Risk Committee Update: January 2026

In this month’s Risk Committee update we’ll share Thomas Murray’s detailed approach to central counterparty assessment. There are also updates from our recent visits to Chile and Hungary, plus market reviews following developments in Lebanon and Venezuela.

Thomas Murray’s Assessment of Central Counterparties

The Thomas Murray Risk Committee recently reviewed and confirmed the assessment of 29 central counterparties (CCPs) across the world. These CCPs clear over 80% of global derivatives trades and are considered to be among the most critical clearing houses globally.

CCPs are the most critical financial market infrastructure in existence today. Although they have been around for a long period of time, their importance greatly increased after the financial crisis of the late 2000s, when the G20 mandated the central clearing of OTC derivatives via CCPs.  

Central counterparties are essential to the global financial system because they reduce systemic risk by becoming the buyer to every seller and the seller to every buyer. CCPs must have robust risk management frameworks to manage the resulting counterparty risk, which they typically do through margining, maintenance of default funds, and stringent membership criteria.

Thomas Murray has been assessing CCPs for almost 15 years. Our assessment methodology has been designed to give clearing members a transparent, comparable view of the risks that each CCP carries, and the soundness of the controls it puts in place. At its core, our approach relies on six risk families: counterparty; treasury and liquidity; asset safety; financial; operational; and governance. Each risk is broken down into detailed elements that reflect international best practice standards, such as CPMI‑IOSCO principles, EMIR requirements and recognised audit frameworks.

Each element is mapped to a set of questions that ask about modelling assumptions, policy documentation, operational execution, monitoring mechanisms and quality of oversight. Answers are scored on a calibrated scale, weighted by the relative importance of the element, and aggregated to produce an overall percentage that is then translated into a grade, ranging from AAA (extremely low risk) to CCC (extremely high risk). This structure enables a consistent, evidence‑based comparison of CCPs across jurisdictions and asset classes, while still allowing the nuances of each market to be reflected in the final grade.

Counterparty risk examines how the CCP vets its members, monitors credit quality, and limits concentrations of risk. It looks at the parameters of the margining framework, the validation of the model, the calculation and collection of initial and variation margin, and the structure of the default fund waterfall.

Treasury and liquidity risk is evaluated through the CCP’s ability to meet its cash and collateral needs under stressed conditions, looking at whether the CCP holds sufficient liquid resources and how quickly it can convert collateral into cash. This risk also examines the quality of the collateral that the CCP accepts, the haircuts it applies, and how often it stress-tests pre-funded resources.  

In terms of asset safety, we look into the available account structures at the CCP that ensure the desired level of segregation and portability, as well as protecting legal claims on pledged assets, and rehypothecation rules.

Financial risk is measured by looking at profitability trends, expense ratios, revenue diversification, and the adequacy of capital and insurance.  

Operational risk covers the breadth of processes that keep the clearing service running smoothly. Our assessment checks that documented procedures exist, that responsibility for their upkeep is clearly assigned, and that they are reviewed frequently. It also looks at audit programs, both internal and external, and business continuity management and disaster recovery capabilities. In addition, the degree of automation across the trade lifecycle, from trade capture to margin collection and clearing, is fully assessed.

Finally, governance and transparency risk focuses on the quality of board oversight, risk committee structure and the openness of information disclosed to participants and the public.  

Data collection, verification and stakeholder engagement

Our assessment process is a blend of data collection, verification and stakeholder engagement. Public sources, such as policy documents, rulebooks, regulatory filings, annual reports, and disclosures, are mined for data. Questions regarding risk elements that cannot be validated by public sources will be sent to the CCP. In parallel to this, the CCP will be invited to participate in the annual review of the information that is undertaken by Thomas Murray. Where possible, on‑site meetings during market visits can be arranged to collect additional information.  

All the information we collect is mapped to our scoring templates. Each element receives a score based on compliance with the best practice benchmark and summed within its risk family. The families are weighted (with counterparty and liquidity together making up over 50% of the grade) and combined to produce a final score that’s converted to its corresponding letter grade.

By bringing together rigorous quantitative scoring with qualitative judgments drawn from years of experience and continuous monitoring of international best practices (as these develop over the years), Thomas Murray analysts can deliver a holistic picture of a CCP’s risk profile. The resulting grade not only guides clearing members in selecting the safest counterparties but also encourages CCPs to enhance transparency and strengthen resilience.

