(18)Thirdly, Union law requires the application of at least one of three anti-procyclicality measures to ensure that initial margins do not fall too low in stable economic times and do not increase precipitously in times of stress. In doing so, such measures deliver stable and conservative margins. The primary rules contain no such specific requirement. CCPs qualified as covered clearing agencies, however, do have in place internal rules and procedures with anti-procyclical effects. Therefore, the CCPs’ internal rules and procedures deliver substantive outcomes equivalent to the effects of the Union rules on anti-procyclicality.