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