S. Court of Appeals for the Ninth Circuit arguing that extender provisions apply only to statutes of limitation.


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TCH Supports Deferral of Revenue Recognition Standard Effective Date May 29, 2015

The Clearing House submitted a comment letter to the Financial Accounting Standards Board supporting their April 29 proposed accounting standards update which would defer the effective date of the Revenue Recognition Standard from December 15, 2016 to December 15, 2017.


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TCH Joins SIFMA in Letter Opposing Bill Subjecting Out-State-Businesses to All-Purpose Jurisdiction of NY State Courts May 22, 2015

The Clearing House (TCH) joined SIFMA in a letter opposing a bill introduced in the New York State legislature that would generally subject out-of-state business organizations that apply for the authority “to do business” in the State of New York to the general (all-purpose) jurisdiction of New York State courts.

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TCH’s Russ Fitzgibbons Testifies on Cyber, Calls for Information Sharing Legislation May 19, 2015

The Clearing House’s Chief Risk Officer, Russ Fitzgibbons, testified before the House Financial Services Committee, Subcommittee on Financial Institutions and Consumer Credit, where he highlighted proactive measures to combat cyber threats taken by TCH and its Owner Banks, the financial services industry, and the government.

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TCH Comments on LEI Proposal May 19, 2015

In a letter submitted to the Fed, The Clearing House expressed continued support for the development of a uniform global LEI solution and discusses industry concerns with several technical and administrative aspects of the proposal.


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TCH Comments on Imposition of Special Measure Against Banca Privada d’Andorra May 12, 2015

TCH signed on to a letter to FinCEN with the ABA regarding the proposal to impose special measures against Banca Privada d’Andorra (BPA).


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TCH and SIFMA File Amicus Brief in FDIC v. Chase Mortgage Finance Corp. May 04, 2015

The Clearing House Association (TCH) joined SIFMA in an amicus brief in FDIC v. Chase Mortgage Finance Corp., which involves claims brought by the FDIC as receiver for Colonial Bank under the ’33 Act.  The principal issue is whether FIRREA’s FDIC extender statute displaces both preexisting statutes of limitations and statutes of repose.


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TCH Files Comment Letter to BCBS on Accounting for Expected Credit Losses Apr 30, 2015

The Clearing House Association filed a comment letter to the BCBS generally supporting the efforts of the BCBS and also noting that their guidance on accounting for expected credit losses is premature and should be reissued as a formal NPR by the U.S. standard setting agencies following implementation of an expected credit losses standard in the U.S.


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TCH Files Joint Trades Amicus Arguing FIRREA Section 1833a Should Not Apply to Self-Affecting Conduct Apr 29, 2015

The Clearing House Association (TCH), along with the ABA, the FSR, and the U.S. Chamber of Commerce filed an amicus brief with the U.S. Court of Appeals for the Second District in support of Bank of America’s appeal in the matter of United States v. Bank of America et al


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TCH Comments on Recordkeeping Requirements Related to Orderly Liquidation Authority Apr 07, 2015

The Clearing House Association and SIFMA, joined by the ABA, FSR, and ISDA, submitted  a comment letter in response to the January 7 FSOC notice of a proposed rulemaking that would implement the qualified financial contract (QFC) recordkeeping requirements outlined in the Dodd-Frank Act related to the FDIC’s receivership authority under Title II. The letter noted that the proposal is a necessary step in the implementation of effective OLA resolution strategies, but that certain aspects of the proposal are inconsistent with its purpose and statutory authority and may actually impede the FDIC’s decision making during a resolution scenario.

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