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Banking Brief: The Clearing House Working Paper Series on the Value of Large Banks Working Paper No. 4: Quantifying the Impact of Macroprudential Regulation on the Largest U.S. Banks Nov 19, 2014

In the fourth paper in its Working Paper Series on the Value of Large Banks, The Clearing House builds on and provides evidence supporting the conclusion drawn in its Third Working Paper that the cost of compliance with regulations imposed on large banks must be factored into any assessment of whether large banks enjoy an unfair funding advantage. 

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TCH Files Amicus Brief in Funds Transfer Case Nov 17, 2014

The Clearing House (TCH) filed an amicus brief in support of Deutsche Bank’s appeal to the Appellate Division of the New York State Supreme Court in Receivers of Sabena, S.A. v. Deutsche Bank AG

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TCH Comments on Proposed BitLicense Regulations Oct 20, 2014

The Clearing House Association comments to the New York Department of Financial Services on its proposed “BitLicense Regulations” for virtual currency businesses states that applying BitLicense Regulations on traditional banking entities would add duplicative regulatory burdens with no additional benefits to the public.

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Banking Brief: Resolution Strategies for Bankruptcy and Orderly Liquidation Authority Oct 09, 2014

This Banking Brief will discuss different strategies, including single-point-of-entry (“SPOE”) and multiple-point-of-entry (“MPOE”), that can be used under both provisions of the law to facilitate the orderly resolution of financial institutions.

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Banking Brief: Living Will Requirements for Banking Organizations Oct 09, 2014

The Dodd-Frank Act requires banking organizations with $50 billion or more of consolidated assets to file resolution plans annually with the Federal Reserve and FDIC.  Each resolution plan, also known as a “living will,” must describe the organization’s strategy for rapid and orderly resolution under the U.S. Bankruptcy Code in the event of the organization’s material financial distress or failure.

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TCH Files Comment Letter on FinCEN’s Customer Due Diligence Proposal Oct 03, 2014

TCH filed a comment letter supporting the significant improvements FinCEN made from its 2012 advanced notice of proposed rulemaking to codify customer due diligence (CDD) requirements.

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TCH Files Comment Letter on Proposed Changes to the FDIC’s Deposit Insurance Assessments Sep 22, 2014
The Clearing House Association (TCH) filed a comment letter with the Federal Deposit Insurance Corporation (FDIC) on its proposed rule regarding changes to the deposit insurance assessment calculation methodology. In the letter, TCH reiterates its support for maintaining a robust federal deposit insurance fund (DIF), but expresses concern that the proposed rule is inconsistent with the statutory requirement that assessments be based on actual risk to the DIF. Read More
TCH Joins Amicus Brief on Wartime Suspension of Limitations Act Sep 05, 2014

The Clearing House (TCH) joined the Chamber of Commerce and several other national trade associations in an amicus brief before the U.S. Supreme Court in Kellogg Brown & Root Services, Inc. v. United States ex rel. Carter, a case involving the Wartime Suspension of Limitations Act.

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TCH Files Comment Letter in Response to FR Y-14A/Q/M Revisions Proposal Aug 21, 2014

The Clearing House (TCH) letter asked that certain aspects of the proposal be reconsidered, as they could potentially create serious implementation difficulties and require technical corrections and clarifications.

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TCH Files Comment Letter on Proposed Amendments to the Capital Plan and Stress Test Rules Aug 11, 2014

The Clearing House Association comment letter to the U.S. banking agencies reiterates TCH’s continued support for strong capital planning, and welcomes the agencies’ revisions to important aspects of the capital plan and stress test rules in a manner that resolves several areas of on-going industry concern.

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Banking Brief: The Clearing House Working Paper Series on the Value of Large Banks: Working Paper No. 3: Assessing Funding Costs and the Net Impact of Government Policy on Large Banks Jul 29, 2014

In the third paper in its Working Paper Series on the Value of Large Banks, The Clearing House examines existing academic literature on bank funding costs, noting the significant decline in large bank funding advantages post implementation of Dodd-Frank reforms.

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TCH Files Amicus Brief in Separate Entity Case Jul 21, 2014

The Clearing House (TCH) amicus brief in Motorola Credit Corp. v. Standard Chartered Bank argues that New York’s traditional rule (i.e., that each office of a bank should be treated as a separate bank) should be retained because subjecting international banks to global service of process in attachment and garnishment orders would force them to choose between conflicting laws.

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Banking Brief: Federal Reserve Proposed Rule to Implement the Dodd-Frank Act Section 622 Financial Sector Concentration Limits Jul 18, 2014

The Clearing House Association believes that the Section 622 concentration limit should be implemented and applied in a manner that is transparent, predictable and, most importantly, avoids unnecessary and unintended restrictions on ordinary course business activity that clearly is outside of Section 622’s intended scope. 

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TCH Association President Saltzman Commends Governor Tarullo’s Remarks on Appropriately Tailoring Prudential Regulation Jul 15, 2014

The Clearing House Association President Paul Saltzman commends Governor Tarullo for his May remarks in Chicago, which emphasized the importance of appropriately tailoring the application of prudential regulation based on the size, scope, and range of activities of individual banking organizations.

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TCH Association President Paul Saltzman Calls for Greater Individual Accountability in Banking Jul 09, 2014
At the event, co-sponsored by The Clearing House Association (TCH) and the Center for Financial Policy at the Robert H. Smith School of Business at the University of Maryland, Mr. Saltzman called for a collective renewed focus on clear, prescriptive, and transparent rules that effect behaviors and produce substantive outcomes. Read More
TCH Files Comment Letter on Fed’s Proposed Rule for the Dodd-Frank Financial Sector Concentration Limits Jul 08, 2014

The Clearing House Association letter, submitted to the Federal Reserve on its proposed rule to implement Section 622 of the Dodd-Frank Act, stresses the practical importance of ensuring that Section 622 is implemented in a manner that is transparent, predictable and, most importantly, avoids unnecessary and unintended restrictions on ordinary course business activity that falls outside of Section 622’s intended scope.

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TCH Files Supplemental LCR Comment Letter Alongside Other Trades Jul 01, 2014

The Clearing House Association’s supplemental joint trades letter includes the findings of TCH’s empirical analyses, which quantify the potential impacts of the “peak day” approach and the application of the U.S. LCR NPRs to certain insured depository institutions. 

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TCH Comments on Possible OFAC Sanctions on Russia Jun 27, 2014

The Clearing House’s unsolicited letter to OFAC points out some of the adverse effects that these sanctions could have on U.S. financial institutions.

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TCH Files Amicus Brief in Bank of America v. Caulkett Jun 27, 2014

The Clearing House (TCH) joined ABA and LSTA in an amicus brief before the U.S. Supreme Court in Bank of America v. Caulkett.


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TCH Joins Trades in Comment Letter on FSB Data Gaps Initiative Statement Jun 17, 2014

The Clearing House letter to FSB seeks clarity on the timing and sequencing of the Phase 2 templates and Phase 3 QIA.

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