International Capital Market Association (ICMA) and International Securities Lending Association (ISLA)
International Capital Market Association (ICMA) and International Securities Lending Association (ISLA)SupportAdvocacy
Summary: The International Capital Market Association (ICMA) and the International Securities Lending Association (ISLA) submitted a joint comment supporting the recognition of modular, cross-product netting architectures within the Basel III Endgame framework. They argue that recognizing these existing industry-standard frameworks (like the CPMA) will preserve operational efficiency, accurately reflect net economic exposures, and maintain liquidity in the securities finance markets.
Dear Sir/ Madam
On behalf of the International Capital Market Association (ICMA) and the International Securities Lending Association (ISLA), we welcome the opportunity to submit the attached joint comment letter addressing the Agencies’ Notices of Proposed Rulemaking under the Basel III Endgame framework. This submission delivers targeted, industry-led recommendations regarding Cross-Product Netting (Question 24 of the G-SIB NPR) and the macroprudential treatment of bankruptcy-remote security pledge structures under the revised Collateral Haircut Approach and the Supplementary Leverage Ratio.
The full technical arguments and structural recommendations supporting the resilience and liquidity of core SFT markets are detailed in the attached document for your review.
Kind Regards
The International Capital Market Association & the International Securities Lending Association