|Date||Title / Description||Documents|
October 18, 2013
JAC Response to the Joint Forum Consultative Document: Point of Sale disclosure in the insurance, banking and securities sector.
On October 18, the Joint Associations Committee on Retail Structured Products (JAC) responded to the Joint Forum Consultative Document: Point of Sale disclosure in the insurance, banking and securities sector.
The consultation considers whether the current different regulatory approaches to Point of Sale disclosure need to be further aligned, so that consumers across all three financial sectors receive adequate product disclosure at the point of sale.
October 10, 2013
JAC response to the CBI Consultation CP68 on types of alternative investment funds under AIFMD
On October 10, the Joint Associations Committee on Retail Structured Products responded to the Central Bank of Ireland's Consultation (CP68) on types of alternative investment funds under AIFMD and unit trust schemes under the Unit Trusts Act 1990 (including EUTs, REITs etc.)
October 9, 2013
ISDA/JAC response to HMT & BIS consultation on Banking Reform: draft secondary legislation
On October 9, ISDA submitted two responses to the consultation issued by HM Treasury & Department for Business Innovation and Skills on Banking reform: draft secondary legislation (issued in July).
The first response was on behalf of the Joint Associations Committee (JAC) on Retail Structured Products in relation to structured issues.
The second response considers proposals for ring-fenced banks to be permitted to sell simple derivatives products only to their customers.
September 20, 2013
ISDA/AFME joint response to the EC on the Regulation on short selling and certain aspects of credit default swaps (the Regulation)
On September 20, ISDA & AFME submitted a joint letter to the European Commission on the current review of the Regulation on short selling and certain aspects of credit default swaps (the Regulation).
September 16, 2013
ISDA-BBA response to the ESMA CP “Draft Regulatory Technical Standards on contracts having a direct, substantial and foreseeable effect within the Union and non-evasion of provisions of EMIR”
On September 16, ISDA and BBA submitted their response to the ESMA consultation paper entitled “Draft Regulatory Technical Standards on contracts having a direct, substantial and foreseeable effect within the Union and non-evasion of provisions of EMIR”
September 12, 2013
Final ISDA/BBA response to the ESMA DP on the Clearing Obligation
On September 12, ISDA and the BBA responded to the ESMA Discussion Paper on the Clearing Obligation under EMIR published on July 12, 2013 related to the preparation of the regulatory technical standards.
August 21, 2013
ISDA, EFET, FOA & GFMA joint response to the European Commission regarding the definition of financialinstruments under MiFID II
ISDA – EFET – FOA – GFMA joint response to the European Commission, European Parliament, Lithuanian Presidency regarding the definition of financial instruments under MiFID II, in particular the wording in Annexe 1, Section C6 of the Council’s
compromise text adopted by ECOFIN on June 21 2013.
August 20, 2013
Methodology for Regulatory Comparisons (Substituted Compliance)
This paper sets forth ISDA’s views regarding a conceptual framework and substantive processes for inter-jurisdictional recognition of derivatives regulation through a principles-based substituted compliance methodology. Our framework prioritizes achievement of the G-20 goals for OTC derivatives.
August 20, 2013
Common Principles - Examples (Substituted Compliance)
In our “Methodology for Regulatory Comparisons” document, ISDA proposed concepts to guide the comparisons of derivatives regulations that will be carried out by regulators assessing the possibility of substituted compliance. Our methodology relies on regulators, with input from the markets, developing common principles that will apply in various subject matter areas within derivatives regulation. These principles should be cast to support comparability of regulation without requiring identical regulation. To illustrate our proposed methodology, we offer the following examples of common principles. These examples have been developed and organized in relation to several of the original G-20 derivatives goals. (To be clear, these are merely examples and do not purport to illustrate comprehensive treatment of their subject matter areas.)
July 19, 2013
ISDA, EFET & FOA commentary on MiFID – Article 59 – Definition of appropriate position limits - ESMA level 2 work
ISDA – EFET – FOA commentary on MiFID – Article 59 – Definition of appropriate position limits - ESMA level 2 work