(17)Secondly, the primary rules do not provide for a minimum liquidation period. However, all CCPs qualified as covered clearing agencies apply minimum liquidation periods of 2 to 5 days in accordance with their internal rules and procedures. Union rules set out minimum liquidation periods of 2 days for non-OTC derivative contracts and 5 days for OTC derivative contracts, typically with margin collected on a net basis. Therefore, the CCPs’ internal rules and procedures deliver substantive outcomes equivalent to the effects of the Union rules on liquidation periods.