On March 26, ISDA and the Association for Financial Markets in Europe submitted a joint response to the European Banking Authority’s (EBA) consultation on implementing technical standards for the 2025 internal models benchmarking exercise. The industry is cognizant of significantly reduced participation in internal models approach benchmarking after implementation of the Fundamental Review of the Trading Book, based on expectations for model applications. The number of firms taking part overall, as well as the number of firms submitting data for specific portfolios, could be lower than the number required to support a meaningful benchmarking exercise. In the response, several issues are identified with the specification of instruments, and it is recommended these specifications are amended to provide greater clarity in the booking of these instruments.
Documents (1) for ISDA Response to EBA on Internal Models Benchmarking
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...