Hungary  

Following a recent operational review in Hungary the RC discussed several market developments that have taken place over the past year, including:

Central and Eastern European stock exchanges plan regional integration

On 25 August 2025, finance ministers and senior officials from Bulgaria, Croatia, Hungary, North Macedonia, Poland, Romania, Slovakia, and Slovenia signed a Memorandum of Understanding (MoU) in Zagreb. The MoU formalises the commitment of the involved countries to work together to enhance the integration of capital market infrastructures in the region. The MoU builds on the strategic agreement signed in November 2024 between the stock exchanges in the signatory countries and the European Bank for Reconstruction and Development (EBRD).

KELER Strategy for 2025

In July 2025, KELER, the Hungarian central securities depository (CSD), published its annual client information document, outlining its development plans for 2025. A description of the projects pertaining to post‑trade services and market infrastructure includes, amongst other things, the following:

• VIBER ISO 20022 Migration: In November 2025, Swift will mandate the use of the ISO 20022 messaging format for cross‑border payment orders. As a result, KELER will implement the migration from the current MT messages to the new ISO 20022 XML format for messages between the CSD and the Hungarian Central Bank. The rollout of ISO 20022 messaging standards is expected to take place on 27 October 2026.
• Cross‑Border Payments and Reporting Plus (CBPR+): In line with the Swift CBPR+ project schedule, KELER is working to ensure the full migration of all MT messages to MX‑based messages. The migration deadline was 22 November 2025.
• GIRO Platform Consolidation: The Hungarian Central Bank is working in collaboration with GIRO to consolidate the three Hungarian settlement platforms. The aim of the project is to technically discontinue the nighttime and daytime settlement platforms by transferring their functionality into the instant payment platform to enhance interoperability. Full integration is expected to take place on 1 March 2027.

Regarding local custodian banks, one bank has had an operational risk upgrade due to confirmation that penetration testing is now being completed annually (whereas this information was previously undisclosed).  

One other bank reviewed has had an asset servicing downgrade due to confirmation that market claims are being processed by the custodian only upon client request - as opposed to a previous understanding that market claims were being processed proactively by the agent.

Chile, Peru and Colombia

A due diligence visit to Chile in November 2025 saw a review of some custodians in the market as well as market developments, as follows:

Nuam Integration

• Single Trading Platform: Nuam (the consolidated Chile, Peru and Colombian markets) continues to advance with the implementation of the Nasdaq-developed single trading platform. After several delays, the rollout for Colombia and Peru - originally scheduled for December 2025 - has been postponed to January 2026. Implementation in Chile remains on hold, pending connectivity to the Electronic Exchange.
• Clearing Interoperability: Nuam has initiated the development of an interoperability framework for the three central clearing houses. As part of this process, a new CCP is being established in Peru. The implementation of the new clearing system is expected in Q3 2026.
• Single CSD Platform: In parallel, the bank noted that Nuam plans to launch a single CSD platform in Q2 2027, enabling full interoperability among the depositories.
• Fixed Income Integration: Once the equity market phase is operational, the next step will be the consolidation of the fixed income markets, currently targeted for Q1 2028.

• T+1 Settlement: Nuam plans to implement T+1 settlement in the second half of 2027. A dedicated T+1 Committee - comprising brokers, CCPs, CSDs, regulators, and custodian banks - will be formed in October 2025 to define requirements and oversee the implementation roadmap.

  Chile and Colombia may adopt a T+1 settlement cycle earlier than H2 2027, provided the new Nuam systems allow, and that the home markets of the securities involved have already transitioned to T+1.

• CBDC: In June 2025, the Central Bank launched a proof-of-concept pilot to assess the feasibility of a Central Bank Digital Currency (CBDC). The initiative aims to build internal expertise on the risks and benefits of a potential future issuance.

Regarding the banks, one Chilean custodian saw an asset servicing upgrade, due to a change in service level in market claims being initiated proactively rather than only on client request. The same custodian also saw an operational risk downgrade, due to a change in their internal audit frequency to “Biennial” (where it was previously conducted on an “Annual” basis).  

Venezuela

The RC Outlook for Venezuela in the Capital Market Infrastructure Risk Assessment (CMIRA) and Market Asset Safety Risk Assessments (MASRA) has been changed to ‘On Watch’ following the limited military but ongoing political intervention by the United States.