# Understanding Central Counterparty Clearing Houses (CCPs) in Trading

> **Definition**
>
> A central counterparty clearing house (CCP) is an entity that facilitates trading in various European derivatives and equities markets.

A central counterparty clearing house (CCP) is an entity that facilitates trading in European [derivatives](https://www.investopedia.com/terms/d/derivative.asp) and equities markets. Typically operated by the major banks in each country, CCPs are a crucial part of these markets, reducing the counterparty, operational, settlement, market, legal, and default risks for traders.

A CCP is a particular type of clearing house. While the latter also facilitates trading, CCPs take an additional step and must agree to the terms before they clear the transaction. In the U.S., the equivalent of a CCP is a derivatives clearing organization (DCO) or derivatives clearinghouse. These are regulated by the Commodity Futures Trading Commission (CFTC) and include the Options Clearing Corporation and Chicago Mercantile Exchange Clearing.

### Key Takeaways

*   Central Counterparty Clearing Houses (CCPs) play a crucial role in trading by acting as intermediaries, managing the risk of default, and ensuring the completion of trades even if one party fails to meet its obligations. This guarantees stability and confidence in financial markets.
*   Blockchain and cryptocurrency technologies are being explored as potential tools to enhance the efficiency and transparency of CCPs; however, these technologies have not yet proven capable of fully replacing the risk management functions of traditional CCPs.
*   The integration of CCPs in the trading process involves significant risk mitigation through methods such as margin requirements and stress testing, which are essential for maintaining market stability and protecting traders from systemic risk.
*   While crypto exchanges are attempting to adopt CCP-like structures to manage risk, they often fall short in transparency, regulatory oversight, and effective risk management when compared to traditional CCPs.
*   Major financial institutions and regulatory bodies, especially in the U.S. and Europe, continue to explore the intersection of blockchain and traditional finance to develop hybrid models that could combine the benefits of blockchain technology with the risk management expertise of CCPs.  
    

![Central Counterparty Clearing House (CCP): An organization that facilitates trading in European derivatives and equities markets.](https://www.investopedia.com/thmb/khvsf5qiGeCUs5pxvUzADJoSv5s=/1500x0/filters:no_upscale():max_bytes(150000):strip_icc()/Ccph_final-13b8185636a54706a78aebb2c8c7f23d.png)

*— Investopedia / Michela Buttignol*

### Overview of Central Counterparty Clearing Houses (CCPs)

Central counterparty clearing houses (CCPs) perform two main tasks as intermediaries in transactions: clearing and settlement. As counterparties to the buyers and the sellers, CCPs guarantee the terms of a trade—even if one party defaults on the agreement. CCPs bear the lion's share of the buyers' and sellers' [credit risk](https://www.investopedia.com/terms/c/creditrisk.asp) when clearing and settling market transactions.

The CCP collects money from each buyer and seller to cover potential losses incurred by failing to follow through on an agreement. In such cases, the CCP replaces the trade at the market price. Monetary requirements are based on each trader’s exposure and open obligations.

Central counterparty clearing houses (CCPs) have two functions: acting as intermediaries in transaction clearing and settlement. As blockchain technology influences the financial landscape, CCPs are both adapting and changing their traditional models.

## Functionality and Operations of Central Counterparty Clearing Houses

To protect privacy, CCPs shield the associated traders’ identities from one another. CCPs also protect trading firms against default from buyers and sellers who are matched by an electronic [order book](https://www.investopedia.com/terms/o/order-book.asp) and whose creditworthiness is unknown. In addition, CCPs reduce the number of transactions that are being settled. This helps smooth operations while reducing the value of the obligations, which helps money move more efficiently among traders.

> **Important**
>
> In the U.S., DCOs or derivatives clearinghouses serve the same role as CCPs and are regulated by the CFTC.

## Understanding Derivatives Clearing Organizations (DCOs)

DCOs help keep U.S. commodities and derivatives markets stable and trustworthy. As defined by the [CFTC](https://www.investopedia.com/terms/c/cftc.asp), a DCO is an entity that enables parties to substitute the DCO's credit for their own through novation (the legal substitution of one party for another in a contract). They are financial middlemen who provide trust in systems where trades occur without credit checks or knowledge of the other party. When two people make a deal involving derivatives, a DCO ensures everyone holds up their end of the bargain.

