On October 29, ISDA responded to the Securities Exchange Commission’s (SEC) notice of proposed rulemaking (NPR).
With the central role governance plays in a clearing agency’s risk management, we believe this NPR is very timely and will improve governance and risk management of these entities. We, however, believe that this NPR is only the beginning and would welcome further improvements in CCP governance.
We are generally very supportive of this NPR. Risk Management Committees (RMCs), Risk Working Groups and the obligation to formally consider stakeholders viewpoints will facilitate effective oversight by the Commission. RMCs are good practice in many central counterparties (CCPs) and are already required by regulation in many other jurisdictions. We, therefore, welcome codification of such governance bodies as proposed by this NPR.
We are also very supportive of the SEC’s thoughts about CCP’s board obligation to oversee service providers for critical services.
ISDA notes that the proposals in the NPR should be considered as a starting point in enhancing the regulatory framework for CCPs. There are several other important issues related to clearing agencies in which further regulatory action is warranted, including emergency powers, margin adequacy, transparency and CCP capital.
Documents (1) for ISDA Responds to SEC on CCP Governance
Latest
A Financial Markets Revolution
Every financial center has its own unique features, but it was particularly fitting that ISDA’s recent Annual General Meeting (AGM) was held in Boston – not only a global hub for asset management and insurance, but also a city that...
ISDA AGM Studio: Nnamdi Okaeme & John Pucciarelli
Marking the 10‑year anniversary of the ISDA Standard Initial Margin Model (ISDA SIMM), Joel Clark, senior director, communications, at ISDA, speaks with Nnamdi Okaeme, ISDA’s head of SIMM, and John Pucciarelli, head of partnerships and director of industry engagement at...
Response on Legal Frameworks for Carbon Credits
On May 4, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Commission’s (EC) consultation on a legal framework for the inclusion of international carbon credits within the EU’s 2040 climate law framework. In the...
ISDA AGM Studio: Julia Hueckel and Chris Zuehlke
Julia Hueckel, director of global regulatory policy at Coinbase, and Chris Zuehlke, global head of Cumberland and partner at DRW, speak with Nicolette Cone, ISDA’s chief of staff and associate general counsel, on the rapidly evolving legislative framework for digital...
