In November 2021, the European Securities and Markets Authority (ESMA) published a consultation on its report on highly liquid financial instruments with regards to the investment policy of central counterparties. In this consultation, ESMA reviews whether the current, fairly restrictive list of investment options for central counterparties (CCPs) should be extended. The report contains a very thorough analysis of regulation and CCP practices in other jurisdictions and proposes some extension of the range of investments available to a CCP, for instance debt issued by the EU but also consults about including corporate debt. On money market funds, ESMA is more careful and proposes for now not to allow these funds.
ISDA members are very supportive of some of the extension of investments available to the CCP and propose to be less prescriptive but to give the CCP and its governance forums including supervisors more leeway. In the response, we also support the inclusion of public debt constant net asset value money market funds, which had significant inflows during the crisis in 2020.
Please find below the ISDA response.
Documents (1) for ISDA Responds to ESMA on Eligible CCP Investments
Latest
US FX Derivatives Review
ISDA has expanded its SwapsInfo website to include data on US foreign exchange (FX) derivatives, extending the platform's coverage beyond interest rate and credit derivatives to a third over-the-counter derivatives asset class. The US FX Derivatives Review covers trading activity...
Response to FCA on Post-trade Transparency
On October 16, ISDA responded to the Financial Conduct Authority’s (FCA) consultation CP26/30. While the consultation is principally focused on cash equity market structure and transparency, ISDA responded to questions on the potential inclusion of equity swaps in the scope...
Efficiency is Vital to Delivering Resilience
With less than three months to go until implementation of US Treasury clearing begins at the end of this year, it’s critical that the mandate is safely implemented without compromising market efficiency. This represents a huge change in market structure,...
ISDA In Review – September 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in September 2026.