Risk Management

ISDA’s Risk Management Team works with members, regulators and policy makers to develop rules which ensure that appropriate, prudent and risk sensitive capital charges are applied uniformly to the various financial risks faced by the industry. The group continually seeks to define best practice in each area and assist all stakeholders in achieving this.

Click here for additional and archived risk management materials.


DateTitle / DescriptionDocuments
November 25, 2014
Principles for CCP Recovery
Central counterparties (CCPs) have become a crucial part of the derivatives market infrastructure, supported by regulation that requires standardized OTC derivatives to be cleared. Given the systemic importance of these entities, ISDA and its members believe particular attention needs to be paid to ensuring the risks of a CCP reaching the point of non-viability are minimized. If that point is reached, however, a clearly defined recovery plan needs to be in place that does not involve the use of public money. The ISDA Principles for CCP Recovery paper identifies the key issues that need to be addressed, and makes several recommendations on how to proceed.
Principles for CCP Recovery FINAL.pdf
November 25, 2014
ISDA letter to the CFTC on margin requirements for uncleared swaps for swap dealers and major swap participants
ISDA provides comments regarding the recently released notice of proposed rules and advance notice of proposed rulemaking ("CFTC Margin Proposal") concerning margin requirements for non-cleared swaps and the implementation of the related statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). Our analysis of the proposed rules and response to the proposed rulemaking addresses three critical themes: providing for implementation without excessive disruption; addressing systemic risk in an appropriate manner; and developing a workable cross-border framework.
ISDA_-_CFTC_Proposed_Margin_Rules_Letter 112414.pdf
November 25, 2014
ISDA letter to the PRs on margin and capital requirements for covered swap entities
ISDA provides comments to the Prudential Regulators (the "PRs") regarding the recently released notice of proposed rulemaking and request for comments ("PR Margin Proposal") concerning margin and capital requirements for non-cleared swaps and non-cleared security-based swaps and the implementation of the related statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). Our analysis of the proposed rules addresses three critical themes: providing for implementation without excessive disruption; addressing systemic risk in an appropriate manner; and developing a workable cross-border framework.
ISDA_-_PR_Proposed_Margin_Rules_Letter 112414.pdf
August 22, 2014
ISDA letter to the ESAs on Estimates of numbers of accounts affected by IM segregation requirements, to demonstrate operational challenges
The margin rules proposed by the European Supervisory Authorities (the "ESAs") require IM to be segregated from proprietary assets on the books and records of a third party holder or custodian, or via other legally effective arrangements. In addition, the rules require cash IM to be segregated individually, unless other legally effective arrangements are in place to segregate it from proprietary assets. Several additional clarifications and issues are described in the letter sent by ISDA to the ESAs in July 20143. As proposed, we illustrate below the unintended consequences arising from the IM segregation requirements.
ESAs Deliverable_IA Seg Estimates_ 08222014v2 (2).pdf
August 22, 2014
ISDA letter to the ESAs on Proposed Margin Rules
ISDA is concerned about the practical consequences of certain provisions of the margin requirements under the Draft RTS on risk-mitigation techniques. These concerns were raised in brief in the letter we sent to the ESAs on 14 July commenting generally on the Draft RTS (the “July Letter”). This letter is intended to provide further detail and we would welcome the opportunity to discuss this further with the ESAs.
ICM-#20179443-v8-ISDA_Letter_-_Margin_RTS (2).pdf
August 18, 2014
ISDA letter to BCBS/IOSCO on timing issues for margin rules for uncleared derivatives
ISDA member firms participating in the industry-led WGMR implementation initiative are concerned about the market’s ability to meet an implementation date of December 2015. This concern is based not only on the significant infrastructural changes required of market participants but also due to the significant coordination effort required of global regulators. In summary, ISDA proposed that rules become effective two years after rules are clarified and finalized in Europe, Japan, and USA. ISDA also proposed a phase-in schedule for upcoming Variation Margin (VM) requirements and urged regulators to avoid imposition of implementation dates during the year end code freeze periods. Based on the above, the practical start date of the WGMR requirements would be April 2017.
WGMR MarginTiming final 18082014 (2).pdf
August 18, 2014
ISDA letter to the ESAs on Proposed Margin Rules: Documentation Requirements
ISDA is concerned about the documentation that is required for parties to qualify for exemptions from the margin requirements under the Draft RTS on risk-mitigation techniques. This documentation is not required by Regulation (EU) No 648/2012 ("EMIR") and imposing such requirements would result in very significant administrative and operational burdens. In the letter, we set out proposed alternative language that could be used to permit exemptions without documentation requirements. This letter is a supplement to the letter we sent to the ESAs on 14 July commenting generally on the Draft RTS.
ISDA_Letter_re_EU_Margin_Documentation 18082014 final (3).pdf
August 17, 2014
ISDA letter to the ESAs on Proposed Margin Requirements: Analysis of Currency Mismatch Haircut
ISDA is concerned about the haircut for a currency mismatch that is proposed in the Consultation Paper on margin and has prepared the attached analysis and counter-proposal.
EMIR_Margin_RTS_Response_-_FX_Haircut_Cover_Letter 17082014.pdf ISDA_-_EMIR_Margin_-_FX_Haircut_examples final 17082014.pdf
July 31, 2014
ISDA/GFMA/IIF further response to the BCBS’s TBG on sensitivity based approach (firm wide quantitative impact study)
On July 31 ISDA, the Global Financial Markets Association (GFMA) and the Institute of International Finance (IIF) submitted to the Trading Book Group (TBG) of the Basel Committee on Banking Supervision (BCBS) a technical paper on the sensitivity based approach as a further response to the firm-wide quantitative impact study (QIS) instructions on the Fundamental Review of the Trading Book (FRTB). This letter followed a detailed industry response submitted on July 17.
Trading Book QIS instructions_BCBS_20140731_SBA-Negative Variance.pdf
July 17, 2014
ISDA/GFMA/IIF response letters to the BCBS’s TBG on the firm-wide FRTB QIS instructions
On July 17, ISDA, the Global Financial Markets Association (GFMA) and the Institute of International Finance (IIF) submitted to the Trading Book Group (TBG) of the Basel Committee on Banking Supervision (BCBS) a detailed response letter to the firm-wide quantitative impact study (QIS) instructions on the Fundamental Review of the Trading Book (FRTB). This letter followed a preliminary industry response submitted on July 8.
Trading Book QIS instructions_BCBS_20140717_detailed response.pdf Trading Book QIS instructions_BCBS_20140708_preliminary response letter    .pdf