Joint Response to FCA Consultation on Ancillary Activities Test for Commodity Derivatives Trading

On August 28, ISDA and FIA submitted a joint response to the Financial Conduct Authority’s (FCA) consultation paper CP25/19 on the ancillary activities test to determine if commercial users or producers of commodities that trade in commodity derivatives, emission allowances or derivatives of emission allowances can benefit from the ancillary activities exemption from the need to seek authorization as an investment firm.

A key concern in the consultation paper was a proposal to include trading venue activity in the de minimis (annual threshold) test. ISDA and FIA argued strongly against this proposal, on the grounds it could diminish the international competitiveness of the UK commodity derivatives market, would add complexity and burden to firms applying the test and risks changing the outcome of the test, which the FCA stated was not the intention.

Documents (1) for Joint Response to FCA Consultation on Ancillary Activities Test for Commodity Derivatives Trading

Raising Clients’ Awareness on Portability

Clients accessing a central counterparty (CCP) via a client clearing service provider (CCSP) for over-the-counter (OTC) and exchange-traded derivatives should consider what may happen to their positions and collateral in a scenario in which the CCSP defaults. While regulatory regimes...

Response to FCA on Ancillary Activities Test

On August 28, ISDA and FIA submitted a joint response to the Financial Conduct Authority’s (FCA) consultation paper CP25/19 on the ancillary activities test to determine if commercial users or producers of commodities that trade in commodity derivatives, emission allowances...

Stress Scenarios for CCP IM Simulators

ISDA has published a paper that explains why stress scenarios that central counterparties (CCPs) use for default fund sizing cannot be used for forward-looking initial margin (IM) simulators. Typically, stress scenarios used by CCPs consist of a single step, transitioning...

Paper on EMIR 3 Active Account Representativeness

On September 4, ISDA, the European Fund and Asset Management Association (EFAMA) and FIA shared a paper with EU policymakers requesting clarification on the implementation of the active account requirement under the third European Market Infrastructure Regulation in relation to...