ISDA letter to the ESAs on the Second Consultation Paper regarding draft regulatory technical standards on risk-mitigation techniques for OTC-derivative contracts not cleared by a CCP

ISDA responds to the Second Consultation Paper on the draft regulatory technical standards 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 ESAs on June 10, 2015. ISDA strongly supports the goals of strengthening systemic resiliency in the non-centrally cleared derivatives market by establishing risk mitigation techniques and margin requirements in accordance with the requirements of EMIR. In order to assist with the implementation of these requirements, we set out below our responses to the questions asked by the ESAs and raise other issues. Where appropriate, we suggest specific changes to the text of the Draft RTS.

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