On March 27, ISDA sent a letter to the European Commission (EC) and the European Securities and Markets Authority (ESMA) to highlight several technical issues arising from the interaction between the delegated regulation (EU) 2025/1003 on identifying reference data to be used for over-the-counter (OTC) derivatives for the purposes of public transparency and the draft regulatory technical standards for derivatives transparency (RTS 2) and from areas of the draft RTS 2 that lack clarity.
ISDA welcomes both the delegated regulation and the revised transparency framework proposed under the draft RTS 2 as necessary and proportionate and considers they will together provide an enhanced level of public transparency for OTC derivatives. However, mismatched dates of application of the delegated regulation and the draft RTS 2 create some legal uncertainty and regulatory risk for market participants. In addition, there are several areas of limited or unclear information in the draft RTS 2 and inconsistency between it and the delegated regulation, which will cause implementation issues if not addressed. ISDA’s letter to the EC and ESMA analyses each of these issues and provides proposed solutions.
Documents (1) for ISDA Letter to EC and ESMA on Technical Issues with Revised Derivatives Transparency Framework
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Letter to EC and ESMA on Derivatives Framework
On March 27, ISDA sent a letter to the European Commission (EC) and the European Securities and Markets Authority (ESMA) to highlight several technical issues arising from the interaction between the delegated regulation (EU) 2025/1003 on identifying reference data to...
Response on Proposed Changes to Transaction Rules
On May 22, ISDA and the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association submitted a joint response to the Australian Securities and Investments Commission's (ASIC) consultation on proposed changes to the ASIC Derivative Transaction Rules (Reporting)...
EBA FRTB-ASA Benchmarking Support for Newly In-scope Banks
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Joint Letter on Sunset of Swaps TR Rules
On May 20, ISDA, FIA and the Securities Industry and Financial Markets Association (SIFMA) submitted a joint letter to US Commodity Futures Trading Commission (CFTC) to request the CFTC to sunset large trader reporting rules (LTR) rules for physical commodity...