|Date||Title / Description||Documents|
July 2, 2014
ISDA comment paper on EU bank structural reform proposal
ISDA has submitted a comment paper to EU decision-makers on the EC proposal for a Regulation on Bank Structure. ISDA largely limits its comments to proposed provisions most relevant to OTC derivatives.
May 30, 2014
ISDA/AFME response to ESMA consultation on draft RTS on the revised Transparency Directive
On May 30, ISDA and AFME responded to the ESMA consultation paper Draft Regulatory Technical Standards on major shareholdings and indicative list of financial instruments subject to notification requirements under the revised Transparency Directive. The response highlights positive developments including the aggregation principle, which allows the inclusion of a break down by type of financial instrument (i.e. distinction between cash-settled and physically-settled derivatives) in notifications. The exemptions from notifications for market-making activities (under Article 9.5) and trading books (under Article 9.6) are also positive developments.
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.
January 27, 2014
ISDA response to ESMA Level 2 MAR consultation
On January 27, ISDA responded to the European Securities and Markets Authority’s (ESMA) discussion paper on measures for implementation of the rules on market abuse and insider dealing under the Market Abuse Regulation (MAR). The letter highlights that any Level 2 legislation should not go beyond the mandate provided by the regulation and should avoid over prescriptive requirements. Implementing measures should also take into account the specificities of different instruments and market participants, while ensuring a level playing field. In particular, ISDA asked for clarification of rules on market soundings, indicators of market manipulation and public disclosure of inside information and delays.
January 24, 2014
ISDA response to IOSCO consultation on the implementation of Oil Price Reporting Agencies (PRA) principles
On January 24, ISDA submitted a response to the International Organization of Securities Commissions (IOSCO) consultation on the implementation of PRA principles. ISDA supports the implementation of the PRA principles and recognises they identify the specificities of oil markets. Accordingly, ISDA does not support alignment of these principles with the IOSCO general principles for financial benchmarks.
October 18, 2013
JAC Response to the Joint Forum Consultative Document: Point of Sale disclosure in the insurance, banking and securities sector.
On October 18, the Joint Associations Committee on Retail Structured Products (JAC) responded to the Joint Forum Consultative Document: Point of Sale disclosure in the insurance, banking and securities sector.
The consultation considers whether the current different regulatory approaches to Point of Sale disclosure need to be further aligned, so that consumers across all three financial sectors receive adequate product disclosure at the point of sale.
October 10, 2013
JAC response to the CBI Consultation CP68 on types of alternative investment funds under AIFMD
On October 10, the Joint Associations Committee on Retail Structured Products responded to the Central Bank of Ireland's Consultation (CP68) on types of alternative investment funds under AIFMD and unit trust schemes under the Unit Trusts Act 1990 (including EUTs, REITs etc.)
October 9, 2013
ISDA/JAC response to HMT & BIS consultation on Banking Reform: draft secondary legislation
On October 9, ISDA submitted two responses to the consultation issued by HM Treasury & Department for Business Innovation and Skills on Banking reform: draft secondary legislation (issued in July).
The first response was on behalf of the Joint Associations Committee (JAC) on Retail Structured Products in relation to structured issues.
The second response considers proposals for ring-fenced banks to be permitted to sell simple derivatives products only to their customers.
September 20, 2013
ISDA/AFME joint response to the EC on the Regulation on short selling and certain aspects of credit default swaps (the Regulation)
On September 20, ISDA & AFME submitted a joint letter to the European Commission on the current review of the Regulation on short selling and certain aspects of credit default swaps (the Regulation).
September 16, 2013
ISDA-BBA response to the ESMA CP “Draft Regulatory Technical Standards on contracts having a direct, substantial and foreseeable effect within the Union and non-evasion of provisions of EMIR”
On September 16, ISDA and BBA submitted their response to the ESMA consultation paper entitled “Draft Regulatory Technical Standards on contracts having a direct, substantial and foreseeable effect within the Union and non-evasion of provisions of EMIR”