The Chicago Mercantile Exchange Group added its voice to the debate about the appropriate level of contribution or “skin in the game” a clearinghouse should make to its clearing member default waterfall in a white paper it published. Arguing that it is a “misconception” that “central clearing results in a concentration of systemic risks,” CME noted that, instead, “risks may be concentrated within a clearing member through the exposure they bring to a [clearinghouse].” Accordingly, says CME, clearinghouses structure default waterfalls “to ensure they can adequately manage the risks brought by clearing members and encourage prudent balancing of risk among clearing members.” CME reminded that it has “long advocated for meaningful, funded, first-loss contributions to the [clearinghouse] waterfall in advance of the mutualized clearing member default fund, and has demonstrated this commitment with its own dedicated capital.” CME said that, as of September 30, 2014, its US and UK waterfall contributions were US $375 million or approximately 5.25 percent of its total funded, mutualized default funds. Previously, LCH.Clearnet weighed in on a host of clearinghouse issues, including what it considered an appropriate level of skin in the game, in a white paper it also published.