On July 6, 2020, ISDA and AFME submitted their joint response to the European Commission’s consultation on the Delegated Acts (DAs) under MiFID II meant to introduce changes to suitability requirements and integrate sustainability risks across product governance, operating conditions, risk management and organisational requirements. In the response, the Associations recommend an appropriately staggered timetable for implementing the DAs due to the significant challenges that the proposed sequencing could pose for firms. The associations also note that availability of relevant and reliable environment, social and governance (ESG) data from issuers remains a significant issue, and will continue to remain so for some time, which will impede the process of identifying to what extent a product meets a client’s sustainability preferences. The Associations are still reviewing the definition of sustainability preferences in the DAs, particularly with respect to how Article 8 and 9 of the Disclosure Regulation should be applied to financial instruments, and they plan to engage further with the Commission on this issue.
Documents (1) for Joint ISDA and AFME Response to EC Consultation on MIFID II Draft Delegated Acts
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Joint Response to EBA Consultation
On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act under Article 8 of...
Response to JSCC on Clearing Fund Consolidation
On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...
Response on CSDD Guidelines
On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...
Response to BoE on Extension of Settlement Hours
On August 6, ISDA responded to the Bank of England’s (BoE) consultation paper on the extension of settlement hours for RTGS and CHAPS, the UK’s high-value payment system. ISDA supports the BoE’s plan to extend RTGS and CHAPS settlement hours...