On April 12, ISDA and the Institute of International Finance (IIF) responded to the Basel Committee on Banking Supervision (BCBS), Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) consultation on transparency and responsiveness of initial margin in centrally cleared markets. The associations support enhancing transparency on cleared margin for all market participants, as it will benefit intermediary and end-user preparedness for margin calls and increase the resilience of the system overall.
In the response, both associations expressed support for enhancing transparency on cleared margin for all market participants, which will help with liquidity preparedness and increase resilience of the system, noting it should start with central counterparties (CCPs) making fundamental disclosures about their margin models. In this regard, both associations highlight their support in the response to recommendations one through eight.
Regarding recommendation nine, ISDA and IIF are supportive of clients having necessary transparency on clearing member (CM) margin requirements. As is recognized in the consultative report, enhanced transparency should not curtail the ability of CCPs or CMs to take risk management actions to respond to dynamic or idiosyncratic stress scenarios within the clearing ecosystem.
Regarding recommendation 10, both associations are generally supportive of the principle that CCPs should have visibility into the risk profile of their clearing participants. Any standardized transparency framework required by CCPs of CMs should be limited only to the information required for CCP risk management and should not raise legal, confidentiality, or competition concerns. The current information required under recommendation 10 does not meet these criteria.
One area where the consultative report should go further is on initial margin model responsiveness. Further work should be done on the fundamentals of CCP margin models, for example appropriateness of margin periods of risk and the calibration of anti-procyclicality tools, to ensure that margins do not fall too low during low volatility periods.
This response covers the positions of our members on the buy-side and sell-side. The paper does not reflect the views of many CCPs, and many of the CCPs are in disagreement with the views.
Documents (1) for ISDA Response to Margin Transparency Consultation
Latest
Response to EC Call for Evidence on Tax Omnibus
On March 30, ISDA, the International Securities Lending Association and the Association for Financial Markets in Europe responded to the European Commission’s (EC) call for evidence on the tax omnibus. The associations argue that inconsistent interpretation of “beneficial ownership” among...
Managing Risk for Australian Superannuation Funds
Assets managed by the Australian superannuation sector reached A$4.5 trillion in December 2025, equivalent to around 160% of Australia’s GDP. Given its size, the sector has rapidly expanded its global footprint, with the share of offshore investments growing as a...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Next Steps on a Much Improved Basel III Endgame
Publication of the revised Basel III endgame proposal earlier this month marks an important step towards completion of the global capital reforms, giving banks much-needed clarity on the likely calibration of the rules in the US. The new proposal is...