They act as stand-ins, ensuring deals proceed even if one side fails to pay. This process, which the CFTC oversees, helps reduce risk and brings far more trading into the market.

DCOs are particularly important in the derivatives market, where they must register with the CFTC before providing clearing services for futures contracts, options on futures, or swaps. DCOs must meet stringent regulations to protect market participants and maintain market stability.

To obtain and maintain registration, DCOs must follow 17 "core principles" established in the [Commodity Exchange Act](https://www.investopedia.com/terms/c/cea.asp). They cover a wide range of operational and risk management requirements, such as the following:

1.  Maintaining adequate financial, operational, and managerial resources
2.  Implementing the appropriate risk management procedures
3.  Ensuring prompt settlement under very different market circumstances
4.  Protecting member and participant funds
5.  Establishing efficient and fair default procedures
6.  Having robust safeguards and disaster recovery plans

DCOs must maintain complete records, publish their rules and operating procedures, and participate in information-sharing agreements. These requirements enhance [transparency](https://www.investopedia.com/terms/t/transparency.asp) and permit effective regulatory oversight.

The CFTC may exempt a DCO from registration for clearing swaps if it determines that the DCO is subject to comparable, comprehensive supervision by authorities in its home country. This provision recognizes the global nature of derivatives markets while ensuring consistent standards across borders.

## The Role of Blockchain and Cryptocurrency in CCPs

CCPs have long been a cornerstone of risk management in European and U.S. financial markets (the latter through DCOs). As blockchain technology and cryptocurrencies reshape the financial landscape, CCPs are adapting to this new paradigm while also changing their traditional models.

In traditional markets, CCPs act as intermediaries between buyers and sellers, guaranteeing trades even if one party defaults. This system has proved effective in mitigating counterparty risk and enhancing market stability. However, the decentralized nature of [blockchain](https://www.investopedia.com/terms/b/blockchain.asp) technology has suggested a possible advance over the CCP model, blockchain proponents have argued.

In 2015, [clearinghouses](https://www.investopedia.com/terms/c/clearinghouse.asp) from several nations joined forces to create a [Davos](https://www.investopedia.com/terms/d/davos-world-economic-forum.asp)\-formed think tank, the Post Trade Distributed Ledger Group (PTDLG), which studies how blockchain technology can be used for clearing, settling, and recording securities trades. The group, which in 2018 began collaborating with the Global Blockchain Business Council, now includes around 40 financial institutions worldwide (though it claims far more in "ambassador" and other roles).

> **Tip**
>
> Blockchain technology, a digital ledger that can be programmed to record financial transactions , is another area where CCPs have been adapted.

Blockchain's inherent features are said to provide transactions with immutability, transparency, and near-real-time settlement. Having these would seem to eliminate the need for CCPs in some markets. [Smart contracts,](https://www.investopedia.com/terms/s/smart-contracts.asp) for instance, automatically execute trades and transfer assets without intermediaries. This has led some crypto enthusiasts to argue that blockchain could make CCPs obsolete.

However, while blockchain can help streamline processes, it can't manage all CCP risk functions. For example, CCPs handle collateral management, netting of positions, and default management procedures—tasks still notional in blockchain-based systems.

There's also the problem that the financial industry has already been through a run of blockchain ventures that didn't pan out. As a _Financial Times_ headline put it in late 2023, the "case for blockchain in financial services" has been "dented by failures." Here are a couple of examples:

*   **B3i (Blockchain Insurance Industry Initiative)**: This consortium of 15 insurance and reinsurance companies aimed to use blockchain to reduce inefficiencies in premium and claims settlement. However, B3i ceased operations and filed for insolvency in July 2022 because of challenges in gaining industry-wide adoption and scaling its blockchain structure.
*   **we.trade**: A blockchain-based trade finance platform backed by 12 major banks, including Deutsche Bank AG ([DB](https://www.investopedia.com/markets/quote?tvwidgetsymbol=DB)), HSBC Holdings PLC ([HSBC](https://www.investopedia.com/markets/quote?tvwidgetsymbol=HSBC)), and Banco Santander S.A. ([SAN](https://www.investopedia.com/markets/quote?tvwidgetsymbol=SAN)), also entered insolvency in 2022. Despite its promise to streamline international trade transactions, even its own members were unconvinced, and the group fell apart because they wouldn't fund it.  
    

In addition, while most DCOs have steered clear of unproven technologies, CCPs elsewhere in the world haven't been as patient.

