ISDA Response to BCBS and IOSCO Consultative Document on Margin Requirements for Non-centrally-cleared Derivatives

ISDA responded to the Basel Committee on Banking Supervision (“BCBS”) and the International Organization of Securities Commissions (“IOSCO”) with respect to the Consultative Document “Margin requirements for non-centrally-cleared derivatives” of July 2012.  Specifically, ISDA expressed its concern that the severe application of the proposals, as presented in the consultation, has the potential to undermine systemic resiliency by significantly affecting liquidity in financial markets and the general economy.


Lofchie Comment:  ISDA’s response to IOSCO, and IOSCO’s reaction, also has significance for U.S. regulation.  For example, the U.S. banking regulators recently extended the comment period for their margin regulations in light of the issues raised by IOSCO. 

View letter in full here (links externally to PDF).