The Clearing House (TCH) filed a comment letter with the Federal Reserve expressing support for the Fed’s important step forward to improve the ratings framework for large bank holding companies by proposing new standards that are clearly articulated and appropriately focused on safety and soundness. TCH’s letter offers recommendations for further refinements that would help achieve the rating system’s safety and soundness objective. In particular, TCH letter recommends that the criteria by which firms would be placed into or out of the transitory Satisfactory Watch rating should be revised and clarified to better align its use with the emergence and remediation of material issues. The letter also suggests that a firm’s “well managed” status should be the result of a holistic assessment of the institution, and that horizontal supervisory assessments should be used to gather information and assess compliance with already articulated standards.
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