FIA, along with the International Swaps and Derivatives Association, has responded to three of the four consultations published by the European Securities and Markets Authority on the CCP Resolution Regime. The responses cover two mandated guidelines on the CCP assessment of resolvability and cooperation arrangements between member states and third-country authorities, and non-mandated guidelines on the summary of resolution plans. The associations did not respond to a consultation on the standard written arrangement template for the resolution college.
FIA and ISDA welcome the proposals, noting the need for allowing flexibility in the circumstances of resolution and the importance of ensuring a thorough impact analysis on the broader market when assessing resolution tools. The responses also outline some of the points made by the associations when responding to previous CCP recovery and resolution rules on level 1 and level 2 consultations.