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Publications & Filings

  • April 11, 2022 • FIA, Customer Protection \ Segregation, Advocacy, Americas, Public Policy Submissions

    FIA requests CFTC codify no-action relief for treatment of separate accounts by FCMs

    FIA has written a letter to the US Commodity Futures Trading Commission requesting codification of no-action relief initially set forth in CFTC Letter No. 19-17, Advisory and Time-Limited No-Action Relief with Respect to the Treatment of Separate Accounts by Futures Commission Merchants, and subsequently extended in CFTC Letter Nos. 20-28 and 21-29.

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  • March 31, 2022 • FIA, CCP Risk, Advocacy, Europe, Clearing, EMIR

    FIA responds to ESMA consultation on margin procyclicality

    FIA has responded to a consultation published by the European Securities and Markets Authority (ESMA) seeking input on the current calibration of the antiprocyclicality tools, and whether proposed revisions to existing Regulatory Technical Standards (RTS) may be necessary.

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  • March 25, 2022 • FIA, CCP Recovery and Resolution, Advocacy, Asia-Pacific, Advocacy, Public Policy Submissions, Regulatory Responses

    FIA responds to ASX Consultation on proposed changes to the ASX Recovery Rules

    On 11 February, ASX issued its “Consultation on proposed changes to the ASX Recovery Rules to allocate US settlement bank investment losses between the ASX CCPs and their clearing participants”. The propose changes seek to address the increased investment exposure of clearing members to US settlement banks due to the inclusion of variation margin exposures in ASX Clear (Futures) overnight (2 a.m.) margin calls.

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  • March 22, 2022 • FIA, Cross Border, Advocacy, Europe, Clearing, Advocacy, Regulatory Responses

    FIA asks EC to expedite equivalence decisions of non-EU CCPs

    FIA has jointly with ISDA, AFME, EBF and EFAMA written to Commissioner Mairead McGuinness requesting that the European Commission expedite the review of clearing arrangements in as many non-EU jurisdictions as possible.

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  • February 25, 2022 • FIA, CCP Risk, Advocacy, Europe, UK, Clearing, Advocacy, Regulatory Responses

    FIA responds to HMT Financial Services Future Regulatory Framework Review: Bank of England regulation of CCPs and CSDs

    FIA recently submitted its response to HM Treasury's central counterparties and central securities depositories reform proposals under the Financial Services Future Regulatory Framework Review.

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  • February 23, 2022 • FIA, Capital, Advocacy, Europe, Clearing, Public Policy Submissions, Regulatory Responses

    FIA responds to proposed changes to EU Capital Requirements Regulation

    FIA's response focuses on the uncertainty that the proposed new segregation condition brings for banks’ ability to offset initial margin for the purposes of calculating the exposure value under the leverage ratio framework for derivatives.

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  • February 22, 2022 • FIA, Amicus Briefs, Public Policy Submissions

    FIA, ISDA submit amicus brief in Kahle v. Cargill case

    FIA along with the International Swaps and Derivatives Association submitted an amicus brief, in support of defendants, in the U.S. District Court in the Southern District of New York. The amicus brief urges the court to grant defendants’ motion to dismiss the complaint in in Kahle v. Cargill, Inc., arguing that the swap agreement safe harbor at issue (11 U.S.C. § 546(g)) preempts state-law fraudulent-conveyance claims brought by Plaintiff, an assignee in state insolvency proceedings.

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  • February 17, 2022 • FIA, Recordkeeping and reporting, Industry Operations, Advocacy, Public Policy Submissions, Regulatory Responses

    FIA responds to FCA and BofE on reporting, data and Trade Repositories registration

    FIA has responded to a joint consultation paper issued by the Financial Conduct Authority and Bank of England regarding changes to reporting requirements, procedures for data quality and registration of Trade Repositories under UK EMIR. The consultation sets out proposals relating to measures for mandatory delegated reporting requirements, counterparty notifications and reconciliations processes and the use of XML schemas and global identifiers based on the adoption of CPMI-IOSCO CDE recommendations.

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  • February 7, 2022 • FIA, Capital, CCP Risk, Advocacy, Clearing, Advocacy, Public Policy Submissions, Regulatory Responses

    FIA outlines clearing capital challenges and portability improvements in comments to CPMI & IOSCO

    FIA has responded to a consultation by the Committee on Payments and Market Infrastructures (CPMI), and the International Organization of Securities Commissions (IOSCO) on client clearing access and portability of positions in the event of a default.

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  • January 27, 2022 • FIA, CCP Risk, Advocacy, Public Policy Submissions

    FIA urges balance in response to BCBS, CPMI, IOSCO consultation on margin

    FIA has responded to a consultation by the Basel Committee on Banking Supervision (BCBS), Committee on Payments and Market Infrastructures (CPMI), and the International Organization of Securities Commissions (IOSCO) on the impact of market volatility in 2020 on central counterparties and initial margin requirements.

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