CCP Risk archive
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FIA and ISDA respond to MAS CP on recovery and resolution planning for market infrastructures
FIA and ISDA respond to the Monetary Authority of Singapore’s consultation on recovery and resolution planning and enhancement of resolution powers for capital market infrastructures. The response supports the proposed framework for recovery and orderly wind-down planning for capital market infrastructures, while recommending greater clarity and safeguards on certain aspects of the framework.
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FIA responds to ESMA consultation on CCP guarantees and investment policy
FIA supports expanding eligible CCP collateral for non-financial counterparties under EMIR 3.0, calling for substance-over-form recognition of letters of credit and mandatory clearing member protections.
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FIA responds to OCC's clearing fund allocation proposal
FIA supports OCC’s stress‑aligned clearing fund allocation, noting improved fairness and risk sensitivity, while encouraging smoothing measures to avoid volatility and monitoring potential metric overlaps.
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FIA responds to CFTC retail DCO request with suggestion for simplified regulatory approach
FIA invites the CFTC to consider a modified regime for fully collateralized and pre-funded clearing models, including those catering to retail traders.
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FIA and ISDA respond to CPMI-IOSCO consultation on general business losses
FIA and ISDA backed CPMI-IOSCO proposals, urging clearer prescriptive treatment of FMI general business losses, stronger resources, consistent scenarios, transparency, and rejecting margin gains haircutting.
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FIA responds to CCIL consultation on capped member liability
FIA submitted comments to the Clearing Corporation of India Limited's consultation on revising the capped member liability framework for Default Fund replenishment. FIA welcomed CCIL’s aim to improve transparency and predictability of members’ potential unfunded Default Fund exposure.
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FIA responds to ESMA consultation on CCP participation requirements
FIA has responded to the European Securities and Markets Authority's consultation on EMIR 3.0 draft regulatory technical standards on the elements to be considered when EU central counterparties define participation requirements. The response highlights the need for CCPs to assess clearing members based on the actual risks they pose, rather than relying on entity type or licensing status as proxies for risk. In particular, the response distinguishes between regulated non-bank financial clearing members and non-financial counterparties that typically clear to hedge commercial exposures and do not provide financial services.
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FIA responds to CFTC on the use of tokenized collateral and on the report of the President's Working Group on Digital Asset Markets
FIA has filed comments with the CFTC on tokenization, stablecoins and digital asset market structure.
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FIA responds to Bank of England consultation on CCP resilience
FIA's response to the BoE on CCP resilience advocates against financial incentives for porting and recommends enhancements to margin models in UK EMIR.
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FIA supports FICC-CME customer cross-margining proposal for U.S. treasuries
FIA has submitted a comment letter to the CFTC and SEC supporting FICC and CME's proposed arrangement for cross-margining of customer trades in treasuries and treasury futures with offsetting risk. The proposed arrangement is under review at both the CFTC and SEC.
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