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TCH Files Comment Letter with International Policymakers on CCP Risk Governance Issues

The Clearing House Association (TCH) submitted a letter to CPMI/IOSCO recommending enhancements to current central counterparty (CCP) risk governance practices and clearing member consultation processes.  TCH urges global regulators to require all CCPs to: (i) establish CCP advisory risk committees (RC) with mandatory composition requirements and clearly articulated mandates; (ii) solicit and consider the input of the advisory RC and clearing members with respect to material risk matters that could impact a CCP’s risk profile or clearing member liability or exposure; and (iii) report to relevant regulatory authorities those instances in which a CCP’s decision on a material risk matter conflicts with the recommendation of the RC or clearing members.