|Date||Title / Description||Documents|
May 3, 2016
ISDA letter to European Commission on Margin RTS
On April 29, 2016, ISDA submitted a letter to the European Commission on the Margin RTS drafted by the European Supervisory Authorities. The letter covers a range of issues, but does not cover variation margin settlement timing, which will be addressed in a separate letter.
April 7, 2016
ISDA responds to the EC’s consultation on European financial legislation impact
When publishing its capital markets union proposal in September 2015, the European Commission (EC) launched a consultation on the cumulative impact assessment of European financial legislation in order to identify the areas where adjustments would help growth and jobs in the European Union. ISDA submitted a response to this cumulative impact assessment that predominantly focuses on the following three topics: a) capital rules; b) market transparency rules (pre-trade public transparency of derivatives markets under the Europe’s revised Markets in Financial Instruments Directive; and c) review of the European Market Infrastructure Regulation, which addresses reporting to trade repositories, central clearing and margining of derivatives. The introduction of this response aims to strongly support and demonstrate the benefits of derivatives markets for the economic growth. This response will serve as a reference for ISDA’s advocacy efforts in the coming months in Europe.
April 6, 2016
ISDA submits joint response on ESMA’s paper on benchmarks
On March 31, ISDA, the FIA and Global Financial Markets Association submitted a response to a discussion paper by the European Securities and Markets Authority aimed at clarifying Europe’s financial benchmarks regulation. The regulation organises how financial benchmarks are produced, what obligations are applicable to their administrators and contributors, and how end users may refer to EU and non-EU benchmarks. Formal consultations on draft technical advice and technical standards are expected in the course of 2016.
March 23, 2016
Response to ESMA’s Consultation Paper on Guidelines on transaction reporting, reference data, order record keeping & clock synchronization (ESMA/2015/1909)
ISDA’s response to ESMA’s Consultation Paper on proposed Guidelines for certain data and reporting aspects of MiFIDII / MiFIR found in Regulatory Technical Standards 22, 23, 24 and 25 of the regulation.
March 9, 2016
ISDA responds to FCA consultation paper 15/43 on MIFID implementation
ISDA has responded to the UK Financial Conduct Authority’s (FCA) consultation paper CP 15/43. It is the first FCA consultation on implementation of the revised Markets in Financial Instruments Directive, and at least a further consultation is expected. CP 15/43 seeks views on issues related to the FCA’s regulation of the secondary trading of financial instruments, and some points covered in the consultation may be affected by yet unpublished European Union legislation and guidance.
February 2, 2016
JAC response to the ESMA consultation paper on PRIIPs key information documents
On November 10, the European Securities and Markets Authority (ESMA) published a consultation paper on packaged retail and insurance-based investment products (PRIIPs) key information documents (KIDs). The paper sought to establish regulatory technical standards on the presentation and content of the KID, including methodologies for the calculation and presentation of risks, rewards and costs within the document. ISDA has responded to this paper in partnership with ICMA and our members.
August 19, 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.
August 12, 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.
August 12, 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.
June 1, 2015
JAC responds to FCA thematic review on product development and governance of structured products
On March 5, 2015, the UK Financial Conduct Authority (FCA) published a thematic review on the product development and governance of structured products. Firms need to ensure they design products that have a reasonable prospect of delivering economic value to end clients and promote their features in a clear and balanced way. The thematic review highlights further areas that firms need to work on. Given the firms are replying in detail to the FCA, the Joint Associations Committee’s (JAC) letter focuses on high-level issues.