## Lessons from the ASX Blockchain Project Failure

The early 2020s failure of the Australian Securities Exchange (ASX) blockchain project serves as a stark warning about the risks of adopting unproven technologies in critical financial infrastructure. It's worth looking at the debacle for that reason. Here's a brief timeline of events:

1.  2017: ASX contracts with tech firm Digital Asset (DA) to create a blockchain-based ledger for its new Clearing House Electronic Subregister System (CHESS).
2.  2020: The project is internally rated as "red," indicating material risks to timely delivery. An email from Digital Asset to ASX noted that "there was a risk of continued delays to the delivery of code ... and that this would put additional pressure on future milestones," according to ASIC.
3.  December 2021: DA revised its timeline to deal with the software issues, but ASX rejected it since it had already published its plan with the earlier dates. 
4.  February 2022: Instead of reckoning with the problem, ASX publicly states the project is "on track for go-live" and "continuing to progress well," according to the Australian Securities and Investments Commission (ASIC).
5.  Mid-July 2022: After nearly seven years and about $250 million invested, ASX terminates the project.
6.  August 2024: ASIC brings a suit against ASX for allegedly making false and misleading statements about the project.

The Australian regulator warned of the risks of overhyping blockchain in complex financial systems. It also warned about the financial consequences and loss of trust that can come from pursuing trendy technologies without a thorough evaluation.

ASIC Chair Joe Longo said that ASX's claims over the years that its CHESS system was on track "go to the heart of trust in the integrity of our markets." "Companies and participants depend on ASX's claims to guide their decisions and investments," he said.

ASIC, which has been busy bringing cases related to crypto fraud, pump-and-dump schemes, and scams involving major players in the Australian markets, has clearly tired of financial executives continually speaking of the promise of crypto and blockchain while hiding problems, if not outright scams. Between the summer of 2023 and 2024 alone, it brought suits in 615 cryptocurrency cons.  

### "Novation"

In the context of CCPs, novation is the process by which the CCP replaces the original parties to a trade by becoming the buyer to every seller and the seller to every buyer, thereby assuming the counterparty risk for both sides of the transaction.

## Blockchain-Based Clearing Innovations in Europe

ASX is not the only CCP looking to blockchain for greater efficiencies and the other promises of the technology. [Euroclear](https://www.investopedia.com/terms/e/euroclear.asp), a major European CCP, partners with Paxos to create a blockchain platform for gold trades. The platform, Euroclear Bankchain, has completed pilot programs and has been processing settlements.

In addition, Euroclear has been working since 2021 on a central bank digital currency ([CBDC](https://www.investopedia.com/terms/c/central-bank-digital-currency-cbdc.asp)) with the Banque de France while working out how to bring to the market blockchain-based settlements for government bonds. In March 2024, Euroclear also bought a major stake in IZNES, a regulated international platform for subscriptions and redemptions of shares of European funds. These efforts indicate that Euroclear is continuing to explore and develop blockchain-based clearing and settlement structures rather than abandoning them​.

SIX, the Swiss stock exchange, operates the SDX to provide blockchain-based trading, settlement, and custody for digital assets. SDX leverages the blockchain for real-time settlement and the simultaneous transfer of ownership. This setup mirrors the role of a CCP by providing central clearing for digital asset trades on its platform. In 2024, SDX, the World Bank, and the Swiss National Bank issued the first Swiss Franc (CHF) digital bond by an international issuer, totaling CHF 200 million. This seven-year bond will settle using the SNB's wholesale CBDC, with coupon and redemption payments made in [tokenized](https://www.investopedia.com/terms/t/tokenized-equity.asp) CHF on the SDX platform.

## The U.S.'s Conservative Integration of Blockchain in Clearing

Meanwhile, U.S. clearing institutions like the Depository Trust & Clearing Corporation (DTCC) that are working on blockchain-based systems are notable for their more circumspect approach. For example, DTCC has been using blockchain for additional projects first, including its "Smart [NAV](https://www.investopedia.com/terms/n/nav.asp)" pilot project for publishing mutual fund asset information. In 2022, DTCC went live with its "Project Ion," a blockchain-based alternative settlement platform. This platform uses [distributed ledger technology](https://www.investopedia.com/terms/d/distributed-ledger-technology-dlt.asp). Most importantly, though, it's designed to work alongside DTCC's existing systems, which remain authoritative for any cleared transactions.

