Rolling Window with a Fixed Cap

Rolling Window with a Fixed Cap

Brief Overview:

The framework on replenishment of default funds vis-à-vis a non-defaulting member is proposed to be calculated based on a rolling window of 30-days, but the same will be limited to 5x of the contribution determined at the time of default.

The proposal is open for comments till 23rd January 2026.

Technical Details:

Key Highlights

1) Capping of liability of the non-defaulting member – default fund – independent of resignation.

2) On default, a non-defaulting member’s contribution to be limited to the lower of:

(a) 5x original contribution (at start of 30-day period) minus what’s already used; and

(b) 5x revised contribution (if resized during the period) minus what’s already used after the revision.

3) Multiple revisions: Calculate for each revision; lowest amount applies.

4) Rolling 30-day window: Ensures predictability and clear liability limits.

5) Max liability certainty: Never exceeds 5x contribution – start default fund.

Takeaways:

The change brings absolute certainty on maximum exposure, eliminates dependency on resignation, and enables better liquidity planning and risk predictability for members.

For further details, please see:

CCIL- Consultation Paper

For any queries/clarifications, please feel free to ping us and we will be happy to chat:
Smrithi Nair ,Mahak Saboo & Kshemya Nair

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