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
Latest
Guidance for EU IM Model Application for ISDA SIMM®
EU financial and non-financial EU counterparties exchanging IM based on ISDA SIMM® should have already submitted an initial application for authorisation to their competent authority (CA), and ECB if applicable. If not, they should do so timely to ensure continued...
Joint Response on Stress Testing Framework
On February 23, ISDA, the Bank Policy Institute, the American Bankers Association, the Financial Services Forum, the Securities Industry and Financial Markets Association and the US Chamber of Commerce jointly responded to the US Federal Reserve’s consultation on the stress...
Joint Letter on Italian 2026 Budget Law
On February 23, ISDA, the Association for Financial Markets in Europe and the International Securities Lending Association jointly sent a letter to the Italian tax authorities about changes to withholding tax on dividends made in the 2026 budget law, which...
Response to FCA on UK MIFIR Consultation
On February 20, ISDA responded to the Financial Conduct Authority’s (FCA) consultation on improving the UK Markets in Financial Instruments Regulation (MIFIR) transaction reporting regime. The consultation aims to reduce the regulatory burden on firms, support sustained economic growth in...
