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ISDA Master Regulatory Disclosure Letter and Accompanying Guidance Note

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The ISDA Master Regulatory Disclosure Letter (MRDL) is a form of letter that is intended to allow market participants to exchange information regarding counterparty status as required under relevant regulatory regimes.

The MRDL currently provides for the exchange of counterparty status information in relation to:

  1. EMIR through Appendix A (European Union); and
  2. UK EMIR through Appendix B (United Kingdom).

It is anticipated that the MRDL will be updated or supplemented over time through the addition of new appendices to accommodate, for example, increased granularity of data or extension of asset class or geography.

The MRDL was updated on:

  • 17th December 2020 to, inter alia, add Appendix B (United Kingdom) relating to the regulatory obligations of market participants in respect of EMIR (and applicable delegated legislation) as retained in UK domestic law pursuant to the European Union (Withdrawal) Act 2018 (UK EMIR).
  • 22nd March 2023 to allows users to provide additional information in the context of the publication of Commission Delegated Regulation (EU) 2022/1855 dated 10 June 2022 and Commission Implementing Regulation (EU) 2022/1860 dated 10 June 2022, each of which introduce new EMIR reporting fields and which take effect from 29 April 2024
  • 5th December 2024 to add an entity responsible for reporting (ERR) field and implement certain other changes pursuant to updates to EMIR, for example relating to the pension scheme exemption and margining phase-in date.

 

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