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The NAPF issued its comments in response to the Basel Committee on Banking Supervision ("BCBS") and the International Organization of Securities Commissions' ("IOSCO") requests for comment as to the amount and handling of margin to be posted as part of OTC derivatives trades. The key points asserted by NAPF are as follows: Pension schemes use derivatives largely to hedge liabilities and, thereby, reduce risk. Extra costs or processes that provide a disincentive for pension schemes to use derivatives could in fact increase the degree of risk in the markets. The new margin requirements would