ISDA, EFAMA, AFME Respond to EC on Reducing Administrative Burden in Environmental Legislation

On September 10, ISDA, the Association for Financial Markets in Europe (AFME) and the European Fund and Asset Management Association (EFAMA) submitted a joint response to the European Commission’s (EC) call for evidence on reducing the administrative burden in environmental legislation. The joint response supports the EC’s objective of reducing unnecessary administrative burdens while ensuring environmental objectives remain intact. The associations believe that simplification efforts focused on the real economy are essential to improving the quality of information, avoiding overlapping rules and enabling effective sustainable finance.

In particular, the joint response highlights the need to:

  • Ensure regulatory coherence with the existing sustainable finance framework (Sustainable Finance Disclosure Regulation, Taxonomy, Corporate Sustainability Reporting Directive and sectoral rules), avoiding duplication and double reporting.
  • Maintain an exemption of financial products and services from the scope of the Green Claims Directive.
  • Clarify that Deforestation Regulation due diligence obligations should apply to lead operators and traders rather than downstream financial institutions, which are already comprehensively regulated under EU sustainable finance rules.

Documents (1) for ISDA, EFAMA, AFME Respond to EC on Reducing Administrative Burden in Environmental Legislation

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...