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In a joint discussion paper, SIFMA, the International Swaps and Derivatives Association ("ISDA"), and the Futures Industry Association ("FIA") asserted that current capital rules on qualifying central counterparty's ("QCCP's") default fund contributions—which base capital requirements on a qualifying central counterparty's "hypothetical capital requirement"—do not adequately "reflect the economics and risk offsets of QCCP cross-margining."