ISDA, along with a number of other trade associations, sent two letters to European Commission (EC) executive vice president Valdis Dombrovskis, European Securities and Markets Authority (ESMA) chairman Steven Maijoor, European Banking Authority (EBA) chairperson José Manuel Campa and European Insurance and Occupational Pensions Authority (EIOPA) chairman Gabriel Bernardino to request that existing time-related exemptions under the European Market Infrastructure Regulation (EMIR) be extended.

The first letter urges the EC and European supervisory authorities (ESA) to consider amending the margin regulatory technical standards (RTS) to permanently exempt single-stock equity option or index option transactions, or to significantly extend the period of deferred application to allow further observation of developments in other jurisdictions and to avoid an unlevel playing field for EU market participants.

The second letter emphasizes the importance of intragroup transactions and requests the following: that the necessary equivalence decisions be adopted in all jurisdictions that have implemented margin rules in line with the Basel Committee on Banking Supervision/International Organization of Securities Commissions framework; and the draft revised margin RTS should be amended by the EC and ESAs so the current temporary derogation from margin requirements for intragroup transactions with non-EU affiliates in other jurisdictions be extended for a further three years.