The Clearing House Association and Payments Company filed a comment letter to the FRB regarding risk management standards for FMUs under Section 804 of the DFA and standards for determining when a designated FMU must provide advance notice of a proposed material change to its rules, procedures, or operations under Section 806 of the DFA. The letter argues that the proposed risk management standards demonstrate that ACH clearing and settlement arrangements do not pose the kind of systemic risk contemplated in the DFA, and further suggests that the Board’s proposed definition of materiality for advance notice of changes to rules, procedures, or operations should be crafted more narrowly and the review process provide for more streamlined reviews.