ISDA letter to global regulators on the use of a broad product set for purposes of margin calculation

The scope of products subject to the proposed margin requirements is not consistent across the EU, Japan and the US. The inconsistency in the margin product set raises problems for both VM and IM calculation, in addition to other cross-border situations. ISDA respectfully advises the regulators that for any counterparty pair, ISDA members intend to mitigate this issue by choosing whether to use a broader product set rather than the set required by any specific regulation, in order to ensure the parties capture all in scope products.

Documents (1) for ISDA letter to global regulators on the use of a broad product set for purposes of margin calculation

Recognition of Cross-product Netting is Critical

US regulators are in the process of making important changes to the regulatory capital framework by proposing modifications to the enhanced supplementary leverage ratio, which should help stop it from acting as a non-risk-sensitive constraint on bank capacity – a...

ISDA, GFXD Response to FCA on SI Regime

On September 10, ISDA and the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association responded to the Financial Conduct Authority's (FCA) consultation paper CP25/20 on the systematic internalizer (SI) regime for derivatives and bonds. ISDA and the...

ISDA Response on Clearing Costs

On September 8, ISDA responded to consultation by the European Securities and Markets Authority (ESMA) on a draft regulatory technical standard on clearing fees and associated costs (article 7c(4) of the European Market Infrastructure Regulation (EMIR)). In the response, ISDA...