CFTC RFI on CCP Climate Stress Testing: The WFE response notes that it is critical that any efforts with respect to assessing climate-related financial risks clearly recognise the risk management practices that CCPs already employ to effectively manage and mitigate such risks. We state that the focus should be less on any one specific event or transition risk(s), but rather on ensuring that the CCP has effective approaches to manage and mitigate the potential impact of such events, risks, and developments more broadly, whether that be through margining, stress testing, or other risk-management practices a CCP employs as part of its risk management framework.

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