4th July 2016

BBA Response to Consultation on ESMA Guidelines on participant default rules and procedures

The BBA broadly supports the proposals put forward by ESMA. We consider that the actions listed in the guidelines and the testing and reviewing procedures are appropriate, although in the case of the latter we recommend that discussions around insolvency proceedings be extended to include “indirect participants”.

We have suggested multiple stakeholders who should be involved in the definition of the default rules and procedures of a CSD, and a number of items that should be included in the internal plans. We believe these suggestions would help to safeguard the position of CSDs and would put CSDs in a strong position to defend themselves against defaults.

Please read the full response via the link below.