|Date||Title / Description||Documents|
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.
October 5, 2015
Joint associations’ response to BCBS consultation on the CVA review
On October 1, ISDA responded jointly with other associations (GFMA/IIF) to the Basel Committee on Banking Supervision consultation on the review of the credit valuation adjustment (CVA) framework. In the response, the industry i) welcomes the BCBS decision to revisit the current CVA framework and to incorporate CVA into the revised market risk framework (ie, within the Fundamental Review of the Trading Book); and ii) believes that the proposed framework is a step in the right direction towards achieving the BCBS goals of risk sensitivity and simplicity, subject to certain modifications. The response then provides a number of recommendations that, if considered together, will facilitate the swift and smooth finalization of the CVA framework review.
July 13, 2015
CCP Resilience: Letter to CPMI-IOSCO on CCP Stress Testing
May 14, 2015
ISDA/GFMA/IIF letter on the Fundamental Review of the Trading Book
On May 1, 2015, the joint associations (ISDA/GFMA/IIF) submitted a letter on the Fundamental Review of the Trading Book (FRTB) to the Chairman of the Basel Committee on Banking Supervision (BCBS) and the Chairman of the Group of Governors and Heads of Supervision (GHOS). The letter highlights the Importance of assessing the impact of the design and calibration of the FRTB in advance of finalizing the framework.
April 27, 2015
ISDA/AFME letter on the EBA CVA report recommendation 15
On April 27, ISDA and AFME submitted a letter to the European Banking Authority (EBA) and the Basel Committee on Banking Supervision regarding recommendation no. 15 of the EBA’s credit valuation adjustment (CVA) report on the framework under development at the Basel level. In general, the industry is very supportive of the EBA’s policy recommendation no. 15, and our members are keen to engage with the regulatory community on the different aspects of the framework as soon as possible.
April 23, 2015
Briefing Notes: Fundamental Review of the Trading Book
ISDA has published Briefing Notes on the Basel Committee's Fundamental Review of the Trading Book (FRTB), which summarises the main components of the FRTB and highlights areas where further attention may be required. In particular, ISDA believes an additional quantitative impact study is required to comprehensively evaluate the impact of the rules and ensure they are consistent and coherent before finalisation of the policy framework.
April 17, 2015
ISDA letter on IM haircutting
CCP recovery and continuity is essential for systemic stability and is preferable to clearing service termination. ISDA believes initial margin haircutting undermines the objective of CCP recovery and continuity, as it creates the wrong incentives for clearing participants.
April 1, 2015
Joint Association response to the BCBS capital floors consultation
On March 27, ISDA responded jointly with other associations (IIF/GFMA/CREFC) to the Basel Committee on Banking Supervision consultation on capital floors.
March 23, 2015
ISDA/GFMA/IIF letter on the net stable funding ratio (NSFR)
On March 20, the associations (ISDA/GFMA/IIF) submitted a joint letter to both the co-chairs of the Basel Committee on Banking Supervision working group on liquidity and the Financial Stability Board, supporting the further review of the treatment of margining of derivatives in the NSFR and encouraging regulators to conduct additional quantitative analysis and consider alternative approaches, if necessary.
February 26, 2015
ISDA/GFMA/IIF letters on the Fundamental Review of the Trading Book
The joint associations (ISDA/GFMA/IIF) submitted on February 20 two letters on the Fundamental Review of the Trading Book (FRTB) to the Basel Committee. The first letter is addressed to the co-chairs of the Basel Trading Book Group (TBG), and is in response to the third FRTB consultation that was published by the Basel Committee in December 2014. The letter notes that since the industry is still working through the text of the third FRTB consultation and the QIS instructions, follow-up supplementary materials may be submitted to the TBG in the coming weeks. The second letter is addressed to the secretary general of the Basel Committee, and expresses the industry's concerns about the timeline announced in the third FRTB consultation paper to complete the FRTB framework by the end of 2015 and continue the calibration work in 2016 and beyond.