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.
Documents (2) for ISDA Letter on Reform of UK EMIR
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ISDA Letter to FASB on Agenda Consultation
On June 30, ISDA submitted a comment letter to the Financial Accounting Standards Board (FASB) in response to the proposal File Reference No. 2025-ITC100, Agenda Consultation. In the letter, ISDA believes the highest priority should be given to expanding the hedge...
Joint Paper on UK EMIR Reform
On July 1, ISDA and UK Finance published a paper, which recommended a set of reforms for the UK European Market Infrastructure Regulation (UK EMIR), carefully considering each EU EMIR 3.0 reform and asking whether we would wish to adopt...
Response to FCA on UK EMIR Reporting
On June 30, ISDA submitted a response to chapter 5 of the UK Financial Conduct Authority’s (FCA) quarterly consultation CP25/16 on trade repository reporting requirements under the UK European Market Infrastructure Regulation (UK EMIR). Chapter 5 proposes ‘Amendments to the...
CDS Trading Activity in EU, UK and US Markets
This report analyzes credit derivatives trading activity reported in Europe. The analysis shows European credit derivatives transactions based on the location of reporting venues (EU versus UK) and product type. The report also compares European-reported credit derivatives trading activity to...