Dear Secretariats
We wish to alert you to a matter which is, in our view, sufficiently important to reducing risk and fostering financial stability to raise at this late stage1. In this letter, we outline our concern and propose potential solutions that we are exploring to address this matter, while acknowledging that, as ever, there is no panacea for risk and that each of our proposed solutions contains its own difficulties and risks. Nevertheless, the industry feels strongly that CPSS-IOSCO ought to address this issue in its Principles for Financial Market Infrastructures (“PFMI”). In particular, CPSS-IOSCO PFMI 3.4.82 and aspects of PFMI 63 require careful amendment.
Click here to download the full comment letter.