|Date||Title / Description||Documents|
June 10, 2016
Industry comments on the second phase of revised Pillar 3 consultation
On June 10, ISDA, along with the Institute of International Finance (IIF) and the Global Financial Markets Association (GFMA), responded to the Basel Committee on Banking Supervision consultation on the second phase of the revised Pillar 3 disclosure requirements. Although the industry strongly endorses the better understanding of banks’ capital and risk profiles, the response highlights concern about the quantity, highly technical character, and granularity of information required, which seem likely to contribute to information overload.
June 3, 2016
Industry associations respond to notice of proposed rule-making on single counterparty credit limits
On June 3, 2016, ISDA, The Clearing House Association, the American Bankers Association, the Financial Services Roundtable and the Securities Industry and Financial Markets Association jointly responded to the Board of Governors of the Federal Reserve System’s notice of proposed rule-making implementing single counterparty credit limits for domestic and foreign bank holding companies with total consolidated assets of $50 billion or more.
May 24, 2016
ISDA and TCH publish considerations for CCP resolution
ISDA and The Clearing House (TCH) have published a new paper on central counterparty (CCP) resolution. The paper identifies a number of potentially significant resolution tools or approaches that require further evaluation by the official sector and the industry.
April 18, 2016
ISDA/GFMA/IIF publish industry FRTB QIS analysis
On April 18, ISDA, GFMA and IIF published key findings from an updated quantitative impact study (QIS) based on the final Fundamental Review of the Trading Book (FRTB) rules. The industry analysis, based on data from 21 banks, shows the new rules will result in market risk capital increasing between 1.5 and 2.4 times compared with current levels, depending on internal model approval for bank trading desks.
March 14, 2016
ISDA/AFME respond to EBA consultation on internal models for market risk
On March 11, 2016, ISDA responded jointly with the Association for Financial Markets in Europe (AFME) to the European Banking Authority (EBA) consultation on assessment methodology on the use of internal models for market risk. The ISDA/AFME response notes the number of areas in the draft regulatory technical standards where the EBA sets out overly prescriptive criteria, highlights the need for sufficient supervisory discretion to reflect the diversity of EU regulated banks, and suggests the avoidance of any contradiction with the Fundamental Review of the Trading Book framework, which banks may need to implement already in 2019.
February 15, 2016
ISDA/AFME response to EBA consultation on treatment of CVA risk under SREP
On February 12, 2015, ISDA responded jointly with the Association for Financial Markets in Europe (AFME) to the European Banking Authority (EBA) consultation on guidelines on the treatment of credit valuation adjustment (CVA) risk under the supervisory review and evaluation process. The ISDA/AFME response challenges the need for the proposed guidelines, suggesting that the right place to make changes to the CVA framework is at the Basel level. It also highlights the duplicative nature of the proposals with existing SREP guidance and the resulting overriding of the EU CVA exemptions.
November 4, 2015
ISDA/GFMA/IIF send letter to GHOS and BCBS on FRTB
On October 30, ISDA, GFMA and IIF sent a letter to the Group of Governors and Heads of Supervision (GHOS) and the Basel Committee on Banking Supervision (BCBS) highlighting areas of the Fundamental Review of the Trading Book (FRTB) framework that require further consideration in order to ensure a balanced and more robust market risk capital framework and prevent negative impacts on the market and broader economy.
October 22, 2015
ISDA/GFMA/IIF publish industry FRTB QIS analysis
ISDA, GFMA and IIF ran a project to analyse the data submitted by 28 banks as part of the fourth Fundamental Review of the Trading Book (FRTB) quantitative impact study (QIS). The results show banks using the standardised approach will have to hold 4.2 times the total market risk capital banks hold today.
October 15, 2015
Consideration of Accounting Analysis for CCP Recovery and Continuity Tools
This paper examines some factors that central counterparties (CCPs) should consider in structuring partial tear-up methodologies so as not to contravene rules on offsetting under the applicable accounting standards, which would render cleared derivatives uneconomical. The paper notes that CCPs can structure partial tear-up in a number of ways. Whatever the structure, the CCP’s methodology for partial tear-up should be transparent, written in its rule book, available to all potentially affected parties and should respect US GAAP and IFRS accounting standards.
October 5, 2015
Joint associations’ response to BCBS consultation on IRRBB
On September 11, ISDA responded jointly with the other associations (IIF/IBFed/GFMA) to the BCBS consultation on interest rate risk in the banking book (IRRBB). The response supports the goal of ensuring that banks continue to manage IRRBB effectively, and that appropriate transparency is achieved to properly gauge banks’ IRRBB exposure. However, it reiterates these goals can be pursued within a Pillar 2 and Pillar 3 frameworks. Given the nature of IRRBB, the industry does not believe that a Pillar 1 approach is appropriate.