FIA has 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. It also expressed broad support for delinking the liability cap from resignation and applying an assessment cap independently of resignation.
The submission also flagged areas for refinement. The main concern was that the proposed 5x multiplier may be high and could create significant liquidity demands during stress. The submission suggested considering a lower cap (around 2x) or providing clearer calibration rationale. FIA also highlighted operational complexity from the rolling 30-day window and Default Fund resizing and suggested simplifying the structure.
Read full response here.
