PIMCO—one of the largest global investment management firms with over US $1.87 trillion in assets under management (as of September 30)—published its own recommendations last week to help avoid a clearinghouse collapse. Among other recommendations are that clearinghouses should increase their own contribution to guaranty funds to the higher of 5 percent of the guaranty fund, US $20 million or the third-largest clearing member contribution, and that this contribution should be fully funded in advance. PIMCO also recommends that (1) clearinghouses should be subject to periodic stress tests approved and reviewed by regulators and have access to central banks for cash deposits and for repurchase agreements for securities (in order to help ensure a clearinghouse’s liquidity in a time of market stress), and (2) if a clearing member fails, client assets should only be utilized as a last resort—after clearinghouse and defaulting members’ “contributions” have been completely used up. The investment manager also argues that the current protective regime in the US for cleared swaps customer funds should be extended to futures. Currently, the rules around cleared swaps customer funds are more stringent in the US than those for futures customer funds.