ISDA wrote to Edwin Schooling Latter, Bank of England and David Lawton, UK Financial Conduct Authority summarising the views of the ISDA Risk and Margin Regulatory Implementation Committee on two issues:

I. The lack of certainty around the meaning of “individual client segregation” under Article 39(3) of the European Market Infrastructure Regulation (“EMIR”). ISDA’s letter was sent in conjunction with an industry-wide effort, led by the Futures and Options Association (“FOA”) and supported by ISDA, to engage with the European Securities and Markets Authority (“ESMA”) on this issue; and

II. CCP default fund (“DF”) sizing.