IIF Authors

Status: Will be live at 03/29/2017 00:00

Joint Response to FSB CD: Guidance on CCP Resolution and Resolution Planning

Wednesday, March 29, 2017

While the FSB had incorporated a number of industry's suggestions in the Guidance Paper, the industry submission highlighted several areas where the current proposals could be of concern. These include potential for forced allocation of contracts, initial margin haircutting, the treatment of non-default losses, compensation for loss and the importance of clearing participants being able to determine and limit their exposure. An overarching theme of the submission is the need for greater transparency in relation to both the resolution authority's powers and the CCP's rules and arrangements.