Public Comment, Adjustment Guidelines, Clearing House

Jeffrey P. Neubert Chief Executive Officer 100 Broad Street New York, NY 10004 Tele 212.613.0103 FAX 212.613-9811 jeffrey.neubert@theclearinghouse.org March 23, 2006 Mr. Robert E. Feldman Executive Secretary Federal Deposit Insurance Corporation th550 17 Street, NW Washington, DC 20429 Attn: Comments Re: Adjustment Guidelines Dear Mr. Feldman: The Clearing House Association L.L.C. (“The Clearing House”), an association of 1major commercial banks, appreciates the opportunity to comment on the Federal Deposit Insurance Corporation (the “FDIC”) notice of proposed assessment rate adjustment guidelines for large institutions and insured foreign branches in risk category I (the “Guidelines”). 72 Fed. Reg. 7878 (Feb. 21, 2007). The Guidelines were issued by the FDIC to clarify the analytical processes, and the controls applied to these processes, in making assessment rate adjustment determinations pursuant to the FDIC’s Final Assessments Rule (the “Rule”). 71 Fed. Reg. 69282 (Nov. 30, 2006). As we previously indicated in our comment letter on the proposal that became the Rule (the “Proposal”), the Clearing House appreciates the effort that the FDIC has undertaken to improve the deposit insurance system, and we agree with the basic objectives identified by the FDIC as guiding this effort (sensitivity to risk, fairness, avoidance of subsidization, consistency and reasonableness). The Clearing House also strongly supports the Guidelines’ key objectives ...