2015/16 Assessment of ASX Clearing and Settlement Facilities 2. Summary and Review of Regulatory Priorities
This Section summarises actions taken by the ASX CS facilities during 2015/16 in relation to regulatory priorities identified in the 2014/15 Assessment, and summarises the recommendations and other priorities identified by the Bank in its 2015/16 Assessment of the facilities against the Financial Stability Standards for Central Counterparties (CCP Standards) and the Financial Stability Standards for Securities Settlement Facilities (SSF Standards).
2.1 Progress against 2014/15 Recommendations and Other Priorities
The Bank's 2014/15 Assessment set out a number of recommendations for the ASX CS facilities to address areas of concern identified in respect of various standards, or to support continuous improvement. The 2014/15 Assessment also noted several developments that the Bank would continue to monitor and other matters that the Bank wished to discuss further with ASX. Together these matters formed the Bank's regulatory priorities for the 2015/16 Assessment period.
The following table summarises the recommendations and other regulatory priorities made in the 2014/15 Assessment, and actions taken by the ASX CS facilities in relation to these recommendations during the 2015/16 Assessment period.
| Recommendation/Priority | Standard | Facility | Actions |
|---|---|---|---|
| Recommendations to address areas of concern | |||
| Recovery planning, loss and liquidity allocation. Complete planned updates to the documentation of recovery plans, and integrate review of recovery plans into the broader risk management and default management framework. Periodically review arrangements for allocating uncovered credit losses and addressing liquidity shortfalls, and for allocating investment-related losses, to ensure that these remain consistent with international guidance on recovery planning. Develop additional participant disclosures regarding contingent exposure to loss allocation tools. | CCP Standards 3, 4, 7 and 14, SSF Standards 3 and 12 | All facilities | Mostly addressed. Expected to be fully addressed by end 2016. ASX has updated the facilities' recovery plans, taking into account the CCPs' expanded suite of recovery tools. ASX has also set out the framework for review of the plans and recovery tools, and developed information management tools to support decision-making in recovery scenarios. ASX also tested the use of recovery assessments in its most recent fire drill for exchange-traded products. ASX has developed aggregate quarterly disclosures on participants' contingent exposures to recovery assessments in both CCPs, and plans on developing similar disclosures on payments haircutting in ASX Clear (Futures) by end 2016. |
| Replenishment and recapitalisation arrangements. Further refine the CCPs' replenishment arrangements to ensure a more timely return to the required level of cover, while minimising the potential for procyclicality. Review the CCPs' capacity to replenish their own contributions to the default fund following a participant default, and ASX's capacity to raise additional equity to replenish business risk capital in respect of all facilities. |
CCP Standards 4 and 14, SSF Standard 12 |
All facilities | Fully addressed. ASX has implemented enhancements to its CCPs' arrangements to support a prompt return to the target level of financial cover following a participant default while mitigating the potential for procyclicality. ASX has established a framework for review of its capacity to replenish its own contribution to the CCPs' default fund. As part of this, ASX presented its recapitalisation plans to the Bank in late 2015. |
| Account structure. Complete implementation of client segregation arrangements that support the lodgement of excess client cash collateral against derivatives positions. Consider implications for portability arrangements arising from the management of the BBY default. | CCP Standard 13 | ASX Clear | Fully addressed. ASX Clear has introduced enhancements to client segregation arrangements to support the lodgement of excess client cash collateral against derivatives positions. As part of its review of experiences gained from the BBY default, ASX has continued to consider how account structures and transfer arrangements could be enhanced to facilitate porting. |
| Investment risk. Implement plans to transition to a treasury investment portfolio that meets the Bank's expectations for the credit and liquidity risk profile of ASX Clearing Corporation's treasury investment policy by 2016/17. | CCP Standard 15 | Both CCPs | Partly addressed. Expected to be fully addressed by end June 2017. ASX has further reduced the concentration of unsecured exposures to the large domestic banks. In early May, the CS Boards approved proposed further changes to the CCPs' investment mandate over 2016/17 so that the Bank's expectations can be met by end June 2017. |
| Resolution planning. Review operational arrangements in light of the proposed establishment of a special resolution regime for FMIs in Australia. | CCP Standard 16, SSF Standard 14 | All facilities | Ongoing. The Australian special resolution regime for FMIs in Australia is not yet in place, so there has been no progress. |
