On 20 September, FIA and ISDA jointly responded to ESMA’s seven consultations on recovery-related topics in the CCP Recovery and Resolution Regulation.
A topic of particular interest to members was the consultation on the second tranche of skin-in-the-game. For this consultation, FIA and ISDA suggested the calibration be reviewed to add more indicators on financial risk management, along with additional proposed indicators.
ESMA’s consultations papers can be found here: