EMIR Responses, Comment Letters, Press Releases and Publications

ISDA supports a resilient and efficient market infrastructure that will serve to reduce risk via clearing, increased use of trade repositories and sound bilateral risk management processes. ISDA is an active participant in discussions with European legislators regarding the proposal for European Market Infrastructure Regulation (EMIR), supporting legislation and guidance.

Please find ISDA's responses, comment letters, press releases and publications pertaining to EMIR regulatory developments below.

 


DateTitle / DescriptionDocuments
September 15, 2016
ISDA response to the ESMA consultation paper on clearing
On September 5, ISDA responded to a consultation paper published by the European Securities and Markets Authority on the clearing obligation for financial counterparties with a limited volume of activity. The response supports a delay for Category 3 counterparties, noting that this would not compromise the overall objective of the clearing obligation to reduce systemic risk.
ISDA ESMA CAT 3 CP FINAL [050916].pdf
September 5, 2016
Response to the European Commission
On 5 September, ISDA responded to the ESMA consultation paper on a proposal to amend the phase-in period of the clearing obligation for financial counterparties with a limited volume of activity.
ISDA-ESMA-CAT-3-CP-FINAL-050916.pdf
April 29, 2016
ISDA letter to European Commission on Margin RTS drafted by European Supervisory Authorities
Letter from ISDA commenting to the European Commission on the Margin RTS drafted by the European Supervisory Authorities, submitted 29 April 2016. The letter covers a range of issues. It does not address VM settlement timing, which will be addressed in a separate letter.
ISDA - Margin RTS - Letter to EC 280416.pdf
August 13, 2015
Response to the European Commission EMIR Review CP
On August 13, ISDA responded to the European Commission’s consultation on the EMIR Review. ISDA highlighted a number of priority issues in its response including advocating for a move to a single-sided reporting regime and the removal of the frontloading obligation.
EMIR REVIEW RESPONSE FINAL 190815.pdf
July 15, 2015
Response to the ESMA clearing obligation consultation for EEA rates derivatives
On July 15, ISDA, FIA Europe and the Investment Association jointly responded to the European Securities and Markets Authority’s consultation on draft regulatory technical standards for the mandatory clearing of EEA interest rate derivatives.
ISDA-FIA Europe-Investment Association CO EEA Rates FINAL 150715.pdf
June 22, 2015
ISDA and four other associations submit letter on EMIR Article 13 Equivalence to EC
On June 22, the International Swaps and Derivatives Association, the Investment Association, FIA Europe, the Managed Funds Association and the Alternative Investment Management Association submitted a letter to the European Commission regarding the importance of EMIR Article 13 and MiFIR Article 33 equivalence in the context of clearing, margin, reporting and trading requirements for derivatives transactions. The letter highlighted the potential negative impact on access to non-European Union (EU) markets by EU institutions that could result in the absence of equivalence decisions.
ISDA-FIA Europe-MFA-IA-AIMA Equivalence Letter Final sig.pdf
November 6, 2014
ISDA/FIA Europe response to the ESMA clearing obligation for FX NDFs CP
On November 6, ISDA and FIA Europe jointly responded to the European Securities and Markets Authority’s consultation on draft regulatory technical standards for the mandatory clearing of foreign exchange non-deliverable forwards.
ISDA_FIA EUROPE FX NDF CO Final Response Nov2014.pdf
September 18, 2014
ISDA/FIA Europe submission on the ESMA clearing obligation for credit derivatives CP
On September 18, ISDA/FIA Europe responded to the ESMA consultation paper on the draft regulatory technical standards ("RTS") establishing a clearing obligation on certain credit OTC derivative classes.
ISDA_CDS_Response_FINAL_SEP2014_3.pdf
August 18, 2014
ISDA/FIA response to the ESMA CP on clearing obligation for G4 interest rate derivatives
On August 18, ISDA and the Futures Industry Association (FIA) responded to the European Securities and Markets Authority (ESMA) clearing obligation consultation on interest rate derivatives. Key issues in the response include the application of the frontloading requirement, phase-in periods and counterparty categorisation.
ISDA_FIA_Europe_G4 Rates CO_CP Response.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