It is a pleasure to join CCP Global for your Annual General Meeting. Joining you today marks the third time that I have had the opportunity to address this important group at the center of the global derivatives markets. Addressing this body in Madrid, Spain in June of 2022 marked one of the earliest keynote addresses that I delivered during my time in service as a Commissioner only months after I joined the Commission.[1]
During my speech in Madrid, I reflected on then-recent market stress resulting from geopolitical events and a global pandemic. In February and March of 2020, our markets faced concerning shocks from the rise of a global pandemic[2] and regulatory responses to contain it.[3] Markets witnessed unprecedented volatility coupled with extreme volumes of trading and at times tight liquidity, placing extraordinary pressure on market infrastructures. Responding to these events, central counterparties CCPs carefully assessed initial and variation margin requirements and ultimately increased initial margin requirements (particularly for equity products) as an integral part of their market risk mitigating solutions.
Facing these challenges, CCPs navigated the risks presented, deploying the carefully developed tools at hand with deep and continuous engagement with global regulators. As a result of effective reforms adopted almost a decade before the pressures of recent geopolitical events and a global pandemic at the start of this decade, our financial system demonstrated remarkable resilience. As noted by the Financial Stability Board (FSB) – “Banks and FMIs, particularly CCPs, held up well and were largely able to absorb rather than amplify the shock.”[4]
In many ways, market conditions during these events stress tested CCP resilience reforms implemented pursuant to the 2009 G20 Pittsburg Summit and the Principles for Financial Market Infrastructure (PFMI) codified under local laws such as the Dodd-Frank Wall Street Reform and Consumer Protection Act and European Market Infrastructure Regulation.[5]
Turning back to the present, it is fitting that we gather here today in a building that has served as a gathering place for government and industry for hundreds of years. My understanding is that the building began as a convent in 1411, but later, in the 17th Century became the meeting place for the administrative board for the Admiralty of Amsterdam. And, in the mid-1600s, became known as a City Hall and served as the seat of Amsterdam’s government.
In the spirit of reflecting on the significant contributions of the CCP Global community and the issues that you will discuss and explore during your general meeting, I hope to highlight the work of the advisory committees of the CFTC. Over the last few years, your members have supported and served on a number of the CFTC advisory committees. Having a full complement of five Commissioners for the last three and a half-years means that we put lots of you to work. As the current remaining Commissioners, Acting Chair Pham and I are continuing our commitment to advance important multi-stakeholder dialogues through our role as advisory committee sponsors. I am hopeful that we may even find a path to collaborate with joint sessions hosted by the two advisory committees that we sponsor.
Today, please allow me to focus my remarks on the importance of our Commission’s advisory committees and highlight some of the suggestions put forth by the Market Risk Advisory Committee (MRAC) following deep engagement on these issues, especially those focused on operational resiliency and derivatives clearing organizations (DCOs) system safeguards, and DCO wind down and recovery plans.
I know that many of you are familiar with the MRAC and other CFTC advisory committees from your service and support as members of their Committees and Subcommittees. The MRAC was established on May 6, 2014 in accordance with the Federal Advisory Committee Act (FACA) after the Commission determined that MRAC was necessary and in the public’s interest.[6] MRAC’s purpose is to support the Commission in “promoting [] integrity, resilience, and vibrancy of the U.S. derivatives markets through sound regulation, as well as the monitoring and management of systemic risk.”[7] Since MRAC’s inception, each sponsoring Commissioner has recognized the vital role this advisory committee plays in the development of Commission rules and regulations and utilized MRAC to put forth important reports and recommendations.[8]
The MRAC has a diverse membership with deep experience across all corners of the derivatives space, including representatives of clearinghouses, exchanges, intermediaries, market makers, end-users, academia, public interest advocates, and regulators. Diversity of membership in our advisory committees is critically important to their success and will be vital as we address jurisdiction over emerging markets and novel asset classes as well as the continuous evolution of complex liquidity and market risk issues. Without perspectives from every side of the integral issues that these committees address, we run the risk of limiting our supervision and oversight and missing out on the opportunity to effectively address emerging risks to market stability and integrity.
