On November 20, the Institute of International Finance (IIF), together with ISDA and FIA, submitted a response to the Financial Stability Board's (FSB) Consultation report on the topic of CCP resolution resources and tools.

In the letter, we welcome the FSB’s ongoing focus on the important topic of adequacy and impact of CCP financial resources for recovery and resolution and the qualitative analysis on financial resources and tools against the relevant considerations set out in the FSB Key Attributes of Effective Resolution Regimes for Financial Institutions and accompanying guidance on CCP resolution to support CCP resolution objectives. Identifying several issues in the consultation report, we encourage the FSB to enhance transparency and predictability, to ensure appropriate calibration and aligning incentives, and to balance the continuum of recovery and resolution.