The Bank for International Settlements considers that regulators should take more of a system-wide approach to assessing the risks of forcing more derivative trades through clearing houses. According to a paper released by it this week, the BIS has looked at how clearers form a web of links between themselves and their customers such as banks, raising the risk of a "domino effect" if one clearer went bust without the resources to contain the fallout. BIS also supports concerns of regulators that CCPs could become a new generation of "too big to fail" firms and states that more needs to be done to supervise them. According to the paper, it is possible that clearers may underestimate the initial margins required to back transactions and competition between CCPs may result in weaker risk management standards and that "Certain challenges stand in the way of designing and implementing sound CCP risk management".