FIA and ISDA have responded to ESMA’s consultation on their “Draft Guidelines on common procedures and methodologies on supervisory review and evaluation process of CCPs under Article 21 of EMIR”.
The associations support standardisation of scope and depth of these reviews. Clearing participants rely on the CCP reviews by national competent authorities and believe that standardisation and improvement of these reviews is important in view of recent defaults at European CCPs, which at least initially required the use of the default fund. The associations recommend that these reviews are not restricted to the elements set out in the consultation, but should holistically review whether the risk management framework is fit for purpose.