As the integration of blockchain and traditional finance continues, it's likely we'll see hybrid models emerge. This could combine the efficiency and transparency of blockchain with the risk management expertise of CCPs. As the ASX debacle shows, while blockchain may offer potential benefits in particular, its application in core clearing and settlement functions is still just a promise on the horizon, not a proven technology.  

##  Evaluating Cryptocurrency Exchanges' CCP Claims

Some exchanges have long been asserting to develop their own CCP-like structures in the cryptocurrency space. For example, since 2018, Binance, one of the largest crypto exchanges, has had what it says is a secured emergency fund for its users, which acts as a type of insurance fund to protect users in case of large-scale breaches or hacks—a function that's said to be like the default funds maintained by traditional CCPs.

However, that's hardly the case: estimates put the amount traded each year on Binance at $1.5 trillion; the company said in August 2024 that assets in its CCP-like fund were valued at $1 billion, the same as in 2022. For comparison, LCH, which clears about the same value each year, has about six times as much in its backup funds, which aligns with regulatory and International Swaps and Derivatives Association and other international clearing best practices.

Moreover, many of the claims in the crypto space about having robust protections aren't true at all. For example, FTX, the major cryptocurrency exchange founded by the since-convicted Sam Bankman-Fried, rapidly grew into a multi-billion-dollar enterprise, not least on the back of its claim to insure at least part of its users' deposits. After [it collapsed in November 2022](https://www.investopedia.com/what-went-wrong-with-ftx-6828447) due to fraud, misuse of customer funds, and a liquidity crisis, its bankruptcy exposed significant gaps in oversight and governance within the crypto industry, leading to widespread investor losses and a slew of criminal proceedings.

A significant element in the FTX meltdown was its claim to have a fund that functioned similarly to a CCP, designed to protect against systemic risk within the platform. This fund, labeled on the exchange as the "FTX Insurance Fund," was said to be able to cover losses in cases where large-scale liquidations occurred that couldn't be fully absorbed by the market. The idea was to create a buffer to prevent cascading failures within the platform, similar to how a CCP acts as a backstop in traditional financial markets.

However, FTX’s approach to providing such protections was, in the end, criminal. In 2023, FTX's cofounder, Gary Wang, testified that the amount displayed to investors as in the fund was taken from a random number multiplied by the [daily volume](https://www.investopedia.com/terms/a/averagedailytradingvolume.asp#:~:text=Average%20daily%20trading%20volume%20%28ADTV%29%20is%20a%20metric%20used%20in,measured%20on%20a%20daily%20basis.) on the exchange. Not even a fraction of that number was ever stored away. The difference between a CCP operating under strict regulatory oversight and crypto exchanges' claims to mirror such investor protections is stark and profound:

1.  **Regulatory framework**: Many crypto exchanges operate in a regulatory gray area (or lawless zone), often with minimal external supervision.
2.  **Transparency and accountability**: CCPs are subject to rigorous transparency requirements, including detailed financial disclosures and operational reports. Crypto exchanges—FTX only stands out as the most costly example—lack this, making it impossible for users to assess the actual state of their risk management practices.
3.  **Risk management practices**: CCPs employ sophisticated, time-tested risk management techniques, including robust margin requirements and default management procedures. Crypto exchanges often claim to have similar protections, but as the FTX case demonstrated, these claims can be grossly exaggerated or entirely fabricated.
4.  **Governance and oversight**: CCPs and DCOs have strong governance structures, including independent boards and risk committees. Many crypto exchanges lack even the most minimal separation of those who own the exchange and those performing any typically "independent" functions.
6.  **Capital requirements**: CCPs and DCOs are required to maintain substantial capital reserves to cover potential losses. Crypto exchanges may claim to have similar reserves, but these claims are unverifiable without proper regulation and auditing.  
    

## Advantages and Disadvantages of Central Counterparty Clearing Houses

Advantages

*   Mitigate counterparty risk
    
*   Reduce risk of default
    
*   Enables market stability and confidence
    
*   Allows more efficient and secure trading
    

Disadvantages

*   Concentration of risk
    
*   Operational and compliance burden on market participants
    

Central Counterparties (CCPs) offer significant benefits in trading by mitigating counterparty risk. They act as intermediaries, ensuring that both parties meet their obligations and reducing the risk of [default](https://www.investopedia.com/terms/d/default2.asp). This structure enhances market stability and confidence, making trading more efficient and secure.  

