FIA has responded to the CPMI-IOSCO consultation on updated guidance for central counterparties (CCPs) resilience and proposed amendments to the Public Quantitative Disclosures (PQDs).
FIA welcomes the proposals and supports the focus on strengthening transparency, predictability and resilience in centrally cleared markets. The response recommends that CCPs be required to provide margin simulation tools covering all material components of the margin requirement, including add-ons, and that access be extended to clients publicly or through secure, authenticated channels.
The response also calls for clearer qualitative disclosures on margin model behaviour, discretionary overrides, default fund methodology and stress scenarios. On the proposed responsiveness metric, FIA puts forward a constructive alternative based on an industry-agreed set of historical stress episodes, in place of a fixed lookback period.
Finally, FIA encourages CPMI-IOSCO to consider a Level 3 post-implementation assessment and to actively monitor the risk of regulatory fragmentation across jurisdictions.
Read full response here.
