November 2019 | CCP12 responds to CFTC consultation Exemption From Derivatives Clearing Organization Registration
In the CCP12 response to the CFTC consultation on its SNPR regarding Exemptions from Derivatives Clearing Organization Registration, CCP12 supports the CFTC’s efforts to codify the existing regulatory framework for exempting clearing houses from the DCO registration requirements, makes comments on the supplemental notice of proposed rulemaking, and recommends that the CFTC finalize its current proposals under the SNPR.
November 2019 | CCP12 responds to CFTC consultation Registration With Alternative Compliance for Non-U.S. Derivatives
In the CCP12 response to the CFTC consultation on its NPR regarding Registration with Alternative Compliance for Non-U.S. Derivatives Clearing Organizations, CCP12 supports the CFTC’s efforts to codify the supervisory approach outlined in the CFTC’s White Paper for cross-border swaps regulation version 2.0.1. CCP12 makes comments on the notice of proposed rulemaking and recommends that the CFTC finalize its current proposals under the NPR.
August 2019 | CCP12 responds to CPMI-IOSCO discussion paper on CCP auctions
In the CCP12 response to the CPMI-IOSCO discussion paper entitled “Central Counterparty Default Management Auctions”, CCP12 provides views from different aspects around CCP default management auctions.
July 2019 | CCP12 responds to ESMA consultations
In the CCP12 response to the ESMA’s Consultation Paper on “Technical Advice on Comparable Compliance under article 25a of EMIR”, CCP12 emphasizes its view that an approach of mutual regulatory deference is of the utmost importance in adopting an approach of comparable compliance, and provides comments on comparable compliance, on ESMA fees for TC-CCPs and on criteria for tiering.
February 2019 | CCP12 response to FSB discussion paper Financial resources to support CCP resolution and the treatment of CCP equity in resolution
In the CCP12 response to the FSB Discussion Paper entitled “Financial resources to support CCP resolution and treatment of CCP equity in resolution”, CCP12 supports an agreed framework that benefits CCPs, regulators, and the financial markets at large, and shares the CCP perspective on these important topics.
January 2019 | CCP12 and EACH respond to the BCBS consultative document Leverage ratio treatment of client cleared derivatives
In the CCP12 and EACH response to the “BCBS Consultative Document: Leverage ratio treatment of client cleared derivatives”, CCP12 and EACH believe that appropriate actions should be taken to address the shortcomings of the Leverage Ratio with respect to centrally cleared derivatives and make suggestions on these topics.