On September 18, 2015, the staff of the Division of Clearing and Risk of the Commodity Futures Trading Commission issued an interpretation to clarify that certain of its risk-management regulations related to derivatives clearing organizations conform to requirements of the Principles for Financial Market Infrastructures. The PFMIs are high-level best practices for key financial market infrastructures, including financial exchanges, trade repositories, and clearinghouses and clearing agencies, that set forth standards for organization; credit and liquidity risk management; settlement; default management; general business and risk management; and other topics (click here to access the Principles). Staff of CFTC’s Division of Market Oversight and DCR also issued an interpretation that use of a so-called “firm or forced trades” process by a derivatives clearing organization will not by itself require a DCO to register as a swap execution facility. Some DCOs use this process to help price certain swaps where public market prices are not available in order to help process variation margin payments and collections by clearing members.