FIA and the International Swaps and Derivatives Association (ISDA) responded to ESMA's Consultation Paper reviewing Article 26 of RTS No 153/2013 with respect to the margin period of risk (MPOR) for client accounts.
FIA and ISDA wrote that, "the regulatory framework for the calculation of margin should not prescribe one particular standard applicable to each element of a CCP’s margin calculation methodology. Rather, the calculation of appropriate margin levels for client accounts at CCPs must take into account several factors in order to ensure that the amount of margin the CCP collects is consistent with its default management objectives, and commensurate with the risk and particular attributes of each product, asset class, portfolio and market it serves, viewed in light of the legal, regulatory and contractual framework in which it operates."
