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 changes and parameters under Articles 49 and 49a of EMIR, which have been revised as part of EMIR 3.
In the consultation paper, ESMA sets out proposed quantitative thresholds and qualitative elements to be considered when determining whether a model change is significant. In the response, ISDA noted that more information would be necessary to understand the rationale behind the thresholds that are proposed. ISDA provided comments on ESMA’s interpretation of ‘concentration risk’ and on the proposed lookback period for assessing whether a change in significant.
Documents (1) for ISDA Response to ESMA on CCP Model Validation
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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...
Cross-product Netting Under US Capital Rules
ISDA, FIA and the Securities Industry and Financial Markets Association (SIFMA) have developed a discussion paper to: (i) provide an overview of cross-margining programs developed by clearing organizations and their importance in the context of implementing recent market reforms with...