The International Swaps and Derivatives Association (ISDA), together with the Institute of International Finance (IIF) responded last year to the consultative paper on margin practices (the Response). Back then there were some issues that we acknowledged but could not develop further in the time available.
This paper provides some additional thoughts on these topics. In addition, we also address some discussions within industry over the last year.
In summary, we cover:
- Intraday variation margin (VM) collection practices: We consider the potential costs and benefits of CCPs paying out intraday margin, and note that there are pros and cons that need to be discussed with participants in each market.
- Measurement of procyclicality: To support comparability between models, measurement of procyclicality should be easy to implement and to understand.
- Governance considerations around anti-procyclicality (APC) tools: We flag the importance of governance of anti-procyclicality (APC) tools.
- Notice for margin rate increases: We consider whether CCPs can provide advance notice of margin rate changes, especially if the use VaR models.
- Forward-looking margin transparency: We propose simple scenarios as a basis for forward-looking margin simulators.
Documents (1) for Additional Thoughts on Margin Practices
Latest
A Financial Markets Revolution
Every financial center has its own unique features, but it was particularly fitting that ISDA’s recent Annual General Meeting (AGM) was held in Boston – not only a global hub for asset management and insurance, but also a city that...
ISDA AGM Studio: Nnamdi Okaeme & John Pucciarelli
Marking the 10‑year anniversary of the ISDA Standard Initial Margin Model (ISDA SIMM), Joel Clark, senior director, communications, at ISDA, speaks with Nnamdi Okaeme, ISDA’s head of SIMM, and John Pucciarelli, head of partnerships and director of industry engagement at...
Response on Legal Frameworks for Carbon Credits
On May 4, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Commission’s (EC) consultation on a legal framework for the inclusion of international carbon credits within the EU’s 2040 climate law framework. In the...
ISDA AGM Studio: Julia Hueckel and Chris Zuehlke
Julia Hueckel, director of global regulatory policy at Coinbase, and Chris Zuehlke, global head of Cumberland and partner at DRW, speak with Nicolette Cone, ISDA’s chief of staff and associate general counsel, on the rapidly evolving legislative framework for digital...
