ISDA, FIA and the Institute of International Finance responded to issues concerning central counterparty ("CCPs") resolution raised in a discussion paper published by the Financial Stability Board ("FSB"). The comment letter addresses CCP equity, the amount of "skin in the game" a CCP should be required to maintain (that is, the amount of losses it must absorb before imposing losses on clearing members), and the rules that should govern "No Creditor Worse Off than in Liquidation" claims in the event that a CCP is resolved rather than being liquidated.
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