However, CCPs also present certain risks and limitations. One of the main concerns is the concentration of risk. Since CCPs centralize counterparty risk management, any failure or disruption in a CCP could have widespread impacts on the entire financial system, potentially leading to systemic risk.  

Another limitation of CCPs is their operational and [compliance](https://www.investopedia.com/terms/c/compliance-cost.asp) burden on market participants. Companies must follow stringent regulations and uphold robust risk management protocols, which can demand considerable resources. These requirements can also limit market access for smaller participants, potentially reducing market liquidity and diversity. That said, it's unlikely these markets would have a fraction of their participants without the trust built by these regulations and risk management standards. The rise and fall of various crypto ventures shows the value of such robust requirements.  

## Moody’s Rating Methods for Central Counterparty Clearing Houses

Moody’s Investors Service rates CCPs worldwide. In its periodic reports, Moody’s evaluates how a CCP is meeting its clearing and settlement obligations and how much money will likely be lost if a trader defaults on an obligation. The CCR report factors in the following considerations:

*   A CCP’s management capabilities for obligation defaults and related protections
*   A CCP's business and financial basics
*   A CCP's operating environment
*   A CCP's quantitative measurements and qualitative issues, which Moody’s uses when determining a given CCP’s creditworthiness

## What Is an Example of a CCP?

The Options Clearing Corporation in the U.S. is a CCP that clears and settles all options traded on U.S. options exchanges.  

## How Do CCPs Enhance Market Stability?

CCPs improve market stability by mitigating counterparty risk, ensuring that trades are completed even if one party defaults.

## How Do CCPs Manage the Risk of Default?

CCPs manage the risk of default by employing risk management techniques, including [margin requirements](https://www.investopedia.com/terms/m/margin.asp) and regular stress testing.

## Can CCPs Operate in Multiple Asset Classes?

Yes, most CCPs operate across many asset classes, including equities, derivatives, and fixed-income securities.

## The Bottom Line

CCPs play a crucial role as intermediaries in trading, specifically in derivatives markets, by mitigating counterparty risk. They have the unique function of novation, where they become the counterparty to each side of the trade, which differentiates them from traditional clearinghouses.

The rigorous risk management strategies employed by CCPs include maintenance of emergency or default funds that cover potential defaults. CCPs in the U.S. operate under stringent regulatory standards as DCOs, ensuring market stability and safeguarding against systemic risk.

While CCPs concentrate risk, they ultimately contribute to market stability by ensuring secure and efficient trading, though they are not without operational burdens for market participants. Blockchain is influencing CCP models by streamlining processes while cryptocurrency exchanges are developing their own CCP-like structures to act a type of insurance fund.