| Disclosure. Implement plans to regularly publish risk and activity data in accordance with international quantitative disclosure standards for CCPs. | CCP Standard 20 | Both CCPs | Fully addressed. In December, the CCPs began to publish risk and activity data in accordance with international quantitative disclosure standards. |
| Recommendations to support continuous improvement | |||
| Capital stress testing. Continue to review the interpretation of ‘extreme but plausible’ market conditions in light of evolving international best practice. Implement planned second-phase enhancements to the CCPs' stress test models. Continue to monitor the use, review and validation of stress test models, and the impact of absolute versus relative yield shocks in ASX Clear (Futures). | CCP Standard 4 | Both CCPs | Ongoing. In February 2016, the CCPs enhanced their stress test frameworks to incorporate intraday rather than close-to-close price movements. ASX is also considering adjusting its stress test framework to better account for spread, liquidity, and concentration risks. This recommendation has been carried over to the forthcoming Assessment period reflecting that CPMI-IOSCO issued draft guidance on CCP resilience and recovery only in August, with the final guidance expected to be published only in early 2017. |
| Margining. Review the CCPs' margining approach in light of the external validation of its margin models, evolving international best practice and, for ASX Clear, experience gained from the BBY default. The review should examine key parameter assumptions, including the holding and look-back periods. | CCP Standard 6 | Both CCPs | Ongoing. ASX is considering introducing add-ons within its margin models to account for spread, liquidity and concentration risk. This recommendation has been carried over to the forthcoming Assessment period reflecting that CPMI-IOSCO issued draft guidance on CCP resilience and recovery only in August, with the final guidance expected to be published only in early 2017. |
| Liquidity stress testing. Continue to review the liquidity stress test approach in light of the external validation of the CCPs' liquidity stress test models and evolving international best practice. | CCP Standard 7 | Both CCPs | Ongoing. In light of the findings of the recent CPMI-IOSCO implementation monitoring exercise and following discussions with the Bank, ASX has produced a range of liquidity-specific stress test scenarios to improve its ability to assess the adequacy of the CCPs' liquid assets. This recommendation has been carried over to the forthcoming Assessment period reflecting that CPMI-IOSCO issued draft guidance on CCP resilience and recovery in August; the final guidance is expected to be published only in early 2017. |
| Liquidity risk. Continue to refine sensitivity analysis and reverse stress test, and integrate these into ASX Clear's broader stress test and liquidity management processes. Further consider how ASX Clear models its reliance on offsetting transaction arrangements, and implement planned participant disclosures regarding their contingent exposure to offsetting transaction arrangements. Carry out plans to develop disclosures to settlement participants. | CCP Standard 7, SSF Standard 6 | ASX Clear, ASX Settlement | Mostly addressed. ASX has split out the derivatives and cash market components of its liquidity stress test exposure in its management reporting, which has allowed management to further consider the degree of ASX's reliance on offsetting transaction arrangements in ASX Clear. ASX has also enhanced the analysis of the priming assumption underlying its liquidity stress test model. In addition, ASX Clear has developed additional disclosures to assist participants in understanding their contingent exposures to offsetting transaction arrangements in an extreme but plausible scenario. These disclosures will be distributed to participants on a monthly basis. |
| Default management. Complete the review of experiences gained from the BBY default, and update default management and risk management arrangements as appropriate. | CCP Standards 4, 12 and 17 | ASX Clear | Partly addressed. ASX has carried out a comprehensive review of experiences gained from the BBY default and set out a plan for further refining its risk and default management arrangements. ASX also started work to update its DMF documentation to reflect the experiences gained from the BBY default; this update is expected to be finalised in 2016/17. |
| Cyber security. Continue engagement with the Bank on cyber risk management and governance arrangements, and review these arrangements in light of forthcoming international guidance on cyber resilience for FMIs. | CCP Standard 16, SSF Standard 14 | All facilities | Ongoing. ASX has continued its dialogue with the Bank on the cyber risk management arrangements of its CS facilities. The CPMI-IOSCO guidance on cyber resilience for FMIs was published on 30 June 2016; this recommendation will therefore be carried over to the forthcoming Assessment period. |
| Other regulatory priorities – matters for further consideration by the Bank | |||
| User governance. Monitor the effectiveness of user governance arrangements. | CCP Standard 2, SSF Standard 2 | All CS facilities | The Bank has continued to monitor user governance arrangements through the review of minutes of meetings and ongoing engagement with ASX. |
