The European Association of CCP Clearing Houses (EACH) represents the interests of Central Counterparties Clearing Houses (CCPs) in Europe since 1992. EACH currently has 20 members from 15 different European countries and is registered in the European Union Transparency Register with number 36897011311-96.
For default losses, European CCPs are already required to hold considerable pre-funded resources to meet a variety of purposes. This includes being able to withstand the default of their two largest clearing members by sizing their default fund based on the potential uncovered exposure of their two largest clearing members (‘cover 2 requirement’), an unprecedented stress situation. We believe that the existing cover 2 requirement for European CCPs provides a sufficiently high degree of protection in extreme but plausible circumstances and ensures the preservation of incentives towards robust risk management.
The full response is available here.