Financial Associations Outline Key Issues For CCP Resolution

The Clearing House ("TCH") and ISDA published a white paper identifying key issues for regulators to consider when developing a comprehensive resolution framework for systemically important central counterparties ("CCPs"). The recommendations are intended to "build on, supplement and, in some instances, offer . . . perspective on the CCP resolution framework," which was proposed in the Financial Stability Board's Key Attributes of Effective Resolution Regimes for Financial Institutions.

TCH and ISDA recommended the following solutions to the "key issues" of CCP resolution:

• CCP Resolution Plans. At a minimum, CCPs should be required to prepare resolution plans (i.e., living wills) in order to (i) facilitate both continuity and resolvability, if the CCP is placed in resolution; (ii) facilitate optimal coordination between the CCP and relevant authorities, particularly at a cross-border level; and (iii) incorporate resolution tools and strategies designed to