The benefits of multi-stakeholder gatherings to address emerging market risks cannot be overstated. Sharing a wide variety of perspectives across our markets to engage in deep, thoughtful, and actionable solutions enables regulators and market participants to be prepared to navigate risks with minimal disruptions and maximum resiliency for strong and vibrant derivatives markets in the U.S. and across the world.
This, in essence, is why I believe you all meet here on an annual basis as well – because you recognize the value of deliberative engagement. Allow me to share briefly on two issues that are top of mind for me and that the MRAC has made significant progress addressing– operational resilience of our derivatives markets and orderly wind down and recovery for DCOs.
Navigating the Cyber Landscape for CCPs
Cybersecurity risks are growing in our markets and must be proactively managed and addressed. In its 2024 Systemic Risk Barometer Survey, the Depository Trust and Clearing Corporation (DTCC) noted that cyber risk was a top five systemic risk to the global economy.[9] Similarly, in May 2024, the International Monetary Fund (IMF) stated that in the past 20 years, the financial sector has suffered over 20,000 cyber-attacks resulting in $12 billion in losses, and noted that there is a growing inequality between cyber resilient organizations and those that lack the resilience to withstand and prevent attacks.[10] Recent events demonstrate the chaos that cybersecurity events can cause for our markets, resulting in billions in losses.
As many of you are aware, in January of 2023, ION Cleared Derivatives (ION) experienced a significant cyberattack. ION provides important back-office services for many global futures commission merchants (FCMs) and other market participants. ION’s effective operations and successful provision of these critical services enable many market participants to clear and settle a significant volume of global transactions on a daily basis. The cyberattack on ION triggered a series of disruptions across markets. Those who rely on ION to perform critical functions were taken offline and many had to rely on manual trade processing. The outage similarly delayed the Commission’s ability to deliver timely the Commitments to Traders reports.
Two years later, in a very different corner of markets, on February 21, 2025, Bybit, a popular cryptocurrency exchange, lost nearly $1.5 billion in losses in mostly Ether from a hacking incident.[11] The Bybit hack represented one of the single largest losses by any cryptocurrency exchange since the first Bitcoin was mined.
The hackers identified a vulnerability in Bybit’s transaction approval process hosted through smart contract logic in off chain infrastructure. What appeared to be a routine transfer from Bybit’s Ethereum cold wallet ended up being a rerouting of the transaction to the hacker’s wallets. What kinds of vulnerabilities have enabled hackers to capture hundreds of millions of dollars in cryptocurrency? Commonly deployed tactics include phishing, supply chain compromises, and private key thefts.
In the context of the Bybit hack, reports indicate that the hackers accessed critical Bybit systems through a third party provided critical infrastructure system and used this access point to inject malicious software that detected and modified outgoing transactions in real time.[12] Hackers appear to have gained access to an off chain Safe user interface provided by a third-party service provider.[13]
To provide guardrails for these types of issues, in December 2023, the Commission unanimously approved a proposed rule that would create an operational resilience framework for FCMs, swap dealers (SDs) and major swap participants (MSPs) to “identify, monitor, manage, and assess risks relating to information and technology security, third-party relationships, and emergencies or other significant disruptions to normal business operations”.[14] The proposed rule included three components: (1) an information and technology security program; (2) a third-party relationship program; and (3) a business continuity and disaster recovery plan. Each of these components was designed to deliver frameworks to establish protections to FCMs, SDs, and MSPs and, in an event like the ION Derivatives cyberattack, a plan to continue business as normal while post-mortem checks are completed.
I want to highlight one of the risks that the proposed ORF seeks to address – concentration risks associated with critical third-party service providers. As early back as 2019, the FSB released a report on third-party dependencies in cloud services and considerations on financial stability implications, including implications of market concentration on competition.[15] These risks can be heightened for smaller or medium sized firms, who may lack both the resources to develop technology in house as well as the bargaining power to negotiate with limited service providers in many cases.
