ISDA’s letter to the CFTC in response to the Notice of Proposed Rulemaking regarding Clearing Member Risk Management (the “NPR”, and the rules it describes, the “Proposed Rule”) issued by the Commodity Futures Trading Commission (the “Commission”), seeking comments on proposed rules regarding risk management for cleared trades by futures commission merchants (“FCMs”), swap dealers(“SDs”) and major swap participants (“MSPs”) that are clearing members.