AIMA supports the Financial Stability Board (“FSB”) consultation’s aim to ensure that all market participants have robust systems and controls in place to manage liquidity risk in times of stress. AIMA’s response urges the FSB to focus on entities not already subject to appropriate regulations, take into account the role and risks banks and infrastructure providers may pose and consider relaxing the often rigid requirement to use cash only for margin calls. The FSB is scheduled to publish its final report in December.