ISDA, AFME Publish Position Papers on CRR III

ISDA and the Association for Financial Markets in Europe (AFME) have published joint position papers on the third Capital Requirements Regulation and the sixth Capital Requirements Directive (CRR III / CRD VI).

The banking proposal was published by the European Commission on October 27 at an important time as policy-makers deal with the fallout from the COVID-19 pandemic and the need to ensure a strong and sustained economic recovery. This makes it even more important that the package is carefully designed and calibrated so that it does not constrain banks’ ability to support the economy.

CRR III also needs to be considered in the context of the EU’s urgent priorities to complete the Banking Union, reduce fragmentation of financial markets and develop and deepen Europe’s capital markets through the establishment of an effective Capital Markets Union.

In this publication, ISDA and AFME present recommendations to ensure CRR III is faithful to the overarching objectives of Basel III but also reflects these priorities.

ISDA Omnibus Canadian Representation Letter

On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...

Joint Response on Cross-margining

On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...

Response to SEC on FICC Guaranty Fund

On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...