On October 11, ISDA, the Institute of International Finance Inc. (IIF) and The Clearing House (TCH) submitted their response to the CPSS-IOSCO consultative report, Recovery of financial market infrastructures, issued for comment on August 12, 2013. The report offers guidance related to financial market infrastructures (FMIs) recovery and provides a meaningful response to ensure a viable framework is adopted. Effective recovery, continuity and resolution mechanisms for FMIs are critical to the efficient operation and sustainability of the financial markets. The Associations’ response focuses on central counterparties (CCPs) which will arguably become the most systemically relevant infrastructure in the financial markets as a result of regulatory reform already enacted. Also attached is the ISDA CCP Loss Allocation at the End of the Waterfall technical paper (issued in August 2013) which forms part of the Associations’ response to this report.
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