Trade Associations Submit Letter on EMIR IM Model Validation

On July 8, ISDA, the Alternative Investment Management Association (AIMA), the European Fund and Asset Management Association (EFAMA) and the Securities Industry and Financial Markets Association’s asset management group (SIFMA AMG) have submitted a letter to the European supervisory authorities (ESAs) and the European Commission on initial margin (IM) model approval requirements set out in the European Market Infrastructure Regulation (EMIR 3.0). The letter highlights challenges posed by the three-month period granted to the European Banking Authority and national competent authorities (NCAs) to validate changes to an IM model and describes how the ISDA Standard Initial Margin Model (ISDA SIMM) schedule can be amended to address these issues.

The letter also recommends that phase five and six firms should be able to meet the IM model approval requirement by notifying their NCA that they will be using a pro-forma IM model (such as the ISDA SIMM). NCAs may request further information or block a firm’s use of a model, but these entities should be able to use the pro-forma IM model once they have notified their NCA, assuming no express disapproval.

Documents (1) for Trade Associations Submit Letter on EMIR IM Model Validation

ISDA Response on Clearing Costs

On September 8, ISDA responded to consultation by the European Securities and Markets Authority (ESMA) on a draft regulatory technical standard on clearing fees and associated costs (article 7c(4) of the European Market Infrastructure Regulation (EMIR)). In the response, ISDA...

ISDA Response on Margin Transparency

On September 8, ISDA responded to a consultation by the European Securities and Markets Authority (ESMA) on a draft regulatory technical standard under the European Market Infrastructure Regulation (EMIR 3.0) on margin transparency requirements. ISDA’s members are supportive of margin...

Paper on Liquidity Assessment for Single-name CDS

On September 5, ISDA submitted a paper to the European Securities and Markets Authority (ESMA) and the European Commission in support of its earlier response to ESMA’s Markets in Financial Instruments Regulation (MIFIR) review consultation package 4 (CP4) on transparency...

Response to EC on Delegated Regulation

On September 4, ISDA responded to the European Commission’s (EC) consultation on amendments to delegated regulation (EU) 2017.567. The key area of interest for ISDA was the proposed insertion of a new article 16a that establishes what constitutes a post-trade...