On January 22, FIA and ISDA jointly responded to a consultation from the Monetary Authority of Singapore on proposed amendments to the capital framework for approved exchanges and approved clearinghouses. The scope of the response is limited to the capital framework for clearinghouses. The associations welcome the introduction of a separate liquidity requirement for clearinghouses and propose that MAS consider a more conservative minimum threshold of at least 12 months of operating expenses, rather than the six months put forward in the proposed amendments. The associations also agree with the proposed amendments to eligible capital components, which should only include equity instruments and should exclude the clearinghouse’s own capital, also known as skin in the game. For the total risk requirement, the response suggests the alignment of the operational risk component with the liquidity risk requirement and the inclusion of some clarifications on the investment risk and general counterparty risk components.
