FIA and ISDA (together the “Associations”) welcome the Bank of England’s consultation paper (CP) on operational resilience of Central Counterparties (CCPs). We applaud the UK authorities for focusing on the operational resilience of the entire financial sector – including Financial Market Infrastructures (FMIs) such as CCPs. We agree with the Bank of England’s assessment that disruption to clearing markets is a financial stability issue and support the policy objective for CCPs to be operationally resilient to disruption events. We also support the concepts of important business services and impact tolerances.
The Associations’ comments from the point of view of clearing members and their clients are:
- We believe that clearing members and their clients (collectively referred to as “clearing participants”) should have a voice in both identifying important business services and determining the impact tolerances.
- In addition, clearing participants should have a voice in determining the criteria for important business services. This is especially important as FMIs are very interlinked and no single FMI or market participant will have a view of how its service interplays with other FMIs and the wider market.
- Metrics on important business services should also be shared with affected clearing participants.
- Clearing participants should be included in testing.
Documents (1) for FIA and ISDA respond to BoE’s consultation on operational resilience for CCPs
Latest
ISDA In Review – September 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in September 2026.
ISDA Digital Assets Forum Opening Remarks
ISDA Digital Assets Forum Washington, DC October 6, 2026 Opening Remarks Scott O’Malia, CEO, ISDA Good morning, and a very warm welcome to the ISDA Digital Assets Forum. Thanks for joining us today, and a special thank you to...
Assessing Tokenized MMFs as Eligible Collateral
Distributed ledger technology and digital assets have matured from their early stages to solutions capable of addressing longstanding inefficiencies in collateral management. Tokenized money market funds (TMMFs) represent a particularly promising area for the application of this technology, combining the...
Response to EC on Carbon Accounting
On October 5, ISDA responded to the Joint Research Centre (JRC) of the European Commission (EC) survey, drawing on input from five member firms across the banking, exchange and market-data sectors. The response highlighted broad support for internationally recognized carbon...
