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The letter to the Federal Reserve on its reproposal of the single-counterparty credit limit (SCCL) requirement of the Dodd-Frank Act, notes substantial improvements included in the March 2016 reproposal, and details some problematic aspects that still remain that could make the rule needlessly difficult to implement and in some instances unworkable.
The Clearing House and the International Swaps and Derivatives Association today issued a white paper identifying key issues that regulators should consider as they develop a comprehensive resolution framework for systemically important CCPs.
The Clearing House (TCH) issued a report, The Role of the Board of Directors in Promoting Effective Governance and Safety and Soundness for Large U.S. Banking Organizations, to serve as a resource to both banks and their supervisors about the respective roles of directors and management. The report highlights the growing responsibilities and emphasis being placed on banking organizations’ board of directors by U.S. regulators. It also provides recommendations to regulators on how best to address what is often seen as a divergence between the role of the board, which is one of oversight, and regulatory compliance-related expectations for directors which at times may overlap with management’s responsibility.
The Clearing House (TCH), in conjunction with FIS, late last Friday submitted a proposal for evaluation of its Real-Time Payments (RTP) system to the Federal Reserve’s Faster Payments Task Force. The Clearing House is working to deliver a ubiquitous, real-time payments system for the U.S. and FIS will help achieve ubiquity by offering enhanced RTP services to more than 3,000 financial institutions.
In a letter to the Federal Reserve Board, The Clearing House (TCH) calls for the proposal for implementing a countercyclical capital buffer to be revised to ensure that any future decision to establish a countercyclical capital buffer is subject to notice-and-comment rulemaking, as required by the Administrative Procedure Act. The letter also suggests that the proposal be empirically grounded.
Late Friday, The Clearing House, the Securities Industry and Financial Markets Association, the American Bankers Association, the Financial Services Roundtable, and the Financial Services Forum submitted comments to the Federal Reserve in response to its proposal to impose total loss absorbing capacity, long-term debt and related “clean holding company” requirements on global systemically important banking groups (G-SIBs). The associations express the industry’s strong support for a TLAC requirement for G-SIBs, which is a crucial aspect of ending “Too Big to Fail” by helping ensure that these institutions can be resolved in an orderly way at the expense of creditors and shareholders (and not taxpayers). The associations also assert that the proposal contains a number of requirements that are counterproductive or unnecessary to achieving the Fed’s policy objectives. In response, the associations provide a number of suggestions aimed at making the proposal more workable and effective.
The Clearing House Association (TCH) today published a final updated version of its Guiding Principles for Anti-Money Laundering Policies and Procedures in Correspondent Banking. The Guiding Principles, which were initially published in 2002, are intended to provide guidance to U.S. banks engaged in foreign correspondent banking and to assist U.S. banks in implementing key anti-money laundering (AML) procedures.
The Clearing House (TCH) provided recommendations to the Committee on Payments and Market Infrastructures (CPMI) in response to CPMI’s recent report on concerns about the safe and efficient functioning of the correspondent banking market and potential measures to improve the correspondent banking environment. In its letter, TCH agreed that technical improvements to information sharing and similar anti-money laundering and counterterrorism financing tools may be helpful in improving access to correspondent banking services. However, TCH also stressed that it is just as important that policymakers and banks work together to better and more clearly define the roles and responsibilities of various stakeholders.
This working paper says payments systems need to evolve to deliver new value to users, support appropriate risk management, and reward innovation and investment.
On September 18, The Clearing House Association (TCH) submitted a letter to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) recommending that global supervisory authorities require central counterparties (CCPs) to adopt four key enhancements to CCP risk governance and member consultation processes.