(8)‘CCPs’ are defined by the SEC as clearing agencies that interpose themselves between counterparties, acting as the buyer to every seller and the seller to every buyer. The term ‘clearing agency’ is defined in Section 23(A) of the Securities Exchange Act of 1934 as any person who acts as an intermediary in making payments or deliveries or both in connection with transactions in securities or who provides facilities for the comparison of data regarding the terms of settlement of securities transactions, to reduce the number of settlements of securities transactions, or for the allocation of securities settlement responsibilities.