WFE feedback on FTX’s Direct Clearing Model Proposal

The WFE appreciates the opportunity to comment on the Proposal to share feedback and set out important considerations when contemplating different types of CCP clearing models – particularly the non-intermediated clearing model being considered by the CFTC. 

The WFE has long advocated for principles-based regulation that is focused on outcomes rather than prescriptive regulation. Against that background, we believe that the Principles for financial market infrastructures (PFMI) are an appropriate framework to perform a comprehensive assessment of any clearing model employed by a CCP to ensure that it meets globally agreed objectives to strengthen core financial infrastructures and markets.