ISDA letter to the ESAs on Estimates of numbers of accounts affected by IM segregation requirements, to demonstrate operational challenges

The margin rules proposed by the European Supervisory Authorities (the “ESAs”) require IM to be
segregated from proprietary assets on the books and records of a third party holder or custodian,
or via other legally effective arrangements. In addition, the rules require cash IM to be segregated individually, unless other legally effective arrangements are in place to segregate it from proprietary assets. Several additional clarifications and issues are described in the letter sent by ISDA to the ESAs in July 20143. As proposed, we illustrate below the unintended consequences arising from the IM segregation
requirements.

Documents (1) for ISDA letter to the ESAs on Estimates of numbers of accounts affected by IM segregation requirements, to demonstrate operational challenges

ISDA Request to Extend 22-18 Relief

ISDA’s request to extend the relief under CFTC No-Action Letter No. 22-18 until further CFTC action resolves the overlapping and contradictory reporting obligations in respect of the P45 obligations for Exempt DCO/No-Action DCO swaps and related Alphas accepted for clearing...

Industry Report under Project Guardian

ISDA and Ant International led the Project Guardian FX industry group to develop a new report for implementing tokenised bank liabilities and shared ledger in cross-border payments and foreign exchange (FX) settlement. The joint report is produced under the Monetary...

Joint Paper on UK EMIR Reform

On July 1, ISDA and UK Finance published a paper, which recommended a set of reforms for the UK European Market Infrastructure Regulation (UK EMIR), carefully considering each EU EMIR 3.0 reform and asking whether we would wish to adopt...