On September 8, ISDA responded to a consultation by the European Securities and Markets Authority (ESMA) on a draft regulatory technical standard under the European Market Infrastructure Regulation (EMIR 3.0) on margin transparency requirements. ISDA’s members are supportive of margin transparency but believe transparency can be achieved in a more efficient manner. EMIR 3.0 and the proposed ESMA rules set an architecture under which central counterparties (CCPs) provide model transparency and simulators to clearing service providers, clearing members and clients providing clearing services, and these clearing service providers provide transparency and simulations to clients. ISDA proposes a more direct approach whereby CCPs make model documentation and simulators available directly to clients.
A sample of seven ISDA members that provide clearing services in the EU showed that only 7% of clients on average pay a margin multiplier or any form of additional margin requirements higher than CCP margin requirements. Access to CCP simulators should therefore suffice for most clients. Additionally, clearing service providers could share worked hypothetical examples of how these factors could apply in practice by providing examples of ‘If X occurs, then Y multiplier may be applied’. When a client is charged a client-specific add-on, then clearing service providers can provide further information on the multiplier upon request or provide historical illustrative examples.
Documents (1) for ISDA Response to ESMA on Margin Transparency
Latest
Response to EC on Market Risk Prudential Framework
On January 6, ISDA, the Association for Financial Markets in Europe (AFME) and the Institute of International Finance (IIF) submitted a joint response to the European Commission’s (EC) targeted consultation on the application of the market risk prudential framework. ISDA,...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Response 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...
U.S. Federal Holidays on December 24 and 26, 2025
Pursuant to an Executive Order of the President of the United States, December 24 and December 26 have been designated as federal holidays for U.S. federal government purposes. The designation of such dates as U.S. federal holidays is not expected to affect...
