ISDA letter to the ESAs on Proposed Margin Rules: Documentation Requirements

ISDA is concerned about the documentation that is required for parties to qualify for exemptions from the margin requirements under the Draft RTS on risk-mitigation techniques. This documentation is not required by Regulation (EU) No 648/2012 (“EMIR”) and imposing such requirements would result in very significant administrative and operational burdens. In the letter, we set out proposed alternative language that could be used to permit exemptions without documentation requirements. This letter is a supplement to the letter we sent to the ESAs on 14 July commenting generally on the Draft RTS.

Documents (1) for ISDA letter to the ESAs on Proposed Margin Rules: Documentation Requirements

A Positive Step to Improve the FRTB in the EU

As the Basel III capital reforms are finalized for implementation in key jurisdictions, ISDA is maintaining a laser focus on making sure the rules are robust and risk-appropriate. Simply put, if capital requirements are set disproportionately high, this will have...