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
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...