This letter contains the response of the International Swaps and Derivatives Association, Inc.
(“ISDA”) to the EBA’s Consultation Paper on draft RTS on capital requirements for CCPs dated 15 June 2012 (the “Consultation Paper”). Since 1985, ISDA has worked to make global over-the- counter (“OTC”) derivatives markets safer and more efficient. Accordingly, this response focuses on the draft RTS’ application to OTC derivatives markets, and in particular the proposals’ suitability for OTC derivatives CCPs.
Click here to download ISDA's comment letter.
