This letter provides brief initial comments from the Association on the assessment of incentives to clear report (the Report) published in October by the OTC Derivatives Assessment Team, established by the OTC Derivatives Coordination group (the Group). The aim is to bring certain issues, which we believe to be critical to the incentives to clear debate, to the immediate attention of the Group. The Association intends to follow this letter up with detailed and technical support for the issues raised in due course.