In response to a Bank of England consultation on stress testing of central counterparty clearinghouses ("CCPs"), ISDA and FIA urged global regulatory coordination.
The associations raised a number of issues and considerations, including (i) the need for regulators to coordinate on stress testing; (ii) the inclusion of operational scenarios in stress tests; (iii) use of, in addition to "plausible" scenarios, scenarios looking at recovery and resolution situations; (iv) analysis of "contagion" risk; and (v) additional disclosure obligations on CCPs and their members.
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