ISDA response to HMT highlighting the following issues:

1. What indirect clearing requires – the policy view expressed in the consultation
2. Agency vs principal arrangements at indirect clearer level – the substantive
conclusion
3. Regulatory capital and netting implications
4. Handling of collateral
5. Cross-border arrangements
6. Implementation intentions in other EU member states
7. Powers of direction over clearing members
8. Cross border non-EEA structures
9. Achievability of individual segregation indirect clearing arrangements