It is therefore critical to make progress in this area. In this context, we also need to reflect on how to ensure a fair loss allocation. While our choice can be guided by the basic premise that those taking the decisions should also be responsible for any losses, it is not always clear where we should draw this line.
For example, the general principle that operational losses should be borne by CCPs may not hold in the case of contagion risks emanating from a clearing member that has suffered a cyberattack. In addition, given the small amount of CCP capital, it is uncertain whether comprehensive loss absorption could be ensured in all circumstances.