In his statement, The Clearing House CEO Jim Aramanda noted that  although the final rule appears to include some improvements to the proposal, The Clearing House (TCH) remains concerned that the final rule failed to address a number of significant flaws identified in our comment letter. These remaining flaws will have meaningful and negative consequences, especially for the robustness and liquidity of markets served by activities disproportionately impacted by the final rule, and will result in adverse impacts to customers and the real economy.

The Clearing House (TCH) welcomed the Consumer Financial Protection Bureau’s (CFPB) release of its “Consumer Protection Principles” for faster payment systems. TCH agrees with the CFPB’s views on the importance of protecting consumers that use faster payments, and strongly supports making consumers’ interests a key consideration as the industry works to build a new real-time payment system.

The Clearing House Association (TCH) released its updated Guiding Principles for Enhancing U.S. Banking Organization Corporate Governance (Governance Principles). TCH’s Governance Principles aim to help 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. 

The Clearing House’s (TCH) Chief Risk Officer Russell Fitzgibbons stressed the importance of continued improvement in collaboration between the private sector and the government in combating cyberattacks and emphasized the need for comprehensive cyber threat information-sharing legislation at a House Financial Services subcommittee hearing on protecting critical financial services infrastructure. 

The Protecting Cyber Networks Act (H.R. 1560) and the National Cybersecurity Protection Advancement Act (H.R. 1731), will help better protect Americans’ sensitive personal information by facilitating more effective information sharing between the government and private sector which is critical to detecting and preventing cybercrime. The Clearing House is, however, disappointed that the House adopted amendments to both bills that will require them to sunset in seven years. These threats will not sunset and we need to ensure certainty and consistency for the long term. 

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.

In a comment letter filed with the Basel Committee on Banking Supervision in response to its “Revisions to the Standardized Approach for Credit Risk and Capital Floors: The Design of a Framework Based on Standardized Approaches” The Clearing House identifies areas where the Proposals 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.

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.

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.

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.

Today, The Clearing House Association (TCH), 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.”

Late last Friday, The Clearing House Association (TCH) filed a comment letter with the Basel Committee on Banking Supervision in response to its “Corporate Governance Principles for Banks” consultative document, which the Basel Committee published for public comment in October 2014.  In the letter, TCH recommends certain changes designed to better delineate the board of directors’ responsibility for oversight of the business of a bank as distinct from management’s responsibility for the day-to-day operations, clarify the nature of director fiduciary duties, and reinforce the importance of giving each banking organization sufficient flexibility to tailor its governance practices to its business and risk profile.

The Clearing House welcomed NACHA’s proposal to move toward a ubiquitous, same-day ACH settlement capability. Together with today's already efficient ACH, Same Day ACH and real-time payments will provide distinct payment options for customers.

On October 22, TCH and its Owner Banks announced plans to undertake a multi-year effort to build a real-time payment system to better meet consumers’ and businesses’ expectations in an increasingly digital economy. The real-time payment system will be designed to address gaps in payment options and will enable consumers and businesses to securely send and receive immediate payments directly from their accounts at financial institutions. Implementing ubiquitous real-time payments is a comprehensive multi-year endeavor, requiring coordination among financial institutions of all sizes and their service and technology providers. The innovative real-time system will be designed to address unmet customer needs and allow them to initiate payments directly from their bank accounts in a safe and secure manner.

The Clearing House Association (TCH) today released two updated guiding principles drafts as part of an effort to assist banks as they work to address two timely issues facing the industry. The first, Guiding Principles for Enhancing Banking Organizations’ Corporate Governance, updates TCH’s previous guiding principles on the issue published in 2012.  The guiding principles are intended to provide banking organizations direction on core corporate governance issues. The second, Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking, last published in 2002, is 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) obligations.

The Clearing House Association (TCH) submitted a comment letter to the U.S. banking agencies expressing general support for the agencies’ proposed revisions to the supplementary leverage ratio and providing suggestions for additional improvements.

The Clearing House Association (TCH) submitted a comment letter to the Office of the Comptroller of the Currency (OCC) today in response to the agency’s January 2014 proposed guidelines that would establish minimum standards for risk governance and bank boards of directors for banks with $50 billion or more in total consolidated assets. In its letter, TCH reiterates its strong support for the primary objective of the guidelines – a strong and effective risk management framework for banks – but recommends clarification of certain key aspects of the proposed guidelines in order to ensure that they achieve their stated purpose.

TCH led a joint industry effort to comment on the U.S. LCR proposal, authoring a comprehensive comment letter that strongly supports U.S. implementation of the LCR as an important step in strengthening the resiliency of banks and the stability of the financial system.

The Clearing House Association (TCH) submitted a comment letter to the Bank of England (BOE) in response to the BOE’s October 2013 discussion paper outlining a proposed stress testing framework for the UK banking system.

The Clearing House finds that U.S. and Basel proposals would make leverage ratio the binding constraint for the banking industry.

The Clearing House finds that U.S. and Basel proposals would make leverage ratio the binding constraint for the banking industry.

The Clearing House is working with the nation’s leading financial institutions to develop an industry-wide credentialing solution designed to help improve the future safety and soundness of digital payments.