In a letter to The Committee on Payments and Market Infrastructures (CPMI) and The International Organization of Securities Commissions (IOSCO) regarding the recently released CPMI-IOSCO consultative report on the resilience and recovery of central counterparties (CCPs), OCC said it appreciates that policy makers should be proactive in ensuring that the regulation of financial markets keep pace with market evolution and that smarter regulation is a goal all parties should strive to achieve. OCC stated its concern that certain aspects of the consultation are too prescriptive and do not afford CCPs such as OCC sufficient flexibility to adapt and apply these principles in the most effective manner for their businesses and the markets they serve. In addition, OCC feels that in several areas of the consultation, the further guidance actually contradicts the Committee's Principles for Financial Market Infrastructures (PFMI), which already have been implemented by most G20 national regulators in the form of binding regulatory requirements.