We commend the work that IOSCO has undertaken to date on this topic including the survey work and the summary findings in the form of the report currently under review.  It is fair to say that the conclusions of the report and areas for further work gave rise to detailed discussions within our industry, yielding ultimately firm views on the priority areas that we support and see value in, and areas we felt were not reflected in the study and thereby building risk into margining models in future crisis scenarios.  These areas are further elaborated in the attached document and include:

• The need for greater transparency and predictability of CCP margin models
• Related to the above, the need for a review and consistency of CCP margin models across entities
• Need for analysis of the repo-market performance for the buy-side during crisis
• Need for expansion of the eligible CCP collateral list