JAC, ICMA, and ISDA Supplementary Observations to Consultation on TUB Article 129 – English Translation

On July 14, the Joint Associations Committee on Retail Structured Products (JAC) along with the International Capital Market Association (ICMA) and ISDA (with the support of the Associazione Italiana Intermediari Mobiliari (ASSOSIM)) wrote to The Bank of Italy with supplementary observations relating to the consultation document “Information reporting as contemplated in Article 129 of the TUB relating to the offer of financial instruments in Italy” (dated October 2013). The response was filed to the Bank of Italy in Italian only. The original response to the same consultation is dated December 13, 2013 and is available on the JAC page.

Documents (1) for JAC, ICMA, and ISDA Supplementary Observations to Consultation on TUB Article 129 – English Translation

Raising Clients’ Awareness on Portability

Clients accessing a central counterparty (CCP) via a client clearing service provider (CCSP) for over-the-counter (OTC) and exchange-traded derivatives should consider what may happen to their positions and collateral in a scenario in which the CCSP defaults. While regulatory regimes...

Response to FCA on Ancillary Activities Test

On August 28, ISDA and FIA submitted a joint response to the Financial Conduct Authority’s (FCA) consultation paper CP25/19 on the ancillary activities test to determine if commercial users or producers of commodities that trade in commodity derivatives, emission allowances...

Stress Scenarios for CCP IM Simulators

ISDA has published a paper that explains why stress scenarios that central counterparties (CCPs) use for default fund sizing cannot be used for forward-looking initial margin (IM) simulators. Typically, stress scenarios used by CCPs consist of a single step, transitioning...

Paper on EMIR 3 Active Account Representativeness

On September 4, ISDA, the European Fund and Asset Management Association (EFAMA) and FIA shared a paper with EU policymakers requesting clarification on the implementation of the active account requirement under the third European Market Infrastructure Regulation in relation to...