Europe


DateTitle / DescriptionDocuments
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.
ISDA BBA response to ESMA DP on Clearing Obligation 12 Septem.pdf
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.
EFET_FOA_GFMA _ISDA_MIFID_scope_financial_instruments.pdf
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.
Methodology for Regulatory Comparisons 20130820.pdf
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.)
Common Principles - Examples 20130820.pdf
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
20130719_MiFID_position_limits.pdf
July 11, 2013
ISDA/AFME joint response to the European Commission's consultation on Reforming the structure of the EU banking sector
ISDA/AFME joint response to the European Commission's consultation on Reforming the structure of the EU banking sector
http___assets.isda.org_media_d268a4bb_61a4360c.pdf
June 25, 2013
ISDA response to EC Green Paper on Long-Term Financing of the European Economy
On June 25, ISDA responded to the European Commission’s Green Paper on long-term financing of the European economy.
20130625_long_term_financing_ISDA.pdf
June 13, 2013
ISDA response to the ECON Committee questionnaire for the public consultation on enhancing the coherence of EU financial services legislation.
On June 13, ISDA responded to the ECON consultation on coherence, with the goal of contributing to a more robust and stable financial marketplace. In this response, ISDA limit ourselves to commenting on ‘Question Two’ and 'Question Four' (issues directly relevant to 'Liquidity' and OTC Derivatives Markets).
ISDA RESPONSE.COHERENCE CONSULTATION.pdf
June 13, 2013
The Joint Associations Committee (JAC) response to the IOSCO consultation on retail structured products
ISDA, UKSPA, AFME, BBA, ICMA & IIF joint response to the IOSCO consultation on retail structured products.
20130613_IOSCO_consultation_Retail_Structured_Product_JAC_response.pdf
May 17, 2013
ISDA responds to IOSCO consultation on benchmarks
On May 17, ISDA submitted its response to the second IOSCO consultation on Principles for Financial Benchmarks.
ISDA Response to IOSCO.pdf