| Collateral concentration. Continue discussion on approach to monitoring collateral concentration risks. | CCP Standard 5 | Both CCPs | The Bank has continued to monitor collateral concentration risk, including by reviewing data measuring this risk. |
| Engagement with Payment Providers. Monitor interaction with the Australian Payments Clearing Association standing sub-committee for Payment Providers. | CCP Standard 9, SSF Standard 8 | ASX Clear, ASX Settlement | The Bank met with ASX to discuss its interaction with the Australian Payments Clearing Association standing subcommittee for Payment Providers. |
| Default management review and testing. Continue to monitor the review of default management procedures for OTC derivatives. | CCP Standard 12 | ASX Clear (Futures) | As part of the special topic on the CS facilities default management arrangements, the Bank reviewed ASX's OTC default management procedures. The Bank also monitored ASX's default management fire drills. |
| Commingled pooled resources. Monitor ASX Clear (Futures)' annual review of its use of commingled pooled financial resources for OTC and exchange-traded derivatives, as well as the adequacy of those resources. | CCP Standard 12 | ASX Clear (Futures) | The Bank will monitor the outcomes of the next annual review of ASX Clear (Futures)' use of its commingled pooled financial resources, planned to be completed in August. |
| Disclosure of investment risk. Discuss disclosure of investment risks to participants in light of plans to allocate investment losses in excess of $75 million to participants. | CCP Standard 15 | Both CCPs | ASX has introduced additional disclosures to support participants in quantifying their contingent liquidity risk to investment losses in excess of $75 million. |
| Major projects. Monitor prioritisation decisions, resourcing challenges, interdependencies with regular processes, and potential change-management issues associated with the technology transformation project. This includes the prioritisation of investment in the replacement of CHESS. | CCP Standard 16, SSF Standard 14 | All CS facilities | The Bank has monitored ASX's technology transformation project through quarterly updates. The Bank has also received updates on the replacement of CHESS through monthly workshops involving ASX, a service provider and other regulators. |
| Critical service providers. Discuss the application of international oversight expectations in managing relationships with external providers of critical services. | CCP Standard 16, SSF Standard 14 | All CS facilities | During the 2015/16, the Bank met with ASX to discuss its arrangements to manage the risks arising from critical service providers, and how it applies the CPMI-IOSCO Assessment Methodology. |
| Concentration in tiering. Continue to monitor the operation of ASX's approach to monitoring concentration risks in tiered participation. | CCP Standard 18 | Both CCPs | The Bank has continued its discussion on ASX's approach to monitoring concentration risks in tiered participation. |
2.2 2015/16 Ratings and Recommendations
In undertaking its Assessment, the Bank has applied the rating system used in the Principles for Financial Market Infrastructures: Disclosure framework and assessment methodology produced by CPMI and IOSCO in December 2012. Under this rating system, a facility's observance of a standard may be rated as:
- Observed – Any identified gaps and shortcomings are not issues of concern and are minor, manageable and of a nature that the facility could consider taking them up in the normal course of its business.
- Broadly observed – The assessment has identified one or more issues of concern that the facility should address and follow up on in a defined timeline.
- Partly observed – The assessment has identified one or more issues of concern that could become serious if not addressed promptly. The facility should accord a high priority to addressing these issues.
- Not observed – The assessment has identified one or more serious issues of concern that warrant immediate action. Therefore, the facility should accord the highest priority to addressing these issues.
- Not applicable – The standard does not apply to the type of facility being assessed because of the particular legal, institutional, structural or other characteristics of the facility.
Section 821A(aa) of the Corporations Act requires that a CS facility licensee, to the extent reasonably practicable to do so, comply with the FSS and do all other things necessary to reduce systemic risk. The Bank has assessed how well each CS facility has complied with each CCP or SSF Standard, and applied a single overall rating to each standard, reflecting this assessment.
It is the Bank's assessment that all four facilities have observed almost all relevant requirements under the FSS in the Assessment period. The only exception is CCP Standard 15: Custody and Investment Risk, for which the two ASX CCPs have broadly observed the relevant requirements. The Bank therefore concludes that the facilities have conducted their affairs in a way that causes or promotes overall stability in the Australian financial system.
