ISDA letter to the ESAs on Estimates of numbers of accounts affected by IM segregation requirements, to demonstrate operational challenges

The margin rules proposed by the European Supervisory Authorities (the “ESAs”) require IM to be
segregated from proprietary assets on the books and records of a third party holder or custodian,
or via other legally effective arrangements. In addition, the rules require cash IM to be segregated individually, unless other legally effective arrangements are in place to segregate it from proprietary assets. Several additional clarifications and issues are described in the letter sent by ISDA to the ESAs in July 20143. As proposed, we illustrate below the unintended consequences arising from the IM segregation
requirements.

Documents (1) for ISDA letter to the ESAs on Estimates of numbers of accounts affected by IM segregation requirements, to demonstrate operational challenges

Safe, Efficient Markets for SFTs

Securities financing transactions (SFTs) – including repurchase agreements (repo), securities lending, buy/sell backs and margin lending – are foundational to the functioning of modern financial markets. They support the day-to-day distribution of liquidity, enable collateral to move efficiently across cash...

ISDA Recommendations to Simplify EU Regulation

On March 9, ISDA submitted a paper to the European Commission setting out focused proposals to improve the functioning of the EU regulatory framework for derivatives. The paper comprises eight targeted recommendations to simplify selected Level 1 provisions in a...