ISDA Responds to EBA on Standardized Approach for Counterparty Credit Risk

On March 14, ISDA and the Association for Financial Markets in Europe (AFME) submitted a joint response to the European Banking Authority’s (EBA) consultation on draft regulatory technical standards (RTS) relating to specific elements of the standardized approach for counterparty credit risk (SA-CCR).

In the response, the associations highlight their concerns about the fragmentation of regulatory requirements relating to SA-CCR across jurisdictions and believe it is crucial to perform a holistic review of the SA-CCR framework at the international level to improve SA-CCR risk sensitivity and minimize the risk of market fragmentation.

The draft RTS provides options to calculate the supervisory delta of commodities. However, there are instances where negative values of the instrument or risk factors underlying an option contract can occur in other asset classes as well. The associations recommend an extension to the application of the λ shift to all asset classes. Furthermore, the associations propose the use of actual front office (FO) deltas or deltas derived from FO prices, such as in the Fundamental Review of the Trading Book. They also highlight that US agencies have proposed an extension of the λ shift to all asset classes, not only commodities. The associations recommend the EBA aligns with the US agencies and extends the scope to all asset classes.

Documents (1) for ISDA Responds to EBA on Standardized Approach for Counterparty Credit Risk

Eyeing the Basel III Finish Line

An effective regulatory capital framework relies on multiple ingredients, from appropriate drafting to rigorous testing and consultation. Even minor calibration distortions can inflate capital requirements, which could negatively affect the capacity of banks to support deep and liquid markets, with...

Joint Comment Letter on Basel III Endgame Proposal

The Institute of International Finance (IIF), the International Swaps and Derivatives Association, Inc. (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) today submitted a joint comment letter to the Board of Governors of the Federal Reserve System, the...