ISDA Response to ESMA on CCP Participation Requirements

On December 24, ISDA responded to a consultation from the European Securities and Markets Authority (ESMA) on central counterparty (CCP) participation requirements. Participation requirements for CCPs are vital for safe and efficient clearing markets, and ISDA broadly supports ESMA’s consultation and proposed regulatory technical standards, which promote fair access and clear membership criteria. While some requirements may scale with clearing member size, core standards on risk management and operational resilience should remain robust. ISDA welcomes the inclusion of sponsored models with clear responsibilities and contingency measures, as well as proposals addressing mutualization risks. However, implementation must be phased to avoid operational disruption, premature position unwinds or market instability as abrupt changes could lead to member exits and concentration risks.

Documents (1) for ISDA Response to ESMA on CCP Participation Requirements

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...

Response to SEC on FICC Guaranty Fund

On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...