Evidence, as well as our experience in working towards the operational resilience framework, indicates that this may be more pronounced in the markets we regulate where there may be even more limited vendors that can provide the sophisticated technologies often used in the derivatives industry. This is not only a potential issue for compliance with regulations and risk management, but also a business risk for market participants.
The Central Counterparty (CCP) Risk & Governance Subcommittee of MRAC recognized the need for a rule like ORF to create a regulatory framework for cybersecurity preparedness and business continuity for cyberattacks and built out a proposal to expand the scope to include DCOs and bolster system safeguards for critical third-party service providers.[16]
MRAC’s Recommendation on DCO System Safeguards for Critical Third-Party Service Providers
The DCO System Safeguards recommendations are an example of MRAC’s proactive response to a potential risk identified. The recommendations also highlight the value of the CFTC advisory committees and the potential for diverse stakeholders who may have divergent perspectives to work together to make real progress towards making our markets more resilient.
A technology and operations workstream of the CCP Risk & Governance Subcommittee began evaluating issues related to cybersecurity and third-party risk management in early 2023. In March of that year, MRAC held a “first-of-its-kind” public meeting to discuss the cybersecurity event at ION Cleared Derivatives that led to a ripple effect across our markets. This was the first chance for experts across our industry to come together following the ION cyberattack to evaluate the event and begin to map out next steps to ensure cyber preparedness among market participants, service providers, and other sources that have the potential to impact our markets.
At the meeting, Futures Industry Association (FIA) President and CEO Walt Lukken announced the creation of a new Cyber Risk Taskforce, the National Futures Association (NFA) President and CEO Tom Sexton discussed NFA’s role in standard setting to mitigate cyberthreats, and we heard from other experts including those from the White House’s Office of the National Cyber Director, the Financial Industry Regulatory Authority (FINRA), and of course, the CFTC, on strategies to enhance the security and resilience of financial markets in the face of new and evolving cyber threats.
Later the same year, the FIA Cyber Risk Taskforce issued an After Action Report outlining the challenges facing our markets.[17] Key findings in the report include a lack of communication amongst market participants in the wake of a cyber incident and the need to connect our market with the broader financial sector to learn from and share the best operational resilience strategies for cyber events. The After Action Report made six recommendations based on their findings: (1) the creation of an “Industry Resilience Committee” to help develop information channels with respect to operational and cyber resilience; (2) connecting our industry with sector-wide specialist groups who focus on operational resilience across our markets; (3) a self-reflective review of our market participant’s policies and procedures for cyber incidents; (4) the establishment of procedures for sharing critical data and information during cyber incidents; (5) identification of ways to assess risk to create more robust operational resilience frameworks; and (6) participation in regularly held cyber preparedness exercises.[18]
The CCP Risk & Governance Committee recognized that there may have been some important gaps in operational resilience and took up the mantle to continue to examine areas not fully addressed by the Commission. The Subcommittee’s recommendations highlight the importance of cyber resilience in DCOs and the need for a more robust regulatory framework. These recommendations, which the MRAC voted to advance to the Commission, would improve upon the existing framework and require that DCOs establish, implement, and maintain a third-party relationship management program.
The CCP Risk & Governance Committee’s report focuses on CFTC Rule 39.18, which establishes system safeguard standards for DCOs and addresses outsourcing but does not expressly discuss third-party relationships. The CCP Risk and Governance recommendations build upon the framework of Rule 39.18 by adding a third-party risk management program to (b)(2). The proposal suggests that a robust third party relationship management program that identifies, assesses, mitigates, and monitors the full risks that are associated with using third party arrangements for critical services should include robust risk management frameworks like policies and procedures that cover the lifecycle of the relationship, personnel assigned to onboarding and diligence of the third party relationships, risk-based monitoring, and more.
