On July 1, ISDA responded to the Reserve Bank of India’s (RBI) consultation on draft amendment directions on the standardized approach for counterparty credit risk (SA-CCR).
ISDA broadly welcomes the RBI’s move to SA-CCR and updated capital treatment for exposures to central counterparties (CCPs), noting the draft directions closely track standards from the Basel Committee on Banking Supervision (BCBS). The response raises five areas for clarification or alignment: (i) the requirement for prior RBI approval of non-zero λj values, which ISDA suggests replacing with a supervisory guidance approach consistent with BCBS frequently asked questions and Hong Kong Monetary Authority practice; (ii) whether the 1.4 alpha factor, designed for internal model method risks, is appropriate under a standardized approach; (iii) support for the draft’s explicit treatment of multi-level client structures; (iv) a requirement for an independent legal opinion to apply a 0% risk weight on qualifying CCP trade exposures, which goes beyond the BCBS standard and could instead be satisfied through internal documented analysis; and (v) the criterion requiring a porting precedent to assess portability as “highly likely”, which should not penalize CCPs that never had a clearing member default.
ISDA also highlights its ongoing global advocacy for SA-CCR to recognize cross-product netting between derivatives and securities financing transactions, referencing the recent response to the US Basel III re-proposal.
Documents (1) for ISDA Responds to RBI Consultation on SA-CCR
Latest
ISDA Letter to BCBS on RMA Models
On July 24, ISDA wrote to the Basel Committee on Banking Supervision (BCBS) to request guidance on how the proposed Risk Mitigation Accounting (RMA) model under International Financial Reporting Standard (IFRS) 9/IFRS 7 should be treated for prudential regulatory capital...
US Treasury Repo Clearing Indicators June 2026
The ISDA-Actrix US Treasury Repo Market Clearing Indicators illustrate central clearing adoption in the US Treasury repo market. Sponsored cleared repo volumes are used as a proxy to monitor client participation in central clearing, a key objective of the Securities...
Australia: ISDA responds to ASIC consultation on pre-hedging guidance
On July 27, ISDA submitted a response to the Australian Securities and Investments Commission's (ASIC) consultation on its proposed regulatory guide on pre-hedging. ISDA's response emphasises the importance of international consistency, including alignment with the International Organization of Securities Commissions'...
An Important Step Towards Efficient Reporting
Of all the problems that have hindered effective trade reporting in the derivatives market, one of the most difficult to resolve has been duplication. In the EU, both parties to a trade are mandated to submit the same information, while...
