The Clearing House Association, along with four other trade associations, submitted a letter to the FRB requesting an extension of the comment deadline with respect to the Board’s proposed rules implementing Sections 165 and 166 of Dodd-Frank. In light of the scope and complexity of the rule, TCH requested that the deadline be extended from March 31 to May 31. On March 2 the FRB extended the comment period deadline of its Section 165/166 NPR from March 31 to April 30.