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. The letter offers specific recommendations with respect to CCP governance (including clearing member involvement), designing the margining system and stress testing framework, and sizing the CCP’s own loss absorbing resources, among other things.