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CCP Risk archive

  • FIA and ISDA respond to CPMI-IOSCO consultation on general business losses

    FIA and ISDA backed CPMI-IOSCO proposals, urging clearer prescriptive treatment of FMI general business losses, stronger resources, consistent scenarios, transparency, and rejecting margin gains haircutting.

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  • FIA responds to ESMA consultation on CCP participation requirements

    FIA has responded to the European Securities and Markets Authority's consultation on EMIR 3.0 draft regulatory technical standards on the elements to be considered when EU central counterparties define participation requirements. The response highlights the need for CCPs to assess clearing members based on the actual risks they pose, rather than relying on entity type or licensing status as proxies for risk. In particular, the response distinguishes between regulated non-bank financial clearing members and non-financial counterparties that typically clear to hedge commercial exposures and do not provide financial services.

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  • FIA responds to CFTC on the use of tokenized collateral and on the report of the President's Working Group on Digital Asset Markets

    FIA has filed comments with the CFTC on tokenization, stablecoins and digital asset market structure.

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  • FIA responds to Bank of England consultation on CCP resilience

    FIA's response to the BoE on CCP resilience advocates against financial incentives for porting and recommends enhancements to margin models in UK EMIR.

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  • FIA supports FICC-CME customer cross-margining proposal for U.S. treasuries

    FIA has submitted a comment letter to the CFTC and SEC supporting FICC and CME's proposed arrangement for cross-margining of customer trades in treasuries and treasury futures with offsetting risk. The proposed arrangement is under review at both the CFTC and SEC.

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  • FIA comments on ICE's US Treasury clearing proposal

    FIA filed comments with the US Securities and Exchange Commission responding to ICE Clear Credit's proposed US Treasury clearing rules. The letter commends ICC for its efforts to expand its clearing services to the U.S. Treasury market and recommends refinements to certain aspects of the proposed rules to ensure predictability and clarity for clearing firms and market participants that will participate on ICC's platform, once approved.

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  • FIA responds to ESMA consultation on margin transparency requirements

    FIA has responded to the European Securities and Markets Authority’s consultation on margin transparency requirements, urging the regulator not to mandate overly prescriptive requirements for clearing member firms, particularly those that do not apply their own margin models but simply pass through clearinghouses’ margin requirements to clients. 

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  • FIA submits request for clarification on EMIR 3.0 active account representativeness

    FIA, ISDA and the European Fund and Asset Management Association have shared a paper with EU policymakers, requesting clarification on the implementation of the active account requirement under the European Market Infrastructure Regulation (EMIR 3.0) in relation to representativeness. The associations request regulatory guidance, with a view to standardising compliance and avoiding fragmented implementation of requirements across EU member states.

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  • FIA and ISDA respond to Reserve Bank of Australia guidance for the clearing and settlement facility resolution regime

    FIA and ISDA urge greater clarity in the RBA’s draft guidance on clearing and settlement facility resolution to enhance transparency, communication and market stability during interventions.

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  • How clearing members managed market volatility

    Speaking at the 2025 IDX conference, clearing members discussed how investments in operations helped many manage the impact of recent volatility spikes.

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