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Risk Management and CCPs

The Clearing House

Policymakers continue to focus on managing and mitigating systemic risks in the financial system, including the emerging risks posed by regulatory requirements that standardized over-the-counter derivatives should be cleared through central counterparties. TCH strongly supports efforts to address and mitigate systemic risks and works to inform these efforts as well as encourage continued domestic and international regulatory cooperation.


Recent Highlights

TCH Responds to BCBS Step-in Risk Proposal

May 15, 2017

The Clearing House letter is supportive of the Basel Committee’s revisions to the proposed guidelines for the identification and management of step-in risk. However the letter notes numerous aspects of the proposal that need to be updated in order to achieve the Basel Committee’s objectives of sensitivity to residual step-in risk and simplicity of the framework. 

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TCH and Other Associations Submit Comments to CPMI-IOSCO to Further the Safety and Soundness of CCPs

Oct 18, 2016

The Clearing House (TCH), along with the FIA, GFMA, the IIF, ISDA (Associations) filed a comment letter responding to a CPMI-IOSCO consultation on the Resilience and recovery of central counterparties (CCPs): Further guidance on the PFMI. The Associations support the Consultative Report as another important step towards enhancing the safety and soundness of CCPs, and provide recommendations to further the goal of effective resilience, recovery, and resolution mechanisms for CCPs.

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TCH Files Comment Letter on Fed’s SCCL Reproposal

Jun 3, 2016

The letter to the Federal Reserve on its reproposal of the single-counterparty credit limit (SCCL) requirement of the Dodd-Frank Act, notes substantial improvements included in the March 2016 reproposal, and details some problematic aspects that still remain that could make the rule needlessly difficult to implement and in some instances unworkable.

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TCH Provides Recommendations to the Basel Committee on Its Proposed Revisions to the Standardized Approach for Credit Risk and Capital Floors

Mar 26, 2015

In a letter to the Basel Committee The Clearing House identifies areas where the proposed revisions to the standardized approach for credit risk and capital floors should be modified to better achieve the Committee’s stated objectives of making the Standardized Approach more risk-sensitive, reducing reliance on external credit ratings and strengthening the comparability of risk-weighted asset calculations across jurisdictions.

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The Clearing House Calls on FSOC to Address CCP Systemic Risk

Jan 9, 2015

The Clearing House Association (TCH) submitted a letter to the Financial Stability Oversight Council (FSOC) urging it to lead a coordinated effort of its member regulatory agencies to address and mitigate systemic risk arising from increasing market reliance on central counterparties (CCPs).  In the letter, TCH details a set of concrete recommendations that would subject CCPs to more stringent standards and help ensure that their risks are more carefully managed and mitigated.

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TCH Comment Letter to OCC on Proposed Heightened Standards Offers Support, Suggests Clarification of Certain Aspects of Proposed Guidelines

Mar 28, 2014

The Clearing House Association’s letter to the Office of the Comptroller of the Currency (OCC) reiterates its strong support for the primary objective of the guidelines – a strong and effective risk management framework for banks – but recommends clarification of certain key aspects of the proposed guidelines in order to ensure that they achieve their stated purpose.

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