The Clearing House (TCH) filed a comment letter with the Federal Reserve on the proposed amendments to the Capital Plan and Stress Test Rules. The comment letter supported the Federal Reserve’s proposal to eliminate the qualitative portion of CCAR for “large and noncomplex” firms and the proposed transition rules for firms crossing the $50B threshold. Additionally, the comment letter requested clarification regarding the supervisory and review process for firms no longer subject to the qualitative assessment.  Lastly, the comment letter strongly suggested that the Federal Reserve maintain the current de minimis threshold of 1%.