Europe

This section catalogues ISDA’s work across the European region, highlighting public policy efforts.

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DateTitle / DescriptionDocuments
August 20, 2013
Methodology for Regulatory Comparisons (Substituted Compliance)
This paper sets forth ISDA’s views regarding a conceptual framework and substantive processes for inter-jurisdictional recognition of derivatives regulation through a principles-based substituted compliance methodology. Our framework prioritizes achievement of the G-20 goals for OTC derivatives.
Methodology for Regulatory Comparisons 20130820.pdf
August 20, 2013
Common Principles - Examples (Substituted Compliance)
In our “Methodology for Regulatory Comparisons” document, ISDA proposed concepts to guide the comparisons of derivatives regulations that will be carried out by regulators assessing the possibility of substituted compliance. Our methodology relies on regulators, with input from the markets, developing common principles that will apply in various subject matter areas within derivatives regulation. These principles should be cast to support comparability of regulation without requiring identical regulation. To illustrate our proposed methodology, we offer the following examples of common principles. These examples have been developed and organized in relation to several of the original G-20 derivatives goals. (To be clear, these are merely examples and do not purport to illustrate comprehensive treatment of their subject matter areas.)
Common Principles - Examples 20130820.pdf
July 19, 2013
ISDA, EFET & FOA commentary on MiFID – Article 59 – Definition of appropriate position limits - ESMA level 2 work
ISDA – EFET – FOA commentary on MiFID – Article 59 – Definition of appropriate position limits - ESMA level 2 work
20130719_MiFID_position_limits.pdf
July 11, 2013
ISDA/AFME joint response to the European Commission's consultation on Reforming the structure of the EU banking sector
ISDA/AFME joint response to the European Commission's consultation on Reforming the structure of the EU banking sector
http___assets.isda.org_media_d268a4bb_61a4360c.pdf
June 25, 2013
ISDA response to EC Green Paper on Long-Term Financing of the European Economy
On June 25, ISDA responded to the European Commission’s Green Paper on long-term financing of the European economy.
20130625_long_term_financing_ISDA.pdf
June 13, 2013
ISDA response to the ECON Committee questionnaire for the public consultation on enhancing the coherence of EU financial services legislation.
On June 13, ISDA responded to the ECON consultation on coherence, with the goal of contributing to a more robust and stable financial marketplace. In this response, ISDA limit ourselves to commenting on ‘Question Two’ and 'Question Four' (issues directly relevant to 'Liquidity' and OTC Derivatives Markets).
ISDA RESPONSE.COHERENCE CONSULTATION.pdf
June 13, 2013
The Joint Associations Committee (JAC) response to the IOSCO consultation on retail structured products
ISDA, UKSPA, AFME, BBA, ICMA & IIF joint response to the IOSCO consultation on retail structured products.
20130613_IOSCO_consultation_Retail_Structured_Product_JAC_response.pdf
May 17, 2013
ISDA responds to IOSCO consultation on benchmarks
On May 17, ISDA submitted its response to the second IOSCO consultation on Principles for Financial Benchmarks.
ISDA Response to IOSCO.pdf
April 12, 2013
Letter on Margin Requirements for Non-Centrally-Cleared Derivatives
Letter from ISDA, IIF, AFME and SIFMA to the chairs of the BCBS, FSB, CGFS, IOSCO and CPSS (the “five chairs”) on concerns regarding the effects of initial margin (IM) requirements. The letter respectfully requests the chairs consider withdrawing or suspending any IM requirements until the consequences of such requirements have been fully analyzed and clarified.
Margin Requirements for Non-Cleared Derivatives.pdf
February 15, 2013
ISDA response to EBA/ESMA Consultation paper - Principles for Benchmarks - Setting processes in the EU
On 15 February, ISDA submitted its final response to the ESMA/EBA consultation on financial benchmarks.
20130215_EBA_ESMA_Benchmarks_ISDA_final_response.pdf