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.

FRTB Impact on Correlation Trading

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A Path to Greater CFTC-SEC Alignment

Earlier this week, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) held a roundtable on regulatory harmonization – an initiative we wholeheartedly support. The US regulatory framework has evolved over time to facilitate financial markets...