The recently published CPMI-IOSCO report on the recovery of FMIs is not intended to create additional standards for CCPs or authorities beyond those set out in the PFMIs. Rather, the regulatory approach is non-prescriptive, and is aimed at providing guidance that should help FMIs to choose the appropriate mix of recovery tools.
Over time, we may very well see the development of more prescriptive rules and regulations. A more prescriptive approach will in my view become inevitable if the current approach fails to prevent a race to the bottom between CCPs or across jurisdictions. The ongoing CPMI-IOSCO implementation monitoring process will be crucial to identify gaps and draw the lessons as needed.