The International Swaps and Derivatives Association, Inc.1 (“ISDA”) is pleased to have the opportunity to comment on the European Market Infrastructure Regulation (“EMIR”), the proposed EU Commission regulation on OTC derivatives, central counterparties and trade repositories. ISDA is writing this letter to explain and emphasise the importance of EMIR having sufficient flexibility so as to accommodate indirect clearing and provide scope for guidance and practice from the European Securities and Market Authority (“ESMA”) in due course.
Documents (1) for ISDA-AFME commentary on indirect clearing under the EMIR – 29 July 2011
Latest
ISDA Omnibus Canadian Representation Letter
On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...
Joint Response on Cross-margining
On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...
Response to SEC on FICC Guaranty Fund
On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...