Letter to BCBS on Revisiting SA-CCR

On April 21, 2022, ISDA, the Institute of International Finance, and the Global Financial Markets Association submitted a joint letter requesting the Basel Committee reopen the 2014 standardized approach for measuring counterparty credit risk (SA-CCR).

While the SA-CCR standard is a more risk sensitive approach for calculating exposure at default for counterparty credit risk compared to the Current Exposure Method, it is becoming evident as firms implement SA-CCR that the framework as written needs to be revisited given the timing of the finalized rule as it does not adequately reflect structural changes in the derivatives market and the overall regulatory framework since the standard was finalised. In light of market developments that have occurred in recent years the industry believes a holistic and consistent review of SA-CCR across all jurisdictions is justified in order to minimize the risk of market fragmentation and to recalibrate SA-CCR to a sufficiently risk-sensitive level.

Eyeing the Basel III Finish Line

An effective regulatory capital framework relies on multiple ingredients, from appropriate drafting to rigorous testing and consultation. Even minor calibration distortions can inflate capital requirements, which could negatively affect the capacity of banks to support deep and liquid markets, with...

Joint Comment Letter on Basel III Endgame Proposal

The Institute of International Finance (IIF), the International Swaps and Derivatives Association, Inc. (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) today submitted a joint comment letter to the Board of Governors of the Federal Reserve System, the...