On June 29, ISDA submitted a response to a consultation from the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) on updated guidance and public quantitative disclosures to implement the 2025 margin proposals.
ISDA’s response makes the following points:
- Retain the final report language on margin simulators;
- Require multi-step, day-by-day stress replay to reflect path dependency;
- Enhance standardization of central counterparty outputs and transparency on stress scenarios and add-ons;
- Clarify that simulators are not a substitute for disclosures needed to support replicability; and
- Refine the backward-looking responsiveness measure by reporting responsiveness over pre-defined historical stress periods rather than via a one-year window.
Documents (1) for ISDA Responds to CPMI-IOSCO Consultation on Margin Proposals
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