Response to HM Treasury Consultation on the Implementation of Basel III Standards

On April 1, 2021, ISDA and the Association for Financial Markets in Europe submitted a joint response to HM Treasury (HMT) on its consultation on implementing the Basel III standards.

The UK Financial Services Bill allows HMT to revoke provisions from the Capital Requirements Regulation (CRR) so the Prudential Regulatory Authority (PRA) can introduce updated prudential rules for credit institutions and PRA-designated investment firms equivalent to the EU’s CRR2.

Chapter two of the consultation paper is a statement of how HMT intends to exercise its revocation power, and chapter three seeks respondents’ views on HMT’s approach to applying the standardized approach (SA) reporting requirements under the Fundamental Review of the Trading Book (FRTB).

The industry appreciates the objective of this consultation for FRTB SA reporting is to leverage the existing regulations, now entered into force in the EU. However, there are areas that we believe require consideration, particularly on how the UK can align with the Basel Committee on Banking Supervision’s international standards. Furthermore, the industry is concerned with the supervisory authorizations that might be necessary ahead of the start of FRTB SA reporting in the first quarter of 2022.

Documents (1) for Response to HM Treasury Consultation on the Implementation of Basel III Standards

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...