ISDA and AFME Response to FCA on Transparency of Enforcement Decisions

On February 17, ISDA and the Association for Financial Markets in Europe (AFME) responded to the UK Financial Conduct Authority’s (FCA) consultation on greater transparency of enforcement decisions. The FCA’s proposal, which gives it the ability to publicly name firms at the start of an investigation, continues to cause trepidation across the industry. In the response, ISDA and AFME highlight concerns that the current proposals are harmful to UK competitiveness and growth and suggest a broader interpretation of the existing exceptional circumstances test could be used to meet the FCA’s objectives. This is the second consultation ISDA and AFME have responded to. The first response from May 7, 2024 is available here.

Documents (1) for ISDA and AFME Response to FCA on Transparency of Enforcement Decisions

Expanding the Universe of Eligible VM

ISDA conducted a series of interviews with buy- and sell-side firms to understand the drivers of a growing use of non-cash assets as variation margin (VM) for non-cleared over-the-counter (OTC) derivatives and the barriers that remain to expanding the use...

ISDA Response on Hedge Accounting Guidance

On August 14, ISDA responded to an exposure draft from the Financial Accounting Standards Board (FASB). ISDA broadly supports the FASB’s proposed targeted improvements to hedge accounting, including allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognizing all Secured...

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...