On July 17, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission’s (SEC) proposed rulemaking regarding clearing agency resilience and recovery and wind-down plans.
The associations generally support the proposed changes aimed at enhancing the regulatory framework for recovery and wind-down plans and intraday margin processes of clearing agencies. They suggest that more prescriptive guidance is necessary for intraday margin and recovery and wind-down plans to provide clear expectations for clearing members and their clients. They emphasize the importance of predictability of margin calls and advocate for increased transparency of initial margin models. Additionally, they stress the need for credible recovery plans to ensure financial stability, and they call for clear rules on non-default losses and compensation for clearing participants.
The response also addresses the need for a second tranche of clearing agency own-funds capital and emphasizes the importance of including procedures for participants to move positions during orderly wind-down in the proposed rules.
Documents (1) for ISDA-FIA Response to Proposed SEC Rules on Clearing Agency Intraday Margin and Recovery/Wind-down Plans
Latest
Response on Commodity Derivatives Markets
On April 22, ISDA and FIA submitted a joint response to the European Commission’s (EC) consultation on the functioning of commodity derivatives markets and certain aspects relating to spot energy markets. In addition to questions on position management, reporting and...
Episode 50: The Value of Derivatives
A new report from ISDA shows that companies all over the world use derivatives to alleviate uncertainty, transfer risk and enhance profitability. ISDA discusses the findings with Boston Consulting Group’s Roy Choudhury. Please view this page via Chrome to access...
ISDA/IIF Response to EC Market Risk Consultation
On February 22, ISDA and the Institute of International Finance (IIF) submitted a joint response to the European Commission’s (EC) consultation on the application of the market risk prudential framework. The associations believe the capital framework should be risk-appropriate and...
ISDA Submits Letter on Environmental Credits
On April 15, ISDA submitted a response to the Financial Accounting Standards Board’s (FASB) consultation on environmental credits and environmental credit obligations. The response supports the FASB’s overall proposals to establish clear and consistent accounting guidance for environmental credits, but...