The International Swaps and Derivatives Association (ISDA) and Futures Industry Association (FIA) have published a joint response to a Bank of England (BoE) discussion paper on central counterparty (CCP) resolution. The associations support greater ex-ante clarity on valuation capabilities and the boundary between recovery and resolution, while opposing creditor hierarchy changes that would weaken the no-creditor-worse-off safeguard. They stress that default fund contributions should not absorb non-default losses. Where clearing members or other creditors bear losses or provide resources in resolution, ISDA and FIA underline the importance of credible mechanisms to return value to them, with profit-sharing arrangements cited as one option. The associations also encourage the BoE to consider alternative loss-absorption sources, such as right-sized CCP equity and parent-group capacity, before drawing on clearing member resources. On partial tear-up, the associations support commercially reasonable pricing and recognise that a pro-rata approach may often be equitable, but emphasise assessing hedging, liquidity and contagion effects on non-defaulting members and clients. ISDA and FIA also support the BoE’s proposed resolvability outcomes but call for greater transparency on resolvability assessments and resolution planning, and for assessments to address how the BoE would coordinate with third-country authorities where a UK CCP resolution could transmit losses or disruption outside the UK.