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
Latest
S&P Global Selected as DC Administrator
ISDA and the Credit Derivatives Governance Committee have announced that S&P Global Market Intelligence has been selected as the administrator for the Credit Derivatives Determinations Committees (DCs). The announcement follows an invitation to tender in November 2025. The DC administrator...
Supporting ISDA SIMM Adoption in Australia
Derivatives have become a critical tool for Australia’s massive superannuation sector, as funds look to manage the risks associated with their expanding offshore investments. The use of derivatives brings real risk management benefits, but it also means funds need to...
ISDA, GDF Respond to the Central Bank of Ireland on DLT and Tokenization
On June 3, ISDA and Global Digital Finance responded to the Central Bank of Ireland’s discussion paper on distributed ledger technology (DLT) and tokenization in financial services. The response focuses on the potential role of DLT and tokenization within wholesale...
Response to Consultation on Dividend Stripping
On May 28, ISDA and the Association for Financial Markets in Europe (AFME) responded to the Dutch Ministry of Finance’s consultation on additional anti-dividend stripping measures, urging that the proposed rules should target only abusive arrangements and not ordinary, commercially...