A CCP is a CCP is a CCP

Dollar and magnifying glass
CCPs should not be seen through the lens of banking regulation

Banks, it is often said, are ‘special’. Central counterparty clearing houses (CCPs) also are special, in that they can be systemically important – but banks and CCPs are special in very different ways.

CCPs are not banks. They do not perform the central risk-taking function that distinguishes banking: asset/liability (or maturity) transformation through deposit taking and lending and related activities.1 The balance sheet of a CCP is “quite different from those of other major types of

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