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TCH Joins Trade Comment Letter to FSB on Essential Aspects of CCP Resolution Planning

The Clearing House (TCH), along with the FIA, GFMA, the IIF, and ISDA (Associations) filed a comment letter responding to an FSB Discussion Note on the Essential Aspects of CCP Resolution Planning. The Associations express support for the Discussion Note, recognizing it as an important step towards addressing the financial disruption that could occur in the unlikely event that a CCP fails.  The Associations note that if a CCP experiences distress, they support a CCP-led recovery in accordance with a clear and transparent CCP rulebook. The Associations recognize, however, that a CCP-led recovery should not continue if recovery measures would cause contagion in the market, negatively impact financial stability, increase moral hazard (e.g., by promising to “bail out” owners of for-profit CCPs), irreversibly erode confidence in a CCP’s management or erode resources beyond the point at which a resolution authority could successfully intervene.