The Bank has nevertheless made a number of recommendations to address areas of concern and to further strengthen the ASX facilities' observance of requirements under the FSS:
- Table 2 summarises the recommendations that the CS facilities should address to observe or continue observing relevant requirements in the FSS.
- Table 3 summarises the recommendations to encourage continuous improvement. Such improvement contributes to the ASX CS facilities' ongoing compliance with the obligation to do all other things necessary to reduce systemic risk.
- Table 4 lists other matters identified in the course of conducting the Assessment that the Bank will continue to monitor or discuss with ASX. These include areas in which ongoing review is required to ensure that emerging new risks are adequately controlled.
The recommendations and other matters in Tables 2 to 4 will form the basis for the Bank's regulatory priorities in 2016/17, and are discussed in more detail in Sections 3 and 4; Appendix A sets out the Bank's ratings and recommendations against each Standard for each facility.
| Recommendation | Facility | Standard |
|---|---|---|
| Liquidity stress testing. In order to continue to observe
CCP
Standard 7, ASX Clear and ASX Clear (Futures) should implement plans to
expand
and refine their liquidity-specific stress scenarios and integrate these
into
their liquidity stress test frameworks. For ASX Clear (Futures), the
expanded
scenarios should include stress tests of non-Australian dollar liquidity
exposures. ASX Clear should continue to refine and enhance the sensitivity analysis of its liquidity stress test model. This includes examining further the sensitivity of outcomes to certain underlying assumptions, such as the level of priming of securities. ASX Clear should ensure that its liquidity stress test framework is aligned with a clearly defined strategy for managing liquidity obligations in a default scenario. ASX Clear should implement plans to maintain sufficient liquid resources to cover a pre-specified value of stressed liquidity exposures arising from cash market transactions, while continuing to maintain sufficient liquid resources to cover stressed liquidity exposures arising from derivatives transactions. For both ASX Clear and ASX Clear (Futures), processes should be in place to respond promptly to any breaches of target liquidity coverage; these processes should be clearly documented. |
Both CCPs | CCP Standard 7 |
| Liquidity risk management. In order to continue to observe
CCP
Standard 7, ASX Clear should conduct appropriate due diligence on its
participants' ability to understand, quantify and manage any contingent
liquidity obligations under its Rules. ASX Clear should ensure that its
disclosures remain consistent with its liquidity risk management framework
and
assist participants in understanding their contingent exposure to the use of
tools to address a liquidity shortfall. ASX Clear should enhance and formalise its processes for conducting due diligence on the ability of its committed liquidity providers to perform as required under those commitments. |
ASX Clear | CCP Standard 7 |
| CCP default management. In order to continue to observe CCP
Standard 12, ASX Clear and ASX Clear (Futures) should continue enhancing
their
approach to the testing and review of their default management arrangements.
Such enhancements should include increasing the complexity and scope of
their
default management fire drills. Both CCPs should also ensure that these fire
drills involve all relevant internal and external stakeholders and
committees,
and test the interaction between all relevant stakeholders. ASX Clear and ASX Clear (Futures) should more prominently involve their default brokers in the testing of default management arrangements for exchange-traded products. On an annual basis, both CCPs should engage with their default brokers on the default brokers' proposed method for closing out the hypothetical portfolio used in the fire drill, including expected close-out prices and timeframes. ASX Clear and ASX Clear (Futures) should also involve the Risk Consultative Committees and other clearing participants in future default management fire drills that test the CCPs' recovery arrangements. As part of their annual review of the DMF, ASX Clear and ASX Clear (Futures) should assess the potential implications of any changes to the resolution regimes that govern their participants. This includes the resolution regimes of any offshore-based participants. ASX Clear and ASX Clear (Futures) should also review their DMF in light of the proposed establishment of a special resolution regime for FMIs in Australia, once the regime has been finalised. ASX Clear (Futures) should validate through its testing and review processes its expectation that its default management arrangements take appropriate account of stability interests in other jurisdictions in which it has material activity, most notably in New Zealand. |
Both CCPs | CCP Standard 12 |
| SSF default management. In order to continue to observe SSF
Standard 11, ASX should carry out further work to enhance the DMF
documentation
for its SSFs, including the documents that set out the specific procedures
