ISDA response to HMT highlighting the following issues:
1. What indirect clearing requires – the policy view expressed in the consultation
2. Agency vs principal arrangements at indirect clearer level – the substantive
conclusion
3. Regulatory capital and netting implications
4. Handling of collateral
5. Cross-border arrangements
6. Implementation intentions in other EU member states
7. Powers of direction over clearing members
8. Cross border non-EEA structures
9. Achievability of individual segregation indirect clearing arrangements
Documents (1) for ISDA-BBA Preliminary response to HMT re. indirect clearing
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