On November 20, ISDA, FIA and the Institute of International Finance submitted a joint response to the Financial Stability Board (FSB) on its consultation on financial resources and tools for central counterparty (CCP) resolution. In the response, the associations express concern that the proposed approach leaves too much flexibility to resolution authorities, and call for more transparency and predictability on what may happen in a resolution scenario, including the tools resolution authorities may use and the circumstances and order in which resolution authorities would be likely to deploy those tools.
The associations also highlight the importance of ensuring that a CCP’s own equity is calibrated in a way that fosters correct incentives for CCP risk management and suggest this should be considered across the recovery and resolution continuum, rather than looking at resolution resources in isolation. The response stresses that authorities should not overly rely on tools such as cash calls and variation margin gains haircutting, which could severely damage market confidence and would come with serious risks to financial stability. The response also includes a detailed discussion on the FSB’s analysis of the resolution tools considered in the consultation.
Documents (1) for Response to FSB on CCP Resolution Resources
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...
