3 October 2022

CPMI Secretariat
[email protected]

IOSCO Secretariat
[email protected]

Re: Discussion Paper on Central Counterparty Practices to Address Non-default Losses (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 how central counterparties (“CCPs”) address non-default losses (“NDLs”), including scenarios that could lead to NDLs, how NDLs can be quantified, and assessing the sufficiency of resources and tools to manage NDL risk. SIFMA AMG appreciates the Supervisory Authorities’ attention to CCP risk given global clearing mandates which can expose our members to the risk of a CCP failure and the possibility of incurring losses arising from such a failure. We applaud the Supervisory Authorities for their efforts to enhance the resiliency of CCPs for participants such as our members and their investors.

Overwhelmingly, SIFMA AMG members have embraced the transition of the over-the-counter 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 clearing members, and with CCPs 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 transparency, governance, capital, and margin.

1 SIFMA AMG brings the asset management community together to provide views on policy matters and to create industry best practices. SIFMA AMG’s members represent U.S. and multinational asset management firms whose combined global assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds.