Joint Trade Association Letter on EMIR Bilateral Margin Requirements for Equity Options

On November 10, ISDA and seven other trade associations wrote to the European Supervisory Authorities (ESAs) to ask them to provide guidance to national competent authorities (NCAs) to exercise their supervisory powers in relation to the European Market Infrastructure Regulation (EMIR) margin requirements for equity options in a proportionate and risk-based manner between January 4, 2024 and the go-live date for EMIR III. Alternatively, the ESAs should extend the temporary exemption in the EMIR bilateral margin regulatory technical standards beyond the current January 4, 2024 expiry date or until EMIR III takes effect.

It is expected that the European Parliament and Council of the EU will support a permanent exemption for equity options from EMIR bilateral margin requirements.

The EMIR bilateral margin requirements have included a time-limited exemption for equity options since they first entered into force in 2016. This exemption has been extended several times, accompanied by guidance from the ESAs that NCAs should exercise their supervisory powers in a proportionate and risk-based way to bridge gaps between the expiry of previous exemptions and the entry into force of amended bilateral margin rules extending the derogation.

Documents (1) for Joint Trade Association Letter on EMIR Bilateral Margin Requirements for Equity Options

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...

Response to SEC on FICC Guaranty Fund

On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...