The Asset Management Group of SIFMA (SIFMA AMG) provided comments jointly with the Managed Funds Association (MFA) to the Bank for International Settlements (BIS) Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) on their discussion paper about CCP default management auctions. The Associations believe strongly that CCPs should have default management processes that include clients as part of auctions and CCP governance, and urge CPMI and IOSCO to recommend such inclusion.