Issues
Advanced Search

Advanced Search

Close
 
Issues
TCH Leads Industry Comment Letter to Fed on Proposed Capital Surcharge for U.S. G-SIBS Apr 02, 2015

The Clearing House Association (TCH), joined by the Securities Industry and Financial Markets Association (SIFMA) and the Financial Services Roundtable (FSR), filed a comment letter with the Federal Reserve in response to its proposal to impose an additional capital surcharge requirement on U.S. global systemically important bank holding companies suggesting that the proposal be revised to better reflect the actual systemic risk posed by U.S. G-SIBs.

Read More
TCH Provides Recommendations to the Basel Committee on Its Proposed Revisions to the Standardized Approach for Credit Risk and Capital Floors Mar 26, 2015

In a letter to the Basel Committee The Clearing House identifies areas where the proposed revisions to the standardized approach for credit risk and capital floors should be modified to better achieve the Committee’s stated objectives of making the Standardized Approach more risk-sensitive, reducing reliance on external credit ratings and strengthening the comparability of risk-weighted asset calculations across jurisdictions.

Read More
TCH Comments on CFPB’s Proposal to Regulate Prepaid Accounts Mar 23, 2015

In a letter submitted to the CFPB The Clearing House recommends that consumers should receive the same protections under consumer financial laws regardless whether the products and services they obtain are provided by a depository institution or a nonbank.

Read More
TCH President Paul Saltzman Calls for a “Dual Mandate” Approach to Financial Regulation that Balances Financial Stability and Economic Growth Mar 18, 2015

Paul Saltzman, President of The Clearing House Association, addressed the Exchequer Club in Washington, D.C. where he discussed the need for greater regulatory focus on achieving a banking system that is not only safe and stable but also resilient. 

Read More
TCH Calls on FinCEN to Address SAR Sharing Restrictions Mar 13, 2015

The Clearing House submitted a comment letter to FinCEN requesting guidance that will better enable banks to share suspicious activity reports (SARs) within their international organizations for enterprise-wide AML compliance purposes.

Read More
Banking Brief : Banking Brief: Overview of Total Loss Absorbing Capacity Feb 20, 2015

In November 2014, the Financial Stability Board (“FSB”) proposed international standards for total loss absorbing capacity (“TLAC”) that a global systemically important bank (“G-SIB”) would be required to maintain to facilitate its orderly resolution should it fail.

Read More
TCH Strongly Supports Regulatory Capital Rules Proposal Feb 17, 2015

The Clearing House Association filed a comment letter with U.S. bank regulators on proposed revisions to the U.S. Basel III capital rules for banks with consolidated total assets of at least $250 billion and consolidated on balance sheet foreign assets of at least $10 billion, expressing its strong support for the proposed revisions.

Read More
TCH and LSTA File Amicus Brief in In Re Motors Liquidation Co Feb 13, 2015

The Clearing House Association (TCH) and the Loan Syndications and Trading Association (LSTA) amicus brief highlights the critical importance of the ability of syndicate lenders to rely on the limits set forth in their formal agreements to restrict their agents’ authority to act on their behalf.

Read More
TCH Comments on CSBS Model Framework for Virtual Currency Activities Feb 13, 2015

The Clearing House Association (TCH), joined by the Independent Community Bankers of America (ICBA), submitted a letter to the Conference of State Bank Supervisors regarding the draft model regulatory framework for virtual currency activities.

 

Read More
TCH Submits Comment Letter on Vintage Disclosures Feb 10, 2015

The TCH letter urged FASB to consider alternatives to this approach, such as enhancing existing credit quality disclosures including, where appropriate, requiring additional disclosures of certain higher risk loan portfolios.

Read More
TCH Amicus Brief Supports Citibank Motion in Argentine Debt Case Feb 09, 2015

The brief, in NML Capital, Ltd v. Republic of Argentina,  argues that under principles of law and international comity, a U.S. court should not order a U.S. bank’s overseas branch to violate its host country’s law, especially where that law is consistent with U.S. law.

Read More
TCH Supports Business Judgment Rule Protection for Bank Directors and Officers Feb 06, 2015

The Clearing House amicus brief, in FDIC v. Rippy, highlights the public policy rationale for, and critical importance of, the protection from liability offered to directors and officers by the business judgment rule.

Read More
TCH Files Comment Letter to NACHA Supporting Same-Day RFC Feb 06, 2015

In a letter to NACHA TCH suggested improvements to the proposal including adopting a different indicator in the Batch Header Record to identify transactions for same day processing and settlement, rather than relying on the Effective Entry Date, and encouraged NACHA to consider leveraging additional evening settlement windows as a future enhancement to the same day ACH capabilities  in light of the expanded operating hours of the Federal Reserve Banks’ National Net Settlement Service.

Read More
TCH Supports TLAC to Help Ensure G-SIBs Can Be Resolved in an Orderly Manner without Taxpayer Assistance Feb 02, 2015

The Clearing House Association, in coordination with ABA, FSR, and SIFMA, filed a letter with the Financial Stability Board in response to its proposal to impose a total loss absorbing capacity (TLAC) requirement on global systemically important banking groups (G-SIBs). The letter expresses the industry’s strong support for a TLAC requirement for G-SIBs to help ensure that these institutions can be resolved in an orderly way at creditor rather than taxpayer expense, bringing us one final step closer to ending “Too Big to Fail.”

Read More
TCH Recommends Liquidity Monitoring Report Proposals Be Revised to Be More Consistent with the Liquidity Coverage Ratio Feb 02, 2015

The Clearing House Association, in coordination with ABA, FSR, and IIB, filed a letter with the Federal Reserve on its proposed revisions to two important supervisory liquidity reports, the Complex Institution Liquidity Monitoring Report (FR 2052a) and the Liquidity Monitoring Report (FR 2052b). In the letter, the associations suggest a number of recommendations that would more closely conform these liquidity reports with the requirements of the Liquidity Coverage Ratio (LCR) and international standards.

 

Read More
TCH Files Brief in Bankruptcy Case Jan 13, 2015

The Clearing House (TCH) filed an amicus brief in support of Bank of America’s cert. petition in Bank of America v. Caulkett.


Read More
The Clearing House Calls on FSOC to Address CCP Systemic Risk Jan 09, 2015

The Clearing House Association (TCH) submitted a letter to the Financial Stability Oversight Council (FSOC) urging it to lead a coordinated effort of its member regulatory agencies to address and mitigate systemic risk arising from increasing market reliance on central counterparties (CCPs).  In the letter, TCH details a set of concrete recommendations that would subject CCPs to more stringent standards and help ensure that their risks are more carefully managed and mitigated.

Read More
TCH Highlights the Importance of Flexibility in Governance Structures and Practices in Comment Letter on BCBS Bank Governance Proposal Jan 09, 2015

In the letter The Clearing House Association states support for corporate governance framework aimed at enhancing bank safety and soundness, promoting confidence in banks, and encouraging consistent supervisory guidance.

Read More
TCH Submits Sectoral Sanctions Letter to OFAC Dec 11, 2014

The Clearing House Association in coordination with ABA, IIB, and SIFMA submitted a letter to OFAC regarding the Ukraine-Related Sectoral Sanctions.

Read More
TCH Comments on Margin and Capital Requirements for Covered Swap Entities Nov 24, 2014

In the letter, the Associations urge the regulators to use their statutory discretion to exclude inter-affiliate swap transactions from margin requirements, consistent with the risk-based approach to implementation contemplated by the relevant statute.

Read More
< 4 5 6 7 8 9 10 11 12 13 >