The Clearing House (TCH) submitted a comment letter to the Fed generally supporting the proposal’s: (i) indefinite suspension of the incorporation of the advanced approaches, (ii) elimination of the Tier 1 common ratio calculation, and (iii) modification of capital action assumptions to better align with the October 2014 amendments. Additionally, while TCH appreciates the proposal’s delay of the incorporation of the supplementary leverage ratio (SLR) for one year, TCH expressed continuing concern that such extension does not permanently resolve the underlying problem of the SLR likely becoming the binding capital constraint for many advanced approaches banking organizations.
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