to be
followed in the event of default of an Austraclear participant, ASX
Settlement
participant, Participating Bank, or Payment Provider. In particular, these
documents should provide guidance on the discretionary decisions that may
need
to be taken by the Participant Incident Response Committee and other
relevant
parties, including elaborating on relevant factors for consideration in
making
these decisions. ASX Settlement and Austraclear should formalise the review of their default management procedures within ASX's broader framework for testing and review of the DMF. ASX Settlement and Austraclear should carry out their plans to enhance participant and client education and communication regarding their default management arrangements. As part of this:
In developing its new system for clearing and settlement of cash market securities, ASX Settlement should ensure that any default management processes are clearly documented, and that the effectiveness of these processes can be tested and reviewed on an ongoing basis. ASX Settlement and Austraclear should continue enhancing their approach to the testing and review of their default management arrangements. Such enhancements should include increasing the complexity and scope of the ASX default management fire drills. ASX Settlement and Austraclear should also ensure that these fire drills involve all relevant internal stakeholders and committees, and test the interaction between all relevant stakeholders. As part of the annual ASX default management fire drills, consideration should be given to the implications of the default of an Austraclear participant, ASX Settlement participant, participating bank or Payment Provider for other ASX CS facilities. |
Both SSFs | SSF Standard 11 |
Investment risk. In order to fully observe CCP Standard 15,
ASX
Clear and ASX Clear (Futures) should implement plans to:
|
Both CCPs | CCP Standard 15 |
Cyber resilience. In order to continue to observe CCP
Standard
16 and SSF Standard 14, the CS facilities should review their cyber risk
management arrangements in light of CPMI-IOSCO guidance on cyber resilience
for
FMIs. As part of this review, the CS facilities should:
|
All facilities | CCP Standard 16, SSF Standard 14 |
| Resolution planning. In order to continue to observe CCP Standard 16 and SSF Standard 14, the CS facilities will need to review their operational arrangements in light of the proposed special resolution regime for FMIs in Australia, once the regime has been finalised. In particular, the CS facilities will need to ensure that their operations are organised in such a way as to facilitate effective crisis management actions under that regime. | All facilities | CCP Standard 16, SSF Standard 14 |
| Recommendation | Facility | Standard |
|---|---|---|
| Documentation. ASX Clear and ASX Clear (Futures) are encouraged to continue enhancing the documentation of the key elements of their financial risk management frameworks, including clear articulation to participants and regulators (and where appropriate the public) of the analytical basis and rationale for the choice and calibration of key margin and stress test model parameters and assumptions. | Both CCPs | CCP Standard 2 |
CCP guidance on resilience and recovery. ASX Clear and ASX
Clear (Futures) are encouraged to review the following aspects of their risk
management arrangements in light of forthcoming CPMI-IOSCO guidance on
resilience and recovery of CCPs:
|
Both CCPs | CCP Standards 2, 4, 5 and 7 |
| Recovery planning. The CS facilities are encouraged to continue to refine the documentation of their recovery plans, including considering further elaborating: stress scenarios; communications procedures; the methodology for determining critical services; how structural weaknesses are identified and addressed; and links to other FMIs. | All facilities | CCP Standard 3, SSF Standard 3 |
| Credit stress testing. ASX Clear (Futures) is encouraged to review the assumptions it makes regarding the value of its prefunded financial resources in extreme but plausible market conditions, in light of any changes to its collateral haircuts. | ASX Clear (Futures) | CCP Standard 4 |
| Liquidity, concentration and spread risks. ASX Clear and ASX Clear (Futures) are encouraged to complete their review of spread, concentration and liquidity add-ons for their margin and credit stress-testing models and incorporate these add-ons as appropriate. | Both CCPs | CCP Standards 4 and 6 |
Risk management system enhancements. ASX Clear and ASX
Clear
(Futures) are encouraged to continue to progress planned enhancements to
their
risk management systems, including to deliver the capability to calculate on
a
near real-time basis:
|
Both CCPs | CCP Standards 4, 6 and 7 |
| Liquidity risk management. ASX Clear and ASX Clear (Futures) are encouraged to regularly test their procedures for accessing their liquid resources, including the on-market liquidation or repo of non-cash collateral and collateral investments, drawdown of ASX Clear's committed liquidity facilities and potential repo of eligible securities at the Bank. | Both CCPs | CCP Standard 7 |
| CCP default management. ASX Clear and ASX Clear (Futures)
are
