<p><span>The Global Association of Central Counterparties (“CCP12”) appreciates the opportunity to contribute to the request for information and comments by the Commodity Futures Trading Commission (“Commission” or “CFTC”) - </span><b>Swap Clearing Requirement To Account for the Transition From LIBOR and Other IBORs to Alternative Reference Rates </b><span>(RIN 3038–AF18)</span></p>