We wish to alert you to a matter which, in our view, may adversely impact the consistent global implementation of the CCP capital requirements. Our concern, in summary, is that without a centrally held and internationally agreed list of Qualifying CCPs (“QCCPs”) or CPSS-IOSCO compliant regimes, it is unclear how the CPSS-IOSCO Principles for Financial Market Infrastructures (“PFMI”) could be consistently assessed for CCPs, including for capital purposes. While latitude is being given to resolve this during 2013 for most jurisdictions, banks’ risk assessment and business viability review process means that anurgent resolution is required to remove uncertainty from the market place.
Click here to download ISDA's response to CPSS, IOSCO & FSB re. Qualifying Central Counterparties .
