SIFMA and ISDA provided comments to the Securities and Exchange Commission (SEC) on the Rules Relating to Security-Based Swap Execution…
May 17, 2019
Mr Steven MAIJOOR
Chairman, European Securities and Markets Authority
103 rue de Grenelle
75345 Paris Cedex 07, France
Mr José-Manuel CAMPA
Chairman, European Banking Authority
DEFENSE 4 – EUROPLAZA 20 Avenue André Prothin CS 30154 92927 Paris La Défense CEDEX
Mr Gabriel BERNARDINO
Chairman, European Insurance and Occupational Pensions Authority
60327 Frankfurt am Main
Re: Margin Requirements for Non-Centrally Cleared Derivatives – Initial Margin Models
The International Swaps and Derivatives Association, Inc. (ISDA), the Securities Industry and Financial Markets Association (SIFMA), the Securities Industry and Financial Markets Association’s Asset Management Group (SIFMA AMG) and the Association of the Luxembourg Fund Industry (ALFI) (hereinafter the Associations) support the efforts of regulators to help the industry in the implementation of the initial margin (IM) rules applicable to non-centrally cleared derivatives.
In September 2018, ISDA, SIFMA and other industry associations submitted a letter to the Basel Committee on Banking Supervision (BCBS) and the International Organization of Securities Commissions (IOSCO) to raise issues associated with the final stages of the uncleared margin rules1, particularly with the introduction of IM requirements for a large universe of counterparties as of September 1, 2020.
1 September 2018 letter sent by ISDA, SIFMA, American Bankers Association, the Global Foreign Exchange Division of the Global Financial Markets Association and the Institute of International Bankers: 20180912-Initial-Margin-Phase-In-Implementation-Joint-Trade-Association-Comments.pdf.