ISDA and FIA Respond to ESMA’s Consultations on Guidelines in Relation to CCP R&R Regulation

On May 19, ESMA published four consultations on proposed guidelines for the EU central counterparty resolution regime (CCPRRR).

ISDA and the Futures Industry Association (FIA) responded to three of these four consultations:

  • Consultation on Guidelines Template Summary Resolution Plans Article 12(7)(a)
  • Consultation on Art 79 CCPRRR Cooperation Arrangements
  • Consultation on Guidelines Resolvability -Annex Section C Article 15(5) CCPRRR

The Associations generally agree with the proposals in the consultations and make mostly technical proposals.

Joint Response on Cross-margining

On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...

Response to SEC on FICC Guaranty Fund

On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...