The Institute of International Finance (IIF), together with ISDA, submitted a response to the Basel Committee on Banking Supervision (BCBS), the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) Consultative report on the topic of “Review of margining practices” on January 26. 

The joint association industry letter appreciates the large amount of data shared by BCBS, CPMI and IOSCO and broadly agrees with the proposed follow up actions covered in the Consultative report.

The letter welcomes that the report acknowledges the difference between margin models for cleared exposures and for non-centrally cleared exposures and provides in-depth response by clearly distinguishing the two models, where ever necessary.

Note: This consultation response covers the positions of our members that are clearing members and their clients. The paper does not reflect the views of many CCPs, and many of the CCPs are in disagreement with the views expressed herein.