The Clearing House Association, along with four other trade associations, filed a comment letter to Treasury regarding its NPR proposing an assessment on bank holding companies and nonbank financial companies supervised by the Fed with assets over $50 billion in order to provide funding for the Office of Financial Research, FSOC, and the orderly-liquidation authority start-up activities of the FDIC.

The letter argues that, among several other concerns, (i) to ensure maximum accountability and efficiency, OFR expenses and budgeting process should be transparent, open to public comment, and subject to robust governance and controls, (ii) the assessment schedule should ensure that assessments are reasonably allocated between the industry and the Fed and generally ensure fairness, and (iii) Treasury should clarify the conditions and procedure under which a company ceases to be an assessed company.