On September 28, 2012, the IIF’s Cross-Border Resolution Working Group, Infrastructure Working Group, and the Special Committee on Effective Regulation submitted a comment letter in response to the consultative report, Recover and Resolution of Financial Market Infrastructures, published by the Committee on Payment and Settlement Systems (CPSS) and the International Organization of Securities Commissions (IOSCO). The IIF recommended that the CPSS and IOSCO convene a roundtable of key stakeholders to discuss the important issues that are unresolved in the consultative report. In addition, the IIF suggested that the CPSS and IOSCO draw clearer distinctions between normal operating procedures, recovery and resolution in its future reports, and that the CPSS and IOSCO consider issues unique to FMIs, which may not be adequately addressed by the FSB’s Key Attributes.