Comment Text:
The Global Association of Central Counterparties (“CCP12”) appreciates the opportunity to contribute to the request for information and comments by the Commodity Futures Trading Commission - Swap Clearing Requirement To Account for the Transition From LIBOR and Other IBORs to Alternative Reference Rates.
CCP12 generally supports the CFTC’s effort to establish the new clearing mandates to reflect the transition of swaps referencing LIBOR to the relevant nominated successor “Risk-Free Rates” (RFRs or Alternative Reference Rates). CCP12 would like to emphasize in this context the importance of clearing and is supportive of a smooth transition, which is aligned between global standard setting bodies and regulators in different jurisdictions across the world.
