Have the agencies sufficiently defined the term “core clearing and settlement organizations” for such organizations to identify themselves?
It is our belief “core clearing and settlement organizations” are the cornerstone of a fully-functional financial system and, therefore, we recommend the Agencies identify and publish qualified organizations or firms (e.g., Depository Trust and Clearing Corporation, Issuing & Paying Agents, Custodial banks, etc.) within six months of publishing the final White Paper. • Have the agencies provided sufficient guidance for firms to determine whether they play “significant roles in critical financial markets?” Additional guidance is necessary to enable firms to determine if they play a “significant role in critical financial markets.” • Are there other measures or additional facts or circumstances that should be used to determine whether a firm plays a significant role or acts as a core clearing organization? Measuring a firm’s role within critical financial markets is appropriately determined by dollar and/or transaction volume. • Should the agencies establish an average daily dollar volum
