ISDA Response to ESMA on Margin Transparency

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

Paper on Enhancing Liquidity and Risk Management

As ISDA marks its 40th anniversary this year, it is an opportune time to reflect on the challenges and opportunities faced by the global derivatives markets over the past four decades. Rapid growth, continued innovation, regulatory reform, central clearing, margining,...

Trade Bodies Seek Delay on Third-Country CCP Rules

On October 21, ISDA and nine other trade associations – the Alternative Investment Management Association, the European Association of Co-operative Banks, the European Association of Corporate Treasurers, the European Banking Federation, the European Fund and Asset Management Association, the European...

ISDA and Tokenovate Launch CDM Taskforce

ISDA and Tokenovate have today announced the establishment of a new taskforce within the Fintech Open Source Foundation (FINOS) to accelerate operationalization of the Common Domain Model (CDM). The initiative responds to growing market demand for standardized, interoperable post-trade processing...