The recommendations build upon the philosophy of the DCO Core Principles, lessons learned and best practices from voices across the industry, and international standard setting bodies. As noted in the report,
These principles are intended to reflect lessons learned from industry efforts and best practices in derivatives, the guidance notes in Form DCO, the NFA interpretive guidance, lessons learned from the wider context of third-party relationship management, as well as the principles enunciated in the PFMIs. Incorporating these principles in Commission regulations would enable the Commission to update its regulatory framework with respect to critical third party service providers and to bring its regulations in line with internationally accepted standards, while maintaining a principles based approach to regulation.[19]
Operational resilience, and especially third-party risk management, is a key issue for me, which I continue to track closely and to discuss frequently with my colleagues at the CFTC and at other agencies, as well as with market participants that we regulate, and at events like these. I frequently request that we take these issues seriously and continue to consider actionable steps to address them. As I’ve noted previously, “effectively combatting cyber threats will require a coordinated effort among regulators and industry,” and I am committed to continuing to foster conversations about how we can work together to make our markets safer and more resilient.[20]
I expect that MRAC will continue to consider issues related to cyber resilience and third-party risk management, including as the risks continue to evolve and AI-enhanced cybersecurity creates new or heightened risks.
DCO Recovery and Wind Down: Parallelism with International Standards
Similarly, the CCP Risk and Governance Subcommittee has outlined supplemental reforms that complement Commission staff work that aims to ensure recovery and orderly wind-down of DCOs as part of the post-crisis reforms and important robust preventative resilience framework. Since reforms adopted in the U.S. under the Dodd-Frank Act, international standard-setting bodies have adopted principles, guidance, and standards to support and inform national policymakers on CCP regulation.[21] The Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO and together with CPMI, CPMI-IOSCO) and the FSB have published numerous reports on these issues on resilience, recovery, and resolution.[22] In 2012, CPMI-IOSCO published a report setting forth 24 principles that financial market infrastructures, like CCPs, should apply, with the goal of enhancing safety and efficiency.[23] The principles, called the Principles for Financial Market Infrastructures (or PFMI), set forth four foundational pillars for managing financial risk associated with CCPs: governance arrangements of CCPs, comprehensive risk management frameworks, financial resources allocated to loss absorption, and stress testing for both credit and liquidity exposures.
The FSB issued guidelines[24] as well and worked together with CPMI-IOSCO to assess CCP financial resources in connection with recovery and resolution.[25] In the following years, the Commission took up a similar path, issuing a proposed rule that would apply guidelines and requirements for recovery and orderly wind down plans that are already required for systemically important DCOs (SIDCOs) and Subpart C DCOs to all DCOs.[26]
The Proposed DCO Recovery and Wind-Down Rule is robust and important to the Commission and its market participants. Again, MRAC and the CCP Risk & Governance Subcommittee identified four main areas to recommend enhancements: supervisory stress testing of recovery and wind-down plans; conducting recovery scenarios and analysis; inclusion of non-default loss (NDL) in recovery and wind-down plans; and porting of customer positions and collateral during a CCP resolution and clearing member default.[27]
The MRAC’s Recommendations on DCO Recovery and Orderly Wind-Down Plans; Information for Resolution Planning
At its April 2024 meeting, the MRAC approved another set of recommendations from the CCP Risk & Governance Subcommittee on DCO recovery and orderly wind-down plans and advanced them to the Commission. The recovery and resolution workstream worked on these recommendations in parallel with the Commission developing the Proposed DCO Recovery and Wind-Down Rule and aimed to support the staff in its drafting and the Commission in its consideration of such a rule.
