The Clearing House Association filed a separate 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 although nonbank financial companies supervised by the Fed are included in Treasury's proposed assessments, none have yet been designated which in turn imposes the full burden of the assessments on banks. This letter also argues that Treasury should consider the equitable distribution of assessments given that currently all of the assessment burden would fall on banks but much of the OFR's and the FSOC's expenses have been, and are likely to continue to be, attributable to the agencies' responsibilities to research, oversee, and manage the systemic risks associated with nonbank financial companies.