ISDA and SIFMA respond to the Consultation Paper on the Draft regulatory technical standards (the “Draft RTS”) on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP under Art. 11(15) of Regulation (EU) No 648/2012 published by the European Securities and Markets Authority (ESMA), the European Banking Authority (EBA) and the European Insurance and the Occupational Pensions Authority (EIOPA, and together with ESMA and EBA, the ESAs) on April 14, 2014.