The WFE response states that while we welcome efforts to build awareness and understanding, and to ensure that practices are in place to address CCP NDLs, we do not believe that further guidance related to CCP NDLs is necessary. In large part, this is due to the strong framework of the PFMIs have already been established. Importantly, as the extent to which NDL risks may arise for a CCP will demonstrably vary, it is not something that can or should be assessed, managed, or overseen in an overly prescriptive or uniform manner. Our response continues to advocate for a principles- and outcomes-based approach to the PFMIs, which allow CCPs to appropriately tailor their risk management practices to the unique risks that they face.
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