Response to PRA and FCA on Margin Requirements

On October 18, ISDA, the Investment Association, the Alternative Investment Management Association and the American Council of Life Insurers responded to the Prudential Regulation Authority (PRA) and Financial Conduct Authority (FCA) consultation on margin requirements for non-cleared derivatives. In the response, the associations welcome the proposal to extend the temporary exemption from UK margining requirements under BTS 2016/2251 for single-stock equity and index options from January 4, 2024 until January 4, 2026, allowing the PRA and FCA to gather the evidence necessary to create a permanent regime. The associations believe a permanent exemption of equity options from the margin regulatory technical standards is warranted.

The associations also welcome the proposal to rely on existing supervisory powers and the current supervisory framework for assessing initial margin (IM) models and risk management rather than introduce a formal pre-approval requirement. As the final phase-in period for regulatory IM occurred on September 1, 2022, most market participants that intend to use an IM model like the ISDA Standard Initial Margin Model (ISDA SIMM) are already doing so, and this use is subject to oversight under the supervisory framework. Major market participants have been using the ISDA SIMM to calculate regulatory IM since September 1, 2016, and the introduction of a pre-approval requirement at this stage could prove disruptive, creating uncertainty on the permission of UK entities and their counterparties to continue to exchange IM based on the ISDA SIMM.

Documents (1) for Response to PRA and FCA on Margin Requirements

Marking a Milestone - IQ January 2025

It was a different time and a very different market, but 1985 remains a seminal year in the history of over-the-counter (OTC) derivatives – the year that ISDA was established and the very first industry standard document was published. While...

Response to FCA on SI Regime

On January 10, ISDA and the Global Foreign Exchange Division (GFXD) of the Global Financial Markets Association (GFMA) responded to questions from the UK Financial Conduct Authority (FCA) on the future of the systematic internalizer (SI) regime. In the response,...

Response to CSA on Clearing Obligation

On December 19, ISDA submitted a response to the Canadian Securities Administrators (CSA) consultation on proposed amendments to the clearing obligation in Canada. The CSA invited comments on the proposed amendments and on the specific question set out in Annex B...

Derivatives Regulations and Usage in Japan

Japan’s regulatory landscape has generally been supportive of derivatives use by various segments of the buy side. While there are some guidelines on the purposes for which derivatives can be used by certain entities, which are not unique to Japan,...