DateTitle / DescriptionDocuments
July 2, 2014
ISDA comment paper on EU bank structural reform proposal
ISDA has submitted a comment paper to EU decision-makers on the EC proposal for a Regulation on Bank Structure. ISDA largely limits its comments to proposed provisions most relevant to OTC derivatives.
Final  Version  ISDA comments EC Bank Structure proposal 020714.pdf
June 30, 2014
Benchmarks: ISDA comments on the agenda for Council Working Group meeting
Benchmarks ISDA comments on the agenda of the 24 July Council Working Group meeting (Italian Presidency)_30.06.14.pdf
June 13, 2014
Benchmarks: ISDA comments on the Greek Presidency note on benchmarks - June 2014
ISDA comments on the Greek Presidency note on benchmarks, dated 6 June 2014_13.06.14.pdf
May 30, 2014
ISDA/AFME response to ESMA consultation on draft RTS on the revised Transparency Directive
On May 30, ISDA and AFME responded to the ESMA consultation paper Draft Regulatory Technical Standards on major shareholdings and indicative list of financial instruments subject to notification requirements under the revised Transparency Directive. The response highlights positive developments including the aggregation principle, which allows the inclusion of a break down by type of financial instrument (i.e. distinction between cash-settled and physically-settled derivatives) in notifications. The exemptions from notifications for market-making activities (under Article 9.5) and trading books (under Article 9.6) are also positive developments.
May 29, 2014
IOSCO Task Force on Cross-Border Regulation invitation for industry submissions
ISDA appreciates the IOSCO Task Force on Cross-Border Regulation’s engagement with the industry at meetings in Hong Kong on April 7, London on April 25 and Washington, DC on April 28, 2014. Further to discussions during those meetings, ISDA wishes to comment on a number of specific issues, and highlight how OTC derivatives markets have been affected by a lack of effective cross-border regulatory harmonization. OTC derivatives markets have historically been the most global in nature of all financial markets, and the absence of consistency in regulatory reform is having a direct impact on these markets as a result. This also affects other product areas and, more importantly, threatens the efficiency with which ‘real economy’ end-users can manage and transfer business risk to financial markets.
IOSCO Letter Cross Border 5 29.pdf
May 26, 2014
Benchmarks: ISDA comments on the Greek Presidency note on benchmarks - May 2014
ISDA comments on the Greek Presidency note on benchmarks dated 9 May 2014_26.05.14.pdf
March 14, 2014
Response to Irish Finance Ministry consultation on EMIR implementation
On March 14, in cooperation with the Irish Debt Securities Association (IDSA), ISDA responded to the Irish Department of Finance consultation on member state discretions in the European Market Infrastructure Regulation (EMIR) No 648/2012. The response highlights concerns about a number of aspects of Irish implementation indicated in the consultation paper.
IDSA _ ISDA Joint EMIR Consultation Response.pdf
March 14, 2014
Benchmarks: European Commission proposal - key concerns
Benchmarks European Commission proposal Key concerns_14.03.14.pdf
January 27, 2014
ISDA response to ESMA Level 2 MAR consultation
On January 27, ISDA responded to the European Securities and Markets Authority’s (ESMA) discussion paper on measures for implementation of the rules on market abuse and insider dealing under the Market Abuse Regulation (MAR). The letter highlights that any Level 2 legislation should not go beyond the mandate provided by the regulation and should avoid over prescriptive requirements. Implementing measures should also take into account the specificities of different instruments and market participants, while ensuring a level playing field. In particular, ISDA asked for clarification of rules on market soundings, indicators of market manipulation and public disclosure of inside information and delays.
January 24, 2014
ISDA response to IOSCO consultation on the implementation of Oil Price Reporting Agencies (PRA) principles
On January 24, ISDA submitted a response to the International Organization of Securities Commissions (IOSCO) consultation on the implementation of PRA principles. ISDA supports the implementation of the PRA principles and recognises they identify the specificities of oil markets. Accordingly, ISDA does not support alignment of these principles with the IOSCO general principles for financial benchmarks.