The Clearing House Association (TCH) submitted a comment letter to the SEC on the Commission’s study on expanding the scope of private litigant securities fraud lawsuits to include those involving fraudulent acts occurring outside of the U.S. TCH expressed its belief that (i) the SEC should recommend to Congress that it not expand the Exchange Act’s private right of action to purchase and sales of securities that occur outside the U.S., and (ii) that under Morrison v. National Australia Bank the Exchange Act’s private right of action does not cover any purchase or sale of a security conducted outside the U.S. TCH’s comment letter was joined by the IIB and ABASA.