The Clearing House (TCH) has submitted a comment letter to the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) responding to their Guidance on Cyber Resilience for Financial Market Infrastructures consultative report. TCH’s letter supports building more resilient FMIs and has made recommendations to assist the guidance in fulfilling this goal. In the letter, TCH provided the following recommendations: (i) proliferation of standards, (ii) a risk-based approach to ensure that each FMI may include requirements for its own risk profile, (iii) development of a common baseline, and (iv) a utility analysis to guarantee that the new Guidance is complimentary and adds value to the existing standards and guidance.
In addition to its own comment letter, TCH joined with Chicago Mercantile, Inc., ICE Clear Credit L.L.C, The Options Clearing Corporation, and the Depository Trust Company to submit a joint industry letter on the same proposal. The Associations’ recommendations included: (i) implementing approaches that can address each FMI’s “unique risks and circumstances,” and (ii) tailoring the guidance so that it is relevant to each organization.