On July 8, ISDA, the Alternative Investment Management Association (AIMA), the European Fund and Asset Management Association (EFAMA) and the Securities Industry and Financial Markets Association’s asset management group (SIFMA AMG) have submitted a letter to the European supervisory authorities (ESAs) and the European Commission on initial margin (IM) model approval requirements set out in the European Market Infrastructure Regulation (EMIR 3.0). The letter highlights challenges posed by the three-month period granted to the European Banking Authority and national competent authorities (NCAs) to validate changes to an IM model and describes how the ISDA Standard Initial Margin Model (ISDA SIMM) schedule can be amended to address these issues.
The letter also recommends that phase five and six firms should be able to meet the IM model approval requirement by notifying their NCA that they will be using a pro-forma IM model (such as the ISDA SIMM). NCAs may request further information or block a firm’s use of a model, but these entities should be able to use the pro-forma IM model once they have notified their NCA, assuming no express disapproval.
Documents (1) for Trade Associations Submit Letter on EMIR IM Model Validation
Latest
Four Reforms for Successful US Treasury Clearing
The US Treasury market is the world’s biggest and most systemically important market. It’s the oil that keeps the wheels of the global financial system turning and is the primary means by which the US government raises funding. It’s therefore...
ISDA Response to ESMA on CCP Model Validation
On April 7, ISDA responded to the European Securities and Markets Authority’s (ESMA) consultation on draft regulatory technical standards (RTS) under article 49(5) of the European Market Infrastructure Regulation (EMIR), on the conditions for an application for validation of model...
Scott O'Malia Testimony on US Treasury Clearing
On April 8, ISDA CEO Scott O'Malia testified on the implementation of mandatory US Treasury clearing before the US House of Representatives Committee on Financial Services Task Force on Monetary Policy, Treasury Market Resilience, and Economic Prosperity. “The US Treasury...
Joint Letter on Changes to French General Tax Code
On March 31, ISDA, the Association for Financial Markets in Europe (AFME) and the International Securities Lending Association (ISLA) sent a letter to the French tax authority about changes being made to Articles 119 bis A and 119 bis 2...