CCP Risk archive
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FIA and ISDA support CFTC and SEC's review of portfolio and cross-margining programs
FIA and ISDA have submitted a joint response to a request for comment on the CFTC and SEC's administration of portfolio margining and cross-margining programs, welcoming the agencies' efforts to expand appropriately tailored risk-based margin frameworks across securities and derivatives markets.
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FIA and ISDA respond to FICC's proposal to establish a Guaranty Fund at its Government Securities Division
FIA and ISDA welcome the FICC's proposed GSD Guaranty Fund but urge the SEC and FICC not to mutualise non-default losses and to preserve the ten-day cooling-off period.
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FIA responds to CFTC consultation on 24/7 and perpetuals in energy
FIA encouraged the agency to assess 24/7 and perpetual products through two different lenses: readiness and appropriateness.
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FIA commends CFTC for prediction markets rule, urges further action
FIA’s latest response notes that prediction markets can serve important functions, including aggregating information and enabling market participants to manage exposure to a broad range of events. FIA commits to working with the CFTC to develop an effective and durable regulatory framework for prediction markets.
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FIA responds to CPMI-IOSCO consultation on updated CCP resilience guidance and PQDs
FIA responds to CPMI-IOSCO's consultation on CCP resilience and PQDs, calling for stronger margin transparency, broader client access to simulation tools and a Level 3 post-implementation review.
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FIA and ISDA respond to MAS CP on recovery and resolution planning for market infrastructures
FIA and ISDA respond to the Monetary Authority of Singapore’s consultation on recovery and resolution planning and enhancement of resolution powers for capital market infrastructures. The response supports the proposed framework for recovery and orderly wind-down planning for capital market infrastructures, while recommending greater clarity and safeguards on certain aspects of the framework.
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FIA responds to ESMA consultation on CCP guarantees and investment policy
FIA supports expanding eligible CCP collateral for non-financial counterparties under EMIR 3.0, calling for substance-over-form recognition of letters of credit and mandatory clearing member protections.
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FIA responds to OCC's clearing fund allocation proposal
FIA supports OCC’s stress‑aligned clearing fund allocation, noting improved fairness and risk sensitivity, while encouraging smoothing measures to avoid volatility and monitoring potential metric overlaps.
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FIA responds to CFTC retail DCO request with suggestion for simplified regulatory approach
FIA invites the CFTC to consider a modified regime for fully collateralized and pre-funded clearing models, including those catering to retail traders.
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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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