In our response to the CPMI-IOSCO report on Streamlining variation margin in centrally cleared markets, the WFE supports the standard setters’ efforts to foster market participant preparedness for VM calls. We also commend the approach taken to craft a comprehensive set of effective practices as the cornerstone of the consultation which builds upon the Principles for Financial Market Infrastructures (PFMI), rather than setting out additional prescriptive proposals which may lead to unintended consequences. The WFE agrees that the predictability of VM practices is critical to supporting the liquidity planning of participants, however, we highlight that this must be balanced against the need for CCPs to appropriately address the current exposures of their participants.