On June 2, ISDA, the European Banking Federation and FIA wrote to the European Commission (EC) and the European Securities and Markets Authority asking the EC both to expedite equivalence decisions relating to EMIR Article 13 and to extend a derogation from the clearing obligation for cross-border intragroup transactions by a further three years (for transactions where one entity is in a jurisdiction that has not yet been found equivalent). The derogation is set to expire on December 21, 2020. This follows a similar letter (sent on April 30) to the EC and European Supervisory Authorities regarding the expiry of the intragroup derogation regarding cross-border intragroup transactions in contracts that are not subject to the clearing obligation.
Documents (1) for Letter on Derogation of EMIR Clearing Obligation for Intragroup Transactions
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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...