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
Latest
ISDA ALF: Katherine Tew Darras Opening Remarks
ISDA Annual Legal Forum New York, October 28, 2025 Opening Remarks Katherine Tew Darras ISDA General Counsel Good morning and welcome to the Annual Legal Forum here in New York. Thank you for joining us today and thanks to...
ISDA 2025 – 2002 Equity Derivatives Definitions (Versionable Edition) Protocol Opens for General Adherence
ISDA has opened the general adherence phase for the ISDA 2025 – 2002 Equity Derivatives Definitions (Versionable Edition) Protocol. The protocol enables adherents to amend the terms of their equity derivatives master confirmation agreements to incorporate the 2002 ISDA Equity...
ISDA Comment on ICC Application as Clearing Agency
On October 6 ISDA submitted a comment letter to the Securities and Exchange Commission in response to the ICE Clear Credit (“ICC”) application for registration as a clearing agency under Section 17A of the Securities Exchange Act of 1934, including...
Paper on Enhancing Liquidity and Risk Management
As ISDA marks its 40th anniversary this year, it is an opportune time to reflect on the challenges and opportunities faced by the global derivatives markets over the past four decades. Rapid growth, continued innovation, regulatory reform, central clearing, margining,...