The report included background about the importance of DCOs and CCPs in derivatives markets and actions taken both domestically and internationally to strengthen their resilience, some of which I have shared with you here today. The recommendations in the report demonstrate the depth of expertise available to the Commission through advisory committees and the inclusive nature of all participating viewpoints. For example, the recommendation to implement supervisory stress tests came with a caveat – while subcommittee members representing end-users, FCMs, and academia believed that stress tests should be required to take place annually, subcommittee members representing DCOs did not believe that the frequency of reverse stress tests should be annual but should be determined by Commission staff.[28] This is a prime example of why continued participation and robust discussion amongst all viewpoints is a necessity when evaluating the complex issues that face our markets. Although the Commission has yet to complete a final rulemaking on this topic, I hope that the recommendations made by MRAC in this report can provide a roadmap for future engagement.
The Work Continues
I will not have sufficient time today to share all of the details about all of the reports or recommendations that that MRAC has advanced during my time at the Commission, but if you will indulge me, I would like to say a word about some of the other projects that have been completed over the past two years.
The Market Structure Subcommittee developed a report and recommendations on the Treasury cash-futures basis trade and effective risk management practices, which the MRAC voted to advance to the Commission. The report takes a thoughtful and comprehensive look at the basis trade, including its mechanics and parties involved, the disruptions experienced in March 2020 during broader COVID-19-related market turmoil, and its impacts on the broader economy), and identifies both benefits and risks before the recommending effective risk management practices associated with the cash-futures basis trade.[29]
At the most recent MRAC meeting, Josh Frost, then-Assistant Secretary for Financial Markets at the Treasury Department, and members of the Treasury Borrowing Advisory Committee spoke about the importance of Treasury markets and their role in price discovery and liquidity across the financial system, drawing on perspectives from a number of participants in the ecosystem, including both asset managers and hedge funds that participate in the basis trade. This discussion was a good example of the importance of the work of the MRAC on topics that have real implications for our market ecosystem, and the value of bringing together different voices to achieve a deeper, more informed understanding of important issues and how best we can address them.
To take one more example, earlier last year, the MRAC Market Structure Subcommittee issued a report sharing results from a survey of data on FCMs spanning 2003-2023,[30] which showed some interesting trends in capacity and concentration. At a recent trade association meeting, FIA Boca, I described issues that I believe are critical for the Commission to consider as we begin to explore clearing U.S. Treasuries.
The data collected in the MRAC Market Structure Subcommittee report outlines industry concentration in the market for FCM services despite the growth of the industry. For example, the survey showed a disproportionate amount of increase in bank-affiliated FCMs and increased concentration of broker-dealer-FCMs that are dully registered with the Securities and Exchange Commission. All of the top ten industry positions in terms of holdings of customer funds were associated with banks or broker-dealers, and they accounted for more than 80% of all customer funds.
Conclusion
We must continue to support our advisory committees and robust multi-stakeholder engagement. Each significantly benefit the stability and integrity of our markets.
Before closing, I would like to personally thank everyone that has supported the MRAC in any way, through service as an MRAC member, participation on a workstream to advance a set of recommendations to the Commission, by serving as an expert presenter at a meeting, or just tuning into the CFTC YouTube page to watch a meeting – thank you for dedicating your time. If you have not served on an advisory committee, I encourage you to consider service and the potential to contribute to the important engagement that service offers.
The broader CFTC community is part of what makes this agency so special and enables us to punch above our weight. It has been an honor to work with and learn from all of you, and I look forward to seeing what we can accomplish together next.
[1] Commissioner Johnson to Deliver Keynote Address at the 2022 CCP12 Annual General Meeting in Madrid (June 22, 2022), https://www.cftc.gov/PressRoom/Events/opaeventjohnson062222; Commissioner Johnson to Provide a Keynote Speech and Participate in a Fireside Chat at the CCP-12 Annual General Meeting (June 14, 2023), https://www.cftc.gov/PressRoom/Events/opaeventjohnson061523. As in my previous speeches, the views I express today are my own and not the views of the Commission, my fellow Commissioners or the staff of the CFTC.
[2] Opening Remarks of Tedros Adhanom Ghebreyesus, World Health Organization (WHO) Director-General, at the WHO Media Briefing on COVID-19 (March 11, 2020), https://www.who.int/director-general/speeches/detail/who-director-general-s-opening-remarks-at-the-media-briefing-on-covid-19---11-march-2020.
