EFAMA welcomes the opportunity to respond to the EC’s targeted consultation on the EU’s central clearing framework. We are pleased to find in this consultation document a fair reflection of the complexity of the CCP ecosystem and consistency with the issues raised in previous dialogues held with the European Commission. In that same spirit, we hope in our response to provide feedback that resonates with the EC’s broader policy objectives while minimizing systemic risk and undue harm to our industry. The consultation is wide-ranging covering a breadth of areas such as expanding the scope of clearing participants and cleared products, capital requirements for clearing members, obligations to clear and active accounts, and expanding services by EU CCPs.  We will provide our collective view here, and if relevant we may provide further quantitative evidence separately.