Response to FSB on CCP Resolution Resources

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

ISDA Recommendations on EMIR under MISP

On November 2, ISDA published its recommendations on the European Parliament compromise amendments to the European Market Infrastructure Regulation (EMIR) under the Market Integration and Supervision Package (MISP). The briefing covers five areas: transaction reporting (Article 9), non-financial counterparties (Article...

Response on Transaction Reporting and Transparency

On October 30, ISDA submitted comments on the European Parliament’s (EP) proposed transaction reporting and transparency-related amendments to the European Commission’s Market Integration and Supervision Package (MISP). On transaction reporting, ISDA commends the EP’s ambition but cautions against trying to...