[3] Sir Jon Cunliffe, Keynote Address at the FIA & SIFMA Asset Management Derivatives Forum 2022 (Feb. 9, 2022), https://www.bankofengland.co.uk/speech/2022/february/jon-cunliffe-keynote-address-fia-sifma-asset-management-derivatives-forum.
[4] FSB Interim Report, Lessons Learnt from the COVID-19 Pandemic from a Financial Stability Perspective (July 13, 2021), https://www.fsb.org/uploads/P281021-2.pdf.
[5] See CFTC Regulation 39.13, applying a principles-based approach to managing procyclicality, and Article 41 of EMIR and Article 28 of the Regulatory Technical Standards, requiring CCPs to implement specific margin procyclicality mitigants.
[6] Market Risk Advisory Committee, 79 Fed. Reg. 25844 (May 6, 2014), https://www.federalregister.gov/documents/2014/05/06/2014-10325/market-risk-advisory-committee.
[7] CFTC, Renewal Chart of the Market Risk Advisory Committee (Apr. 16, 2024) (accessible at https://www.cftc.gov/About/AdvisoryCommittees/MRAC).
[8] See, e.g., Opening Statement of Acting Chairman Rostin Behnam before the Market Risk Advisory Committee (Feb. 23, 2021), https://www.cftc.gov/PressRoom/SpeechesTestimony/behnamstatement022321 (“Advisory committees like MRAC are vehicles for change, challenge, and perhaps most importantly, debate and consensus.”); Statement of Commissioner Sharon Bowen before the Market Risk Advisory Committee (Apr. 2, 2025), https://www.cftc.gov/PressRoom/SpeechesTestimony/bowenstatement040215 (“The information and recommendations from this Committee will be invaluable”). For a list of reports and recommendations set forth by the MRAC, see Market Risk Advisory Committee, CFTC, https://www.cftc.gov/About/AdvisoryCommittees/MRAC.
[9] DTCC, Systemic Risk Barometer Survey, 2024 Risk Forecast (2024), https://www.dtcc.com/-/media/downloads/Systemic-Risk/29873-Systemic_Risk-2024.
[10] World Economic Forum, Global financial stability at risk due to cyber threats, IMF warns. Here’s what to know (May 15, 2024), https://www.weforum.org/agenda/2024/05/financial-sector-cyber-attack-threat-imf-cybersecurity/; see also World Economic Forum, Global Cybersecurity Outlook 2024 (January 11, 2024), https://www.weforum.org/publications/global-cybersecurity-outlook-2024/.
[11] Vicky Ge Huang and Robert McMillan, How the Biggest Crypto Hack Ever Nearly Destroyed the World’s No. 2 Exchange, WSJ (Mar. 6, 2025), https://www.wsj.com/finance/currencies/how-the-biggest-crypto-hack-ever-nearly-destroyed-the-worlds-no-2-exchange-ee273a3a?msockid=26f265067f5965a63f6273047e1464d0.
[12] Alexandra Andhov, Inside The Bybit Hacking Incident: Lessons From The Breach, Forbes (Apr. 1, 2025), https://www.forbes.com/sites/digital-assets/2025/04/01/inside-the-bybit-hacking-incident-lessons-from-the-breach/; see also Sandy Carter, Latest On The Bybit Record Breaking 1.4 Billion Dollar Crypto Hack, Forbes (Feb. 21, 2025), https://www.forbes.com/sites/digital-assets/2025/02/21/latest-on-the-bybit-record-breaking-14-billion-dollar-crypto-hack/.
[13] Taylar Rajic, The ByBit Heist and the Future of U.S. Crypto Regulation, CSIS (Mar. 18, 2025), https://www.csis.org/analysis/bybit-heist-and-future-us-crypto-regulation.
[14] CFTC, Operational Resilience Framework for Futures Commission Merchants, Swap Dealers, and Major Swap Participants, 89 Fed. Reg. 4706 (proposed Jan. 24, 2024).
