ISDA Letter on Reform of UK EMIR

On December 22, 2022, ISDA CEO Scott O’Malia sent a letter and accompanying note to HM Treasury, the Financial Conduct Authority and the Bank of England with recommendations to reform the UK European Market Infrastructure Regulation intragroup transaction exemption and the equity options exemption for variation margin and initial margin.

ISDA proposes that there should be permanent intragroup exemptions from margin and clearing requirements for over-the-counter derivatives between UK and non-UK group companies, which do not depend on equivalence determinations in respect of non-UK countries. The note presents a set of reforms that would give the industry clarity and would remove a cliff edge for some firms at the end of 2023. The letter also urges UK authorities to permanently exempt single-stock options and equity index options from margin requirements, and to communicate plans early to firms that otherwise face an uncertain implementation period.

ISDA Response on Hedge Accounting Guidance

On August 14, ISDA responded to an exposure draft from the Financial Accounting Standards Board (FASB). ISDA broadly supports the FASB’s proposed targeted improvements to hedge accounting, including allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognizing all Secured...

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...