ISDA Response to ESMA on CCP Model Validation

On April 7, ISDA responded to the European Securities and Markets Authority’s (ESMA) consultation on draft regulatory technical standards (RTS) under article 49(5) of the European Market Infrastructure Regulation (EMIR), on the conditions for an application for validation of model changes and parameters under Articles 49 and 49a of EMIR, which have been revised as part of EMIR 3.

In the consultation paper, ESMA sets out proposed quantitative thresholds and qualitative elements to be considered when determining whether a model change is significant. In the response, ISDA noted that more information would be necessary to understand the rationale behind the thresholds that are proposed. ISDA provided comments on ESMA’s interpretation of ‘concentration risk’ and on the proposed lookback period for assessing whether a change in significant.

Documents (1) for ISDA Response to ESMA on CCP Model Validation

IRD Trading in the US, EU and UK

This research note analyzes changes in interest rate derivatives (IRD) trading activity in the US, EU and UK from 2021 to 2024. It examines how central bank interest rate policies influenced IRD trading volumes and how the composition of IRD...

Response to ESMA on Clearing Threshold Regime

On June 16, ISDA responded to the European Securities and Markets Authority's (ESMA) consultation on the new clearing threshold (CT) regime. The new CT regime, based on uncleared positions, was introduced in the context of the European Market Infrastructure Regulation...