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ISDA has been working on a proposal that we consider can be calibrated to properly measure the risk of loss of a Clearing Member’s (“CM”) default fund contribution and meet regulatory requirements. The proposal builds on existing frameworks and in our view has a firm theoretical underpinning which should deliver appropriate sensitivity to the key risks to the default fund. Part of the proposal, specifically the Historic Drawdown Measure (“HDM”) has been reviewed by the Joint Working Group (“JWG”). We now propose to incorporate the HDM into an Incremental Default Risk Charge (“IDRC”), which is the type of model that is currently used for trading book default risk. Our proposal is that Central Counterparties (“CCPs”) would be requiredto provide the HDM data to CMs. CMs would then run an IDRC model to estimatethe 99.9th percentile loss on the basis that they might become liable for calls on the default fund over a one-year time horizon. The capital requirement covers funded and unfunded losses.
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