In our view it is essential that CCP recovery is given every opportunity to succeed, as we believe resolution would likely have a more negative impact on the overall market. We do not support resolution authorities seeking to interfere with – or override – the CCP’s recovery process unless intervention is absolutely required to support financial or market stability. The decision regarding when to invoke resolution should only be taken if it is clearly necessary to provide for continuity of clearing services and market stability. We believe the interests of the financial system are best served by a regime that is designed primarily to avoid resolution and instead, incentivize market participants’ active participation in the recovery process. In the extreme and remote scenario of a potential CCP resolution, the resolution authority should intervene after the exhaustion of the resources and tools defined for recovery in a CCP’s rulebook and recovery plan. If a resolution authority were to intervene prior to this, the incentives market participants must actively participate in the recovery process are undermined.