On June 11, ISDA and AFME submitted an industry response to the EBA on the Consultation Paper on Draft Regulatory Technical Standards (‘RTS’) which was published in March of this year on the conditions for assessing the materiality of extensions and changes of internal approaches when calculating own funds requirements for credit, market and operational risk.
Attached:
Industry comments (marked up) of the EBA Consultation Paper (March 2013)
Cover letter to the EBA
Industry response paper
Documents (3) for ISDA/AFME response to the Consultation Paper on Draft Regulatory Technical Standards (‘RTS’) to the European Banking Authority (EBA)
Latest
ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...