The Clearing House Association submitted its October 12, 2010 comment letter on alternatives to the use of credit ratings to the SEC and the NCUA in response to their NPRs. As does the TCH letter submitted to the federal banking agencies, each of these letters expresses concerns about any complete removal of references to, or requirements of reliance on, credit ratings in the agencies’ regulations, notes international regulators’ concerns, offers possible alternatives and its cooperation in working with regulators to develop others, and urges the agencies to allow external credit ratings to continue to be used within the constraints imposed by Dodd-Frank.