The latest IM deadline passed at the start of this month without fanfare, and larger firms were able to breathe their fourth sigh of relief. A year from now, the challenge will not be as “easy”.
Highlander 1986, “There can be only one!” or for a younger generation, “When you play the game of thrones, you win or die”.
In May 2019, ISDA launched two consultations: one addressing adjustments to fallback rates if IBORs are permanently discontinued, and another to address the pre-cessation of LIBOR and other IBORs.
Last July, ISDA decided to add French and Irish law to our library of Master Agreements in an attempt to prepare for potential Brexit complications. As mentioned in our earlier post, the objective of this is not to undermine English and New York law, but merely to offer an alternative so firms are awarded a greater choice.
The FCA’s recently published Stocktake Report reviewing the implementation of the Senior Managers and Certification Regime (SM&CR) is a polite criticism of senior managers and their superiors in the banking sector.
“I just wired you the funds; did you get them?”… “No… I can’t see them. Which account did you send them to? Which reference did you use? Can you ask your bank to chase?”
ESMA recently closed a consultation on the Securities Financing Transaction Reporting regulation (SFTR). The scope of SFTR includes “commodities lending”, which could be taken to include certain activities undertaken by commodity and energy market participants. SFTR covers Non-Financial Counterparties (NFC), as well as Financial Counterparties (FC). Earlier this year the start dates of reporting were … Continue reading
As expected, ISDA have communicated a more granular breakdown of
estimates for the likely population of the new IM phases 5 and 6, via relevant
working groups. These have been replicated and published by a number of third
party firms. Although all the numbers are estimated, there seems to both a lack
of mathematical rigour and some confusion between the population and threshold
The estimates are as follows: