On September 20, ISDA and FIA jointly responded to the European Securities and Markets Authority’s (ESMA’s) seven consultations on recovery-related topics in the central counterparty (CCP) recovery and resolution regulation.
A topic of particular interest to members was the consultation on the second tranche of skin-in-the-game. For this consultation, ISDA and FIA suggested the calibration be reviewed to add more indicators on financial risk management, along with additional proposed indicators.
ESMA’s consultations papers can be found here:
- Consultation on Draft Guidelines Further Specifying the Circumstances for Temporary Restrictions in the Case of a Significant Non-default Event
- Consultation on Draft Guidelines on the Consistent Application of the Triggers for the Use of Early Intervention Measures
- Consultation on Draft RTS on the Methodology for Calculation and Maintenance of the Additional Amount of Pre-funded Dedicated Own Resources
- Consultation on the Draft Guidelines on CCP Recovery Plan Indicators
- Consultation on Draft RTS on Order of Compensation Art. 20
- Consultation on the Draft Guidelines on CCP Recovery Plan Scenarios (Article 9(12) CCPRRR)
- Consultation on Draft RTS Further Specifying the Factors that Shall be Considered by the Competent Authority and the Supervisory College When Assessing the CCP Recovery Plan
Documents (7) for FIA and ISDA Respond to ESMA’s Consultations on CCP Recovery & Resolution
- FIA-ISDA response Art 20 Recompense(pdf) will open in a new tab or window
- FIA-ISDA response Early Intervention Measures(pdf) will open in a new tab or window
- FIA-ISDA response Recovery Indicators(pdf) will open in a new tab or window
- FIA-ISDA response Recovery Plan Assessment Factors(pdf) will open in a new tab or window
- FIA-ISDA response Recovery Plan Scenarios(pdf) will open in a new tab or window
- FIA-ISDA response Second Tranche SITG(pdf) will open in a new tab or window
- FIA-ISDA response Temporary Restrictions(pdf) will open in a new tab or window
Latest
Trading Book Capital: Scott O'Malia Remarks
Trading Book Capital: Capital Conundrum, Navigating Basel III Endgame February 5, 2026 Welcoming Remarks Scott O’Malia, ISDA Chief Executive Good afternoon, and welcome to ISDA’s Trading Book Capital event – it’s great to be here in New York. We...
ISDA In Review – January 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in January 2026.
ISDA Responds to RBI Unique Transaction Identifier (UTI) Proposals
On November 14, 2025, ISDA submitted comments to a Draft Circular from the Reserve Bank of India (RBI) proposing to mandate the global Unique Transaction Identifier (UTI) for all transactions in OTC markets for Rupee interest rate derivatives, forward contracts in Government...
How and Why Pension Funds Use Derivatives
With over $58 trillion in assets globally, pension fund managers are major participants in financial markets and play a vital role in helping to provide post-retirement incomes for plan employees. Meeting such an important goal requires careful consideration of investment...
