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Publications & Filings

  • February 23, 2022 • FIA, Capital, Advocacy, Europe, Clearing, Public Policy Submissions, Regulatory Responses

    FIA responds to proposed changes to EU Capital Requirements Regulation

    FIA's response focuses on the uncertainty that the proposed new segregation condition brings for banks’ ability to offset initial margin for the purposes of calculating the exposure value under the leverage ratio framework for derivatives.

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  • February 22, 2022 • FIA, Amicus Briefs, Public Policy Submissions

    FIA, ISDA submit amicus brief in Kahle v. Cargill case

    FIA along with the International Swaps and Derivatives Association submitted an amicus brief, in support of defendants, in the U.S. District Court in the Southern District of New York. The amicus brief urges the court to grant defendants’ motion to dismiss the complaint in in Kahle v. Cargill, Inc., arguing that the swap agreement safe harbor at issue (11 U.S.C. § 546(g)) preempts state-law fraudulent-conveyance claims brought by Plaintiff, an assignee in state insolvency proceedings.

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  • February 17, 2022 • FIA, Recordkeeping and reporting, Industry Operations, Advocacy, Public Policy Submissions, Regulatory Responses

    FIA responds to FCA and BofE on reporting, data and Trade Repositories registration

    FIA has responded to a joint consultation paper issued by the Financial Conduct Authority and Bank of England regarding changes to reporting requirements, procedures for data quality and registration of Trade Repositories under UK EMIR. The consultation sets out proposals relating to measures for mandatory delegated reporting requirements, counterparty notifications and reconciliations processes and the use of XML schemas and global identifiers based on the adoption of CPMI-IOSCO CDE recommendations.

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  • February 7, 2022 • FIA, Capital, CCP Risk, Advocacy, Clearing, Advocacy, Public Policy Submissions, Regulatory Responses

    FIA outlines clearing capital challenges and portability improvements in comments to CPMI & IOSCO

    FIA has responded to a consultation by the Committee on Payments and Market Infrastructures (CPMI), and the International Organization of Securities Commissions (IOSCO) on client clearing access and portability of positions in the event of a default.

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  • January 27, 2022 • FIA, CCP Risk, Advocacy, Public Policy Submissions

    FIA urges balance in response to BCBS, CPMI, IOSCO consultation on margin

    FIA has responded to a consultation by the Basel Committee on Banking Supervision (BCBS), Committee on Payments and Market Infrastructures (CPMI), and the International Organization of Securities Commissions (IOSCO) on the impact of market volatility in 2020 on central counterparties and initial margin requirements.

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  • January 26, 2022 • FIA, CCP Recovery and Resolution, Advocacy, Europe, Clearing, Regulatory Responses

    FIA submits joint response to six ESMA consultations on CCP resolution

    As part of their level-2 rulemaking, the European Securities and Markets Authority (ESMA) consulted on six topics around central counterparty (CCP) resolution.

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  • January 19, 2022 • FIA, Advocacy, Europe, Clearing, EMIR, Regulatory Responses

    FIA and ISDA submit joint response to ESMA paper on clearing thresholds under EMIR

    On 19 January, FIA and ISDA jointly submitted its respond to ESMA's Discussion Paper on the review of the clearing thresholds under EMIR.

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  • January 17, 2022 • FIA, Commodities, Sustainable Finance, Advocacy, Americas, Asia-Pacific, Europe, Advocacy, Regulatory Responses

    FIA responds to proposed updated IOSCO commodities principles

    FIA has filed a response to a consultation report on principles for the regulation of commodity derivatives from the Board of International Organization of Securities Commissions (IOSCO). The report, published in November 2021, aimed to reflect changes and developments in commodities derivatives markets since the publication of the existing IOSCO Principles for the Regulation and Supervision of Commodity Derivatives in 2011.

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  • January 6, 2022 • FIA, Recordkeeping and reporting, Advocacy

    FIA supports efforts to modernize SEC recordkeeping requirements

    FIA has sent a letter to the US Securities and Exchange Commission in support of the agency’s efforts to modernize recordkeeping requirements, and in support of comments filed with the SEC by the Securities Industry and Financial Markets Association on the topic.

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  • January 5, 2022 • FIA, CCP Risk, Advocacy, UK, Clearing, Advocacy, Public Policy Submissions, Regulatory Responses

    FIA and ISDA respond to BofE consultation on stress testing

    FIA and the International Swaps and Derivatives Association (ISDA) welcomed a consultation by the Bank of England (the Bank) on supervisory stress testing. The Associations together agreed overall with the presented approach. However, given the huge effort to run supervisory stress tests, the Associations jointly proposed for global regulators to join forces and run joint SSTs.

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