CFA Institute responds to ESMA’s consultation on criteria for tiering third country central counterparties (TC-CCPs). When commenting on ESMA’s proposed indicators designed to assess the level of systemic importance of a TC-CCP for the stability of the EU or individual member states, CFA Institute draws ESMA’s attention to the work of the Systemic Risk Council (SRC), a CFA Institute sponsored institution committed to mitigating systemic risk. In particular, the comment letter refers to a letter sent by Sir Paul Tucker to the Financial Stability Board (FSB) where he stresses the urgent need for authorities to agree on a resolution regime for distressed CCPs, as recovery policies may not suffice and cannot substitute for resolution. CFA Institute welcomes ESMA’s ambitious effort to formalize the methodology used to tier TC-CCPs and thus determine their systemic importance.
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CFA Institute
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