ISDA has published a briefing paper that addresses the argument put forward by EU authorities that clearing at third-country tier-two central counterparties (CCPs) carries a financial stability risk, as well as risks to monetary policy implementation. In the paper, ISDA highlights that the tier-two designation depends largely on the CCP’s size, which does not translate to increased risk if the CCPs are subject to appropriate risk management and supervision. Furthermore, ISDA notes that European Market Infrastructure Regulation 2.2 ensured that tier-two CCPs from the UK are held to the exact same standards as EU CCPs and are directly supervised by the European Securities and Markets Authority, in addition to being supervised by the Bank of England, which affords EU authorities robust safeguards in a recovery scenario. This highlights that clearing at UK CCPs is not riskier than clearing at EU CCPs. Finally, the paper also covers concerns in relation to risks to monetary policy implementation and crisis scenario concerns.