Page 18 - 期货和衍生品行业监管动态（2025年2月刊）

期货和衍生品行业监管动态

example of this. Unfortunately, ISDA’s analysis has shown that the US Basel III rules

and the capital surcharge for global systemically important banks (G-SIB) would

increase capital for six US G-SIB client clearing businesses by $7.2 billion, which is

equivalent to more than 80%. This punitive tax is completely at odds with the

post-financial crisis policy objective to promote greater use of central clearing and

would negatively affect market stability. We have set out the steps that are necessary

to fix this issue and will continue to advocate for those changes so the provision of

vital client clearing services is not compromised.

This comes at a time when the US Securities and Exchange Commission (SEC)

is due to introduce mandatory clearing in the US Treasury market from the end of this

year. ISDA has been leveraging its experience in derivatives clearing to help firms

prepare for this transformational change, but the prudential framework must also be

calibrated appropriately.

As it stands, the proposed US capital rules don’t recognize cross-product netting

for transactions based on US Treasury securities and interest rate futures. Services like

these allow firms to obtain initial margin efficiencies from offsetting trades in a

portfolio of transactions, reflecting reduced risk, but there is no commensurate benefit

from a capital perspective under the standardized approach for counterparty credit risk.
As more Treasury securities and repos are cleared under the SEC rules, the lack of

recognition of cross-product netting will constrain bank balance sheets and limit their

ability to offer client clearing.

We also think changes are necessary to the supplementary leverage ratio (SLR),

which is inconsistent with the objective to improve the efficiency and resilience of the

Treasury market, as we pointed out in a letter to prudential regulators last year. The

SLR acts as a non-risk-sensitive binding constraint on banks that can impede their

ability to act as intermediaries, including their capacity to offer client clearing. We are

pleased to hear Federal Reserve chair Jerome Powell acknowledge in testimony to the

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