On March 26, ISDA and the Association for Financial Markets in Europe submitted a joint response to the European Banking Authority’s (EBA) consultation on implementing technical standards for the 2025 internal models benchmarking exercise. The industry is cognizant of significantly reduced participation in internal models approach benchmarking after implementation of the Fundamental Review of the Trading Book, based on expectations for model applications. The number of firms taking part overall, as well as the number of firms submitting data for specific portfolios, could be lower than the number required to support a meaningful benchmarking exercise. In the response, several issues are identified with the specification of instruments, and it is recommended these specifications are amended to provide greater clarity in the booking of these instruments.
Documents (1) for ISDA Response to EBA on Internal Models Benchmarking
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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...
Response on CSDD Guidelines
On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...
Response to BoE on Extension of Settlement Hours
On August 6, ISDA responded to the Bank of England’s (BoE) consultation paper on the extension of settlement hours for RTGS and CHAPS, the UK’s high-value payment system. ISDA supports the BoE’s plan to extend RTGS and CHAPS settlement hours...