The Clearing House (TCH) has filed a comment letter requesting a broader exemption to FinCEN’s proposed Report of Foreign Bank and Financial Accounts (FBAR) requirements. In the letter, TCH notes that while the proposed regulations generally make the FBAR requirements more consistent with the statutory purpose of gathering or maintaining information that has a “high degree of usefulness in criminal, tax, or regulatory investigations or proceedings,” there are a number of other issues that should be addressed before the proposed regulations are finalized.  In that regard, TCH expressed its support for a number of recommendations made on behalf of several TCH member banks in a separately filed letter on May 9, 2016.