The CFTC Division of Clearing and Risk (the Division) interprets Part 39 (subparts A, B and C) to incorporate all of the standards set forth in the PFMIs and, indeed, to be fully consistent with the PFMIs. This position is supported by CFTC Regulation 39.40, which states that [t]his subpart C is intended to establish standards which, together with subparts A and B of this part [Part 39 of CFTC regulations], are consistent with Section 5b(c) of the Act and the Principles for Financial Market Infrastructures… and should be interpreted in that context.