On September 20, ISDA and FIA jointly responded to the European Securities and Markets Authority’s (ESMA’s) seven consultations on recovery-related topics in the central counterparty (CCP) recovery and resolution regulation.
A topic of particular interest to members was the consultation on the second tranche of skin-in-the-game. For this consultation, ISDA and FIA suggested the calibration be reviewed to add more indicators on financial risk management, along with additional proposed indicators.
ESMA’s consultations papers can be found here:
- Consultation on Draft Guidelines Further Specifying the Circumstances for Temporary Restrictions in the Case of a Significant Non-default Event
- Consultation on Draft Guidelines on the Consistent Application of the Triggers for the Use of Early Intervention Measures
- Consultation on Draft RTS on the Methodology for Calculation and Maintenance of the Additional Amount of Pre-funded Dedicated Own Resources
- Consultation on the Draft Guidelines on CCP Recovery Plan Indicators
- Consultation on Draft RTS on Order of Compensation Art. 20
- Consultation on the Draft Guidelines on CCP Recovery Plan Scenarios (Article 9(12) CCPRRR)
- Consultation on Draft RTS Further Specifying the Factors that Shall be Considered by the Competent Authority and the Supervisory College When Assessing the CCP Recovery Plan
Documents (7) for FIA and ISDA Respond to ESMA’s Consultations on CCP Recovery & Resolution
- FIA-ISDA response Art 20 Recompense(pdf) will open in a new tab or window
- FIA-ISDA response Early Intervention Measures(pdf) will open in a new tab or window
- FIA-ISDA response Recovery Indicators(pdf) will open in a new tab or window
- FIA-ISDA response Recovery Plan Assessment Factors(pdf) will open in a new tab or window
- FIA-ISDA response Recovery Plan Scenarios(pdf) will open in a new tab or window
- FIA-ISDA response Second Tranche SITG(pdf) will open in a new tab or window
- FIA-ISDA response Temporary Restrictions(pdf) will open in a new tab or window
Latest
Efficiency is Vital to Delivering Resilience
With less than three months to go until implementation of US Treasury clearing begins at the end of this year, it’s critical that the mandate is safely implemented without compromising market efficiency. This represents a huge change in market structure,...
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...