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TCH Comment Letter Contends That Tools for Recovery Should Be Tailored for Individual Financial Market Utilities

The Clearing House Association filed a comment letter with the Committee on Payment and Settlement Systems (CPSS) of the Bank for International Settlements and the Board of the International Organization of Securities Commissions (IOSCO) on their consultative report, Recovery of Financial Market Infrastructures, which proposes that all FMI, such as TCH, have in place comprehensive and effective plans to recover from threats to their viability and continue to provide essential services. TCH supports this overall goal, but the comment letter states that tools for recovery should be tailored to meet the particular circumstance of individual FMIs, including the risks they face and their organizational and ownership structures.