On November 17, ISDA responded to a joint Bank of England/Prudential Regulation Authority (PRA) consultation paper on UK withdrawal from the EU and changes before the end of the transition period.

In the response, ISDA asks the PRA to retain the existing scope of qualifying indices for the purposes of detailed rules on liquidity horizons in the new market risk rules on the Fundamental Review of the Trading Book. In relation to the binding technical standards on risk-mitigation techniques, the response calls for the PRA to clarify the position regarding UK phase-in of phases five and six of the initial margin requirements, and raises concerns about the operation of the exemption for intragroup transactions. ISDA welcomes the transitional relief that permits firms subject to the UK margin requirements to continue to accept European Economic Area UCITS as initial margin until March 31, 2022. However, we believe this permission should be permanent.