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September 1st, 2014 by Nick Railton-Edwards

The EU Council has issued notice of an attaché level meeting on 4 September 2014 to discuss the sharing of data held in trade repositories. However, the promised land is still some way off- the meeting will examine the Commission recommendation for a Council decision to open negotiations on bilateral agreements between the EU and […]

August 29th, 2014 by Simon Lafrance

On 18 August 2014, ISDA sent a letter to BCBS and IOSCO requesting a two year extension to international implementation of the margin rules for uncleared derivatives. BCBS-IOSCO Framework was finalised in September 2013 and favours international implementation in December 2015, with phase-in until December 2019. The letter is the latest outgrowth of coordinated efforts […]

August 28th, 2014 by Nick Railton-Edwards

The FCA have stated their intention to make “substantial and important” changes to the controversial attestation process. Attestation is an informal tool, with unclear legal backing. While the Agency has no formal powers to force attestation, a refusal to comply is almost certain to trigger more intrusive investigation. Director of Supervision Clive Adamson’s letter to […]

August 27th, 2014 by Simon Lafrance

On 26 August 2014, the Regulatory Oversight Committee (ROC) published an updated version of the Principles to be observed by pre-LOUs that wish to integrate into the Interim Global Legal Entity Identifier System (GLEIS). One generous footnote was added, which provides further clarification on the mandatory conditions for endorsement: 1.  Adherence to the Principles as […]

August 26th, 2014 by Simon Lafrance

On 21 August 2014, the Governing Council of the ECB announced that it has identified four systemically important payment systems (SIPS): TARGET2 (operated by the Eurosytem), EURO1 and STEP2-T (both operated by EBA CLEARING) and CORE(FR) (operated by STET) The SIPS are given one year to comply with the Regulation on oversight requirements for SIPS […]

August 26th, 2014 by Nick Railton-Edwards

The FT last week reported the latest turn of the regulator’s revolving door. Flamboyant outgone CFTC Commissioner Bart Chilton has been retained in an advisory capacity by the Modern Markets Initiative (MMI)[1], a hitherto obscure lobbying group for HFT funds[2]. In his role as regulator, Mr Chilton famously called HFTs “cheetahs”; this was not merely […]

August 22nd, 2014 by Simon Lafrance

On 21 August 2014, ISDA published the 2014 ISDA Credit Derivatives Definitions Protocol. Members and non-members can adhere by 12 September 2014. Citigroup is the first entity to adhere to the protocol. The protocol should enable the adhering parties to effectively transition to the new 2014 ISDA Credit Derivatives Definitions, published earlier this year and […]

August 21st, 2014 by Nick Railton-Edwards

The CFTC has issued three no action letters in as many days, variously relating to: SEF documentation of uncleared swap confirmations, customer account templates for the CME and Indian Rupee clearing by the Clearing Corporation of India Ltd. Each is only of specific import, a brief summary follows: SEF Documentation of Uncleared Swap Confirmations: Letter […]

August 18th, 2014 by Nick Railton-Edwards

The WSJ reported on Friday that the EC has privately indicated that it will recommend a two year extension to pension funds’ clearing exemption under EMIR. The clock on the three year exemption has been running since EMIR’s entry into force on 16 August 2012, if granted the extension will run until August 2017[1]. Pension […]

August 15th, 2014 by Simon Lafrance

At a time where an unknown number of institutions covered by EMIR are still figuring out what LEI means, sitting on their hands as partners in crime with national regulators which are equally puzzled with enforcement of trade reporting obligations, BaFin shouts Eureka. has published an article  outlining the drastic solution put in place […]

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Derivatives Risk Solutions LLP