ISDA published the master regulatory disclosure letter and the accompanying guidance note. The ISDA master regulatory disclosure letter is intended to allow market participants to exchange information regarding counterparty status, as required under the relevant regulatory regimes. Additionally, ISDA published the Trade Life Cycle Events Guide for non-cleared margin. The guide is developed by the ISDA working group to assist market participants in preparing for non-cleared margin requirements by providing a uniform global approach to the treatment of life cycle events to legacy transactions, based on the guidance in the BCBS and IOSCO framework for margin requirements for non-centrally cleared derivatives.
The ISDA master regulatory disclosure letter currently provides for the exchange of counterparty status information in relation to European Market Infrastructure Regulation, or EMIR (as amended by EMIR REFIT) by appending a modified form of the previous ISDA EMIR Classification Letter as Appendix A (European Union). It is anticipated that the ISDA master regulatory disclosure letter will be updated or supplemented over time through the addition of new appendices to accommodate, for example, increased granularity of data or extension of asset class or geography.
With respect to developing Trade Life Cycle Events Guide, the working group identified and agreed the list of trade events as well as agreed to the general consensus captured in the matrix on whether or not these identified trade events would bring a legacy non-cleared swap transaction into scope for the new margin rules. The intention of the list is to provide an agreed market guide for firms to utilize to comply with certain aspects of the non-cleared margin rules within their respective jurisdictions. No firm is legally bound or compelled to follow any determinations made within the list.
- Notification on ISDA Master Regulatory Disclosure Letter
- Notification on Trade Life Cycle Events Guide
Keywords: International, Europe, EU, Banking, Securities, Disclosures, Margin Requirements, EMIR, Legacy Transaction, OTC Derivatives, Swaps, BCBS, IOSCO, ISDA
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