ISDA has submitted to the European Securities and Markets Authority (ESMA) an analysis of the costs of regulatory reporting, which proposes where savings can be made most effectively.
This document supplements the recent response submitted by ISDA, the Association for Financial Markets in Europe, FIA and the Global FX Division of the Global Financial Markets Association to ESMA’s call for evidence on a comprehensive approach for the simplification of financial transaction reporting. The new analysis and proposals reflected in this supplementary document were developed based on member feedback to a questionnaire carried out by ISDA. All answers have been anonymized and aggregated.
The responses supported many of the arguments put forward in the original response, with the most impactful cost saving identified as the delineation by instrument (OTC derivatives under the European Market Infrastructure Regulation and exchange-traded derivatives under the Markets in Financial Instruments Regulation) as proposed under Option 1a. There was also strong support for single-sided reporting and the removal of pairing and matching requirements.
ISDA developed this analysis for ESMA’s consideration in drafting the final report following the call for evidence.
Documents (3) for ISDA Submits Supplementary Analysis to ESMA on Reporting Costs
- ESMA CASR ISDA cost questionnaire analysis Final 100825(pdf) will open in a new tab or window
- ESMA CASR ISDA Appendix 2 cost questionnaire aggregated answers(xlsx) will open in a new tab or window
- ESMA CASR ISDA Appendix 1 Questionnaire on the cost of compliance with EU reporting requirements(pdf) will open in a new tab or window
Latest
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...