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
ISDA In Review – October 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in October 2026.
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 UK MIFIR Reporting Guidelines
On November 6, ISDA responded to the Financial Conduct Authority’s (FCA) consultation CP26/34 ‘Preparing for the new transaction reporting regime’ on the upcoming changes to the UK Markets in Financial Instruments Regulation (MIFIR) transaction reporting regime, as set out in...
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...
