The Clearing House Association’s comment letter expresses deep concerns that the implementation of the proposed Volcker Rule will negatively impact U.S. and global financial markets, the safety and soundness of banking entities, and the recovery of the U.S. economy. TCH urges the agencies to reject the proposed plan to implement the rule in a highly restrictive manner and instead revise the rule during the conformance period to reduce unnecessary harm to the markets, customers and financial institutions resulting from overly restrictive regulations. TCH believes that (i) the assumption that only limited damage would occur and that the financial system will be self-correcting at some future point is both unproven and risky, (ii) the loss of the ability to engage in certain parts of the market-making business may force banking entities to consider shuttering the entire business, (iii) the global markets will adapt quickly to any major regulatory change, and, once they adapt, the competitive position of the U.S. financial system and individual affected banking entities will suffer irreparable damage.