  Central Counterparties (CCPs) are widely promoted as a requirement for safe
banking with little dissent except on technical grounds (such as proliferation
of CCPs). Whilst CCPs can have major operational positives, we argue that CCPs
have many of the business characteristics of Rating Agencies, and face similar
business pressures. Thus we see a risk that prices from CCPs may develop the
characteristics attributed to ratings from Rating Agency pre-crisis. Business
over-reliance on ratings of questionable accuracy is seen as a cause of the
financial crisis. We see the potential for same situation to be repeated with
prices from CCPs. Thus the regulatory emphasis on CCPs, rather than on
collateralization, may create the preconditions for an avoidable repeat of the
financial crisis.
