16  The Counterparty Risk Management Policy Group has urged market participants to establish margin requirements and initial margins that are stable over the cycle. CRMPG, "Containing Systemic Risk: The Road to Reform" (Report of the CRMPG-III 6 August 2008).
17  "Because they are not required to calculate and hold a minimum of economic capital, such pools of private capital can have the freedom to take advantage of the possible herd behaviour of others that could result from those that apply more rigid risk management procedures required of regulated institutions." IMF, Global Financial Stability Report October 2007, 72. 10  BIS Review 29/2009