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
Joint Response to FCA and HMT Consultations
On January 16, ISDA and UK Finance responded to both the consultation on streamlining the UK European Market Infrastructure Regulation (UK EMIR) intragroup regime by the Financial Conduct Authority’s (FCA) and the draft statutory instrument from His Majesty’s Treasury (HMT)....
Key Trends in OTC Derivatives Market H1 2025
The latest data from the Bank for International Settlements (BIS) over-the-counter (OTC) derivatives statistics shows an increase in notional outstanding of OTC derivatives during the first half of 2025 compared to the first half of 2024. Notional outstanding rose across...
Credit Derivatives Trading Activity Q3 2025
This report analyzes credit derivatives trading activity reported in Europe. The analysis shows European credit derivatives transactions based on the location of reporting venues (EU versus UK) and product type. The report also compares European-reported credit derivatives trading activity to...
Striking a Balance on EU Market Risk Capital
With US prudential regulators poised to publish a revised Basel III endgame proposal this year, and EU and UK regulators moving to finalize their own rules, ISDA is maintaining a laser focus on achieving a risk-appropriate capital framework that is...