[15] Third-party dependencies in cloud services, Considerations on financial stability implications, FSB (Dec. 9, 2019), https://www.fsb.org/uploads/P091219-2.pdf.
[16] Recommendations on DCO System Safeguards Standards for Third Party Service Providers, Central Counterparty Risk and Governance (CCP) Subcommittee, Market Risk Advisory Committee of the U.S. CFTC (Dec. 2024) (available at https://www.cftc.gov/PressRoom/Events/opaeventmrac121024).
[17] FIA Taskforce On Cyber Risk After Action Report and Findings, FIA (Sept. 2023), https://www.fia.org/sites/default/files/2023-09/FIA_Taskforce%20on%20Cyber%20Risk_Recommendations_SEPT2023_Final2.pdf.
[18] Id.
[19] Recommendations on DCO System Safeguards Standards for Third Party Service Providers, Central Counterparty (CCP) Risk and Governance Subcommittee, MRAC (Dec. 2024) (available at https://www.cftc.gov/PressRoom/Events/opaeventmrac040924).
[20] Keynote Remarks of Commissioner Kristin Johnson at the Federal Reserve Bank of Dallas (May 29, 2025), https://www.cftc.gov/PressRoom/SpeechesTestimony/opajohnson19.
[21] Recommendations on Derivatives Clearing Organizations Recovery and Orderly Wind-Down Plans; Information for Resolution Planning, CCP Risk and Governance Subcommittee, MRAC (Aug. 2024) (available at https://www.cftc.gov/PressRoom/Events/opaeventmrac040924).
[22] Id.
[23] CPMI-IOSCO, Principles for Financial Market Infrastructures (April 16, 2012), https://www.bis.org/cpmi/publ/d101.htm; see also CPMI-IOSCO, Resilience and Recovery of Central Counterparties (CCPs): Further Guidance on the PFMI – Consultative Report (August 16, 2016), https://www.bis.org/cpmi/publ/d149.htm; CPMI-IOSCO, Implementation Monitoring of PFMI: Level 3 Assessment – Report on the Financial Risk Management and Recovery Practices of 10 Derivatives CCPs (August 16, 2016), https://www.bis.org/cpmi/publ/d148.htm.
[24] FSB, Guidance on Central Counterparty Resolution and Resolution Planning (July 5, 2017) https://www.fsb.org/2017/07/guidance-on-central-counterparty-resolution-and-resolution-planning-2/; FSB, Guidance on Financial Resources to Support CCP Resolution and on the Treatment of CCP Equity in Resolution (November 16, 2020), https://www.fsb.org/2020/11/guidance-on-financial-resources-to-support-ccp-resolution-and-on-the-treatment-of-ccp-equity-in-resolution/.
[25] FSB, Central Counterparty Financial Resources for Recovery and Resolution (March 10, 2022), https://www.fsb.org/2022/03/central-counterparty-financial-resources-for-recovery-and-resolution/.
[26] CFTC, Derivatives Clearing Organizations Recovery and Orderly Wind-Down Plans; Information for Resolution Planning, 88 Fed. Reg. 48968 (proposed July 28, 2023) (Proposed DCO Recovery and Wind-Down Rule).
[27] Recommendations on Derivatives Clearing Organizations Recovery and Orderly Wind-Down Plans; Information for Resolution Planning, CCP Risk and Governance Subcommittee, MRAC (Aug. 2024) (available at https://www.cftc.gov/PressRoom/Events/opaeventmrac040924).
[28] Id.
[29] The Treasury Cash-Futures Basis Trade and Effective Risk Management Practices, MRAC (Dec. 2024) (available at https://www.cftc.gov/PressRoom/Events/opaeventmrac121024).
[30] Market Structure Subcommittee Data and Analysis Regarding FCM Capacity, MRAC (Apr. 2024) (available at https://www.cftc.gov/PressRoom/Events/opaeventmrac040924).