encouraged to complete their reviews of the DMF and finalise planned
enhancements to the relevant documents. ASX Clear is encouraged to implement its plans for enhancing the effectiveness of its default management arrangements, including improvements to portability and the close-out process for exchange-traded options, and finalise its policy on dealing with ‘specific cover’ exposures. ASX Clear and ASX Clear (Futures) are encouraged to continue examining ways in which their new risk management system could be used to facilitate, and mitigate risks arising in, the default management process. The CCPs are encouraged to continue developing the system functionality over time, integrating learnings from fire drills and other enhancements identified by the Default Management Steering Group. In the meantime, the CCPs are encouraged to continue to explore options to improve the effectiveness of the default management process within their existing systems. ASX Clear and ASX Clear (Futures) are encouraged to carry out plans to sign on an additional default broker for the markets that they clear for (i.e. ASX and Chi-X markets for ASX Clear, and ASX 24 for ASX Clear (Futures)). ASX Clear and ASX Clear (Futures) are encouraged to carry out their plans to enhance participant and client education and communication regarding the CCPs' default management arrangements. As part of this, the CCPs are encouraged to complete their planned updates of existing participant disclosures on the key aspects of their default management arrangements. For ASX Clear, this should include the development of an ASX Clear Client Fact Sheet. Any disclosures should be easily accessible, preferably in a centralised location. |
Both CCPs | CCP Standard 12 |
| Timeliness and reliability of insurance payments. The CS facilities are encouraged to review their assumptions in respect of the reliability and timeliness of payments under their insurance policies in calculating their general business risk capital. | All facilities | CCP Standard 14 and SSF Standard 12 |
| Commercial settlement banks. ASX Clear (Futures) is encouraged to review its risk management arrangements applicable to commercial settlement banks, and consider establishing a formal framework for the management of these risks. | ASX Clear (Futures) | CCP Standard 15 |
| Replacement of cash equities clearing and settlement system. ASX Settlement is encouraged to continue to invest in the ongoing maintenance and smooth functioning of the CHESS system in the transition to its replacement system, ensuring that it continues to meet the needs of users and that it continues to support stability in the financial system. ASX is also encouraged to invest in appropriate contingency arrangements, to ensure the timely implementation of an alternative CHESS replacement system should the decision be taken not to proceed with the DLT solution. | ASX Settlement | SSF Standard 14 |
| Participant core capital requirements. ASX Clear is encouraged to complete enhancements to participant minimum core capital requirements. | ASX Clear | CCP Standard 17 |
| Concentration in tiered participation. ASX Clear and ASX Clear (Futures) are encouraged to review their approach to monitoring concentration risks in tiered participation, including triggers for further investigation and actions, and processes for ongoing review of concentration risk. | Both CCPs | CCP Standard 18 |
| Priority | Facilities | |
|---|---|---|
| The Bank will continue to monitor the effectiveness of arrangements for stakeholder engagement in each of the ASX CS facilities, including the Risk Consultative Committee, Business Committee, Technical Committee and Exchange-traded Options Advisory Committee. | All facilities | CCP Standard 2, SSF Standard 2 |
| The Bank will monitor the annual review of the CCPs' prefunded financial resources, including consideration of the adequacy of those resources and whether the commingling of pooled resources for OTC and exchange-traded derivatives in ASX Clear (Futures) remains appropriate. | Both CCPs | CCP Standard 4 |
| The Bank will continue to discuss with ASX its approach to monitoring collateral concentration risks. | Both CCPs | CCP Standard 5 |
| The Bank will continue to monitor ASX Clear (Futures)' approach to portfolio margining of futures and OTC derivatives, particularly in light of ASX's launch of the margin optimiser service. | ASX Clear (Futures) | CCP Standard 6 |
| The Bank will monitor ASX's project to implement a DLT solution for the clearing and settlement of equities, including the governance arrangements supporting the project. | ASX Settlement | SSF Standard 14 |
| The Bank will continue to monitor prioritisation decisions, resourcing challenges, interdependencies with day-to-day business-as-usual processes, and potential change-management issues associated with ASX's technology transformation project. | All facilities | CCP Standard 16, SSF Standard 14 |
| The Bank will continue to engage with ASX on its approach to managing its relationship with external providers of critical services, including its application of the oversight expectations in the PFMI and associated Assessment Methodology. | All facilities | CCP Standard 16, SSF Standard 14 |