On September 27, ISDA wrote to the European Commission (EC), asking it to address the conditions in Article 13 of the European Market Infrastructure Regulation (EMIR) and related equivalence decisions that make it difficult for EU firms to avoid duplicative and conflicting rules, including for the purpose of compliance with phases five and six of initial margin requirements for non-cleared trades.
Documents (1) for ISDA Writes to EC on EMIR Article 13 Equivalence
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ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...