> **Article Sources**
>
> 1.  Commodities Futures Trading Commission. "[Derivatives Clearing Organizations](https://www.cftc.gov/IndustryOversight/ClearingOrganizations/index.htm)."
>     
> 2.  European Association of CCP Clearing Houses. "[Central Counterparty Clearing Houses and Financial Stability](https://www.eachccp.eu/wp-content/uploads/2015/12/CCP.pdf)."
>     
> 3.  John C. Hull. "[Options, Futures, and Other Derivatives,](https://www.pearson.com/en-us/subject-catalog/p/options-futures-and-other-derivatives/P200000005938/9780136939917)” Page 3–4, 33–35. Pearson, 2022.
>     
> 4.  Commodities Futures Trading Commission. "[Commodity Exchange Act.](https://www.cftc.gov/exit/index.htm?https://www.law.cornell.edu/uscode/text/7/chapter-1)"
>     
> 5.  Depository Trust & Clearing Corporation. "[DTCC's Project Ion Platform Now Live in Parallel Production Environment, Processing Over 100,000 Transactions per Day on DLT](https://www.dtcc.com/news/2022/august/22/project-ion)."
>     
> 6.  Global Blockchain Business Council. "[Who We Are](https://www.gbbc.io/about)."
>     
> 7.  _Posttrade 360_. "[Watching DLT in Post Trade? Here's Your Monthly Regulatory Intelligence](https://posttrade360.com/news/regulation/watching-dlt-in-post-trade-heres-your-monthly-regulatory-intelligence/)."
>     
> 8.  Binance. "[Binance Academy](https://academy.binance.com/en/glossary/secure-asset-fund-for-users#:~:text=What%20Is%20SAFU%3F%20The%20Secure%20Asset%20Fund%20for,it%20to%20a%20sizable%20level%20to%20safeguard%20users.)."
>     
> 9.  Baxter Hines. "[Digital Finance: Security Tokens and Unlocking the Real Potential of Blockchain](https://www.wiley.com/en-us/Digital+Finance:+Security+Tokens+and+Unlocking+the+Real+Potential+of+Blockchain-p-9781119756309)," Pages 29-30. John Wiley & Sons, 2020.
>     
> 10.  Euroclear. "[Blockchain in Capital Markets](https://www.euroclear.com/newsandinsights/en/Format/Whitepapers-Reports/BlockchainInCapitalMarkets.html)."
>      
> 11.  _Financial Times_. "[Case for Blockchain in Financial Services Dented by Failures](https://www.ft.com/content/cb606604-a89c-4746-9524-e1833cd4973e)."
>      
> 12.  Australia Securities and Investments Commission. "[ASIC Sues ASX for Alleged Misleading Statements.](https://asic.gov.au/about-asic/news-centre/find-a-media-release/2024-releases/24-177mr-asic-sues-asx-for-alleged-misleading-statements/?altTemplate=betanewsroom)"
>      
> 13.  Australia Securities and Investments Commission. "[Online Investment Trading Scams Top ASIC's Website Takedown Action.](https://asic.gov.au/about-asic/news-centre/find-a-media-release/2024-releases/24-180mr-online-investment-trading-scams-top-asic-s-website-takedown-action?altTemplate=betanewsroom)"
>      
> 14.  Australia Securities and Investments Commission. "[Online Investment Trading Scams Top Asic's Website Takedown Action.](https://asic.gov.au/about-asic/news-centre/find-a-media-release/2024-releases/24-180mr-online-investment-trading-scams-top-asic-s-website-takedown-action?altTemplate=betanewsroom)"
>      
> 15.  Euroclear. "[Euroclear Bank](https://www.euroclear.com/services/en/provider-homepage/euroclear-bank.html)."
>      
> 16.  Euroclear. "[Banque de France and Euroclear Lead CBDC Blockchain Experiment](https://www.euroclear.com/newsandinsights/en/Format/Whitepapers-Reports/cbdc-to-settle-french-government-bonds.html)."
>      
> 17.  Euroclear. "[Euroclear To Invest in IZNES](https://www.euroclear.com/newsandinsights/en/press/2024/mr-09-euroclear-to-invest-in-iznes.html)."
>      
> 18.  SDX. "[SIX Digital Exchange Explained](https://www.sdx.com/videos/six-digital-exchange-explained/)."
> 19.  SDX. "[Digital Equity](https://www.sdx.com/digital-equity/)."
> 20.  Binance. "[Frequently Asked Questions on Secure Asset Fund](https://www.binance.com/es/support/faq/frequently-asked-questions-on-secure-asset-fund-for-users-safu-028799e730294ae4a9b382d60d350116)."
>      
> 21.  CPMI. "[Overview](https://www.bis.org/cpmi/about/overview.htm)."
>      
> 22.  International Swaps and Derivatives Association. "[CCP Best Practices](https://www.isda.org/a/cigME/CCP-Best-Practice.pdf)."
>      
> 23.  LCH. "[SwapClear Volumes](https://r.search.yahoo.com/_ylt=AwrijUjX.cRmmSQAR0UPxQt.;_ylu=Y29sbwNiZjEEcG9zAzIEdnRpZAMEc2VjA3Ny/RV=2/RE=1724213848/RO=10/RU=https%3a%2f%2fwww.lch.com%2fservices%2fswapclear%2fvolumes/RK=2/RS=iiLYniNQO1qaOmB149LE6OYY.20-)."
>      
> 24.  _The Block_. "[FTX Used Random Numbers To Generate the Size of Its Insurance Fund](https://www.theblock.co/post/255352/ftx-used-random-numbers-to-generate-the-size-of-its-insurance-fund)."
>      
> 25.  Moody's. "[Clearing Houses Methodology—Ratings](https://ratings.moodys.com/api/rmc-documents/65421)."
>      
> 26.  Moody's. "[Clearing Houses](https://www.moodys.com/researchandratings/region/north-america/united-states/0420B6/005001005003?po=1)."