7 February 2022

CPMI Secretariat
[email protected]
IOSCO Secretariat
[email protected]

Re: Discussion Paper on Client Clearing: Access and Portability (the “Discussion Paper”) by the Committee on Payments and Market Infrastructures (“CPMI”) and the Board of the International Organization of Securities Commissions (“IOSCO”)

Dear Secretariats:

The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG” or “AMG”)1 appreciates the important work of CPMI and IOSCO (collectively, the “Supervisory Authorities”) in assessing issues related to developing models for client clearing and the potential benefits, risks, and challenges associated with each model – with a focus on the porting of positions should the clearing access sponsor (“CCSP”) fail. Especially as the Supervisory Authorities are considering potential enhancements to aspects of the existing clearing model, SIFMA AMG also appreciates this work to identify issues related to emerging practices so as to enhance the resiliency of central counterparties (“CCPs”), clearing members (“Intermediaries”) and the overall market for participants (“clients”).

Overwhelmingly, SIFMA AMG members have embraced the transition of the over-thecounter market to clearing. Our members have been consistent, engaged supporters of the global mandates for the central clearing of standardized derivatives, and have worked closely with global regulators, with CCPs, and with CCSPs to enhance the regulatory framework for central clearing so that it is a resilient structure to facilitate healthy, growing cleared markets. SIFMA AMG has long advocated for a globally harmonious, risk-appropriate, and efficient ruleset targeting improvements with respect to CCP capital, transparency and governance, and margin.

Our members applaud the CPMI-IOSCO Steering Group in directing the Policy Steering Group (“PSG”) to:

(1) develop knowledge and understanding regarding new access models;
(2) develop knowledge and understanding of current porting processes in place at CCPs;
(3) consider possible approaches to facilitate access and portability arrangements; and
(4) consider the potential benefits, risks, and challenges that new access models and potential solutions may bring with respect to access.