On 29 November 2021, the Committee on Payments and Market Infrastructures (CPMI) and the Board of the International Organization of Securities Commissions (IOSCO) published a discussion paper on client clearing. The discussion paper considers issues concerning access to central counterparties (CCPs) and effective porting practices. The discussion paper does not intend to provide guidance on the Principles for financial market infrastructures (PFMI) but only to increase the common understanding on new access models and effective porting practices and identify potential issues for possible follow-up work from the industry.

Clients are not typically direct clearing participants but rather require access to clearing through clearing participants. As a result, access to client clearing is a critical issue for the success of the G20 reforms, especially in jurisdictions where the clearing obligation also applies to clients. Principle 19 of the PFMI states that financial market infrastructures (FMIs), including CCPs, “should identify, monitor, and manage the material risks to the FMI arising from tiered participation arrangements”. Moreover, Principle 14 of the PFMI states: “a CCP should have rules and procedures that enable the segregation and portability of a participant’s customers and the collateral provided to the CCP with respect to these positions”. Against this background, CPMI and IOSCO decided to analyse whether and to what extent concentration in client clearing creates issues of concern specifically in relation to client access.

The deadline for feedback is 24 January 2022.