The Clearing House Association submitted a letter to the Office of the Comptroller of the Currency (OCC) commenting on its proposal to implement Section 1044 of the Dodd-Frank Act. TCH endorsed much of the preemption framework proposed by the OCC. The comment letter noted that Section 1044 merely codified the existing preemption standard and was not an attempt to create a new, narrower formulation. The letter also addressed process issues related to preemption determinations, existing OCC regulations that are affected by the proposed rule, and the important market and operational impacts that may occur if the existing framework is altered. Last, TCH also addressed specious arguments linking Federal preemption to the subprime mortgage crisis. On July 21 the OCC published in the Federal Register its final rule on preemption. The final rule largely tracks the initial proposal and incorporates several substantive comments made by TCH Association.