(3)The Commission has adopted two annual reports on 23 September 2020 2 and 6 May 2021 3 respectively. In those reports, the Commission observed that market participants have made efforts over the years to develop appropriate technical solutions which include collateral transformation either by clearing members or through cleared repo markets. The Commission also noted that some pension scheme arrangements have started to centrally clear a portion of their derivatives portfolios voluntarily. The report concluded that the key remaining challenge for pension scheme arrangements was access, in stressed market conditions, to liquidity to be able to post variation margin, because that requirement would rapidly and significantly increase the risk of exhausting the cash allocations of pension scheme arrangements.