The Clearing House (TCH) filed a comment letter with the BCBS on its consultation entitled Reducing variation in credit risk-weighted assets – constraints on the use of internal model approaches, which would both (i) eliminate a substantial proportion of banking organizations’ credit exposures from the advanced internal ratings based approach (the “A-IRB Approach”) altogether in favor of the Standardized Approach, and (ii) permanently circumscribe A-IRB Approach capital measures for a separate substantial portion of banking organizations’ credit exposures, including by imposing various standardized exposure and model parameter floors and constraints on model estimation practices. In the letter, TCH discusses the importance of providing banking organizations with the opportunity to evaluate holistically the entire package of revisions to the Basel III capital framework and the data upon which the revisions are based. Additionally, the letter expresses concern that the effect of the recent proposals will be to fundamentally change the way in which risk-weighted assets are calculated and to increase capital requirements without properly considering and accounting for the reality that stressed measures of risk-weighted assets as implemented by national jurisdictions—not the regulatory minimums—represent the true binding constraint for many banking organizations.