ISDA is concerned about the documentation that is required for parties to qualify for exemptions from the margin requirements under the Draft RTS on risk-mitigation techniques. This documentation is not required by Regulation (EU) No 648/2012 (“EMIR”) and imposing such requirements would result in very significant administrative and operational burdens. In the letter, we set out proposed alternative language that could be used to permit exemptions without documentation requirements. This letter is a supplement to the letter we sent to the ESAs on 14 July commenting generally on the Draft RTS.
Documents (1) for ISDA letter to the ESAs on Proposed Margin Rules: Documentation Requirements
Latest
ISDA Guidance: SOFR Publication on Good Friday 2026
ISDA guidance for parties to over-the-counter derivative transactions affected by expected non-publication of SOFR on Good Friday in 2026. Please note that the guidance may be updated from time to time.
ISDA Paper on FRTB Rules in Brazil
On March 24, ISDA submitted a paper to Banco Central do Brazil’s (BCB) on its implementation of the revised market risk framework under the Fundamental Review of the Trading Book (FRTB), which represents an important step toward strengthening prudential standards...
IQ Interview with Mark Uyeda
Mandatory clearing of US Treasury securities is due to begin at the end of this year under rules finalized by the Securities and Exchange Commission (SEC) in 2023. SEC commissioner Mark Uyeda talks to IQ about the benefits of clearing...
Response to FCA on CFI Codes for Transparency
On March 19, ISDA responded to Chapter 3 of the UK Financial Conduct Authority’s (FCA) Quarterly Consultation CP26/8 on transparency requirements for financial instruments under Market Conduct Sourcebook (MAR) 11. Sections 3.11-3.13 of the consultation paper explain a discrepancy between...