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
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...
ISDA Omnibus Canadian Representation Letter
On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...
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...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...