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 for derivatives. The paper argues that the proposed assessment of five-year single-name credit default swaps (CDS) that reference global systemically important banks (G-SIBs) as liquid, proposed in CP4 for the purposes of public transparency, is fundamentally flawed. It highlights that the methodology used to assess the liquidity of five-year single-name CDS referencing G-SIBs is markedly different from the methodology used to assess other derivatives and bonds and presents analysis that shows these instruments would be deemed illiquid if they had been assessed in a way that was consistent with other instruments. This is important, as it dictates whether trades in these instruments should be made public in real time or deferred. ISDA has consistently advocated that making trades in illiquid instruments transparent in real time places undue risk on liquidity providers.
Documents (1) for ISDA Paper on Proposed Liquidity Assessment for Single-name CDS
Latest
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...
ISDA Omnibus Canadian Representation Letter
On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...
Joint Response on Cross-margining
On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...
