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
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.
20150427 - Trade Associations Letter on EBA CVA Report re Basel Recommen....pdf
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.
FRTB Briefing Notes FINAL.pdf
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.
IM Haircutting Letter - April 17 2015.pdf
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.
Standardized Approach Capital Floors Final Comment Letter.pdf
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.
letter to co-chairs BCBS Working Group on Liquidity 20 March 15.pdf
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.
1b. Trade Associations Response - FRTB CP3_20150220_FINAL.pdf 2b. FRTB  Letter to Secretary General Coen_20150220_.pdf
February 11, 2015
ISDA Webcast: Preparing for WGMR Implementation
This webcast outlines the scope of the new requirements and describes the ISDA initiatives that are under way to prepare for the rules. This includes progress on developing a standard initial margin model (SIMM) and adaptations to collateral documentation.

ISDA Webcast: Preparing for WGMR Implementation
ISDA WGMR webcast FINAL slides.pdf
January 26, 2015
CCP Default Management, Recovery and Continuity: A Proposed Recovery Framework
CCPs are required to develop recovery plans to avert a threat to their viability and ensure they can maintain the continuity of critical services without requiring the intervention of resolution authorities or resorting to public money. The ISDA CCP Default Management, Recovery and Continuity paper proposes a framework for recovery and sets out tools that can be used to re-establish a matched book following the default of one or more clearing members. The paper does not cover non-default losses and those relating to liquidity shortfalls.
CCP Default Management recovery and continuity 26-01-2015.pdf
January 16, 2015
ISDA responds to BoE consultation on CCP interoperability
On January 16, ISDA responded to the Bank of England’s consultation on central counterparty interoperability.
ISDA's response to the BoE CCP inter-operability paper Jan 16 2014 - Final.pdf
December 5, 2014
ISDA Response to OTC DAT Assessment of incentives to clear centrally
This letter provides brief initial comments from the Association on the assessment of incentives to clear report (the Report) published in October by the OTC Derivatives Assessment Team, established by the OTC Derivatives Coordination group (the Group). The aim is to bring certain issues, which we believe to be critical to the incentives to clear debate, to the immediate attention of the Group. The Association intends to follow this letter up with detailed and technical support for the issues raised in due course.
ISDA Response to OTC DAT Assessment of Incentives to Clear Dec 14 (2).pdf