On October 7, 2019, ISDA’s responded to the Financial Accounting Standards Board’s (FASB) exposure draft file reference number 2019-770 on reference rate reform (Topic 848). ISDA members support the FASB’s proposals in the exposure draft to provide optional expedients and exceptions to applying US GAAP to derivatives and hedging relationships and other transactions and contracts that will be affected by reference rate reform. ISDA is in favor of the exposure draft’s targeted improvements, but, at the same time, is requesting additional clarification to avoid unintended consequences.
Documents (1) for ISDA Response to FASB’s Exposure Draft on Reference Rate Reform
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Raising Clients’ Awareness on Portability
Clients accessing a central counterparty (CCP) via a client clearing service provider (CCSP) for over-the-counter (OTC) and exchange-traded derivatives should consider what may happen to their positions and collateral in a scenario in which the CCSP defaults. While regulatory regimes...
Response to FCA on Ancillary Activities Test
On August 28, ISDA and FIA submitted a joint response to the Financial Conduct Authority’s (FCA) consultation paper CP25/19 on the ancillary activities test to determine if commercial users or producers of commodities that trade in commodity derivatives, emission allowances...
Stress Scenarios for CCP IM Simulators
ISDA has published a paper that explains why stress scenarios that central counterparties (CCPs) use for default fund sizing cannot be used for forward-looking initial margin (IM) simulators. Typically, stress scenarios used by CCPs consist of a single step, transitioning...
Paper on EMIR 3 Active Account Representativeness
On September 4, ISDA, the European Fund and Asset Management Association (EFAMA) and FIA shared a paper with EU policymakers requesting clarification on the implementation of the active account requirement under the third European Market Infrastructure Regulation in relation to...