Comment Letter
Documents (1) for CFTC’s Proposed Rulemaking on: 1) 17 CFR Part 43 Real-Time Public Reporting of Swap Transaction Data; 2) 17 CFR Part 45 Swap Data Recordkeeping and Reporting Requirements; and 3) 17 CFR Part 23 Reporting, Recordkeeping, and Daily Trading Records Requirements for SDs and MSPs.
Latest
Determining Initial Reference Index for New Trades
On November 25, 2025, ISDA published a Market Practice Note (MPN) to recommend a specific methodology that market participants could elect to use for the purposes of determining the Initial Reference Index for certain new inflation derivative transactions given that...
ISDA Response to FCA on Fund Tokenization
On November 21, ISDA responded to the Financial Conduct Authority’s (FCA) consultation paper CP25/28 on progressing fund tokenization. In the response, ISDA focuses on the use of tokenized assets as both cleared and non-cleared derivatives collateral. Tokenization presents a significant...
ISDA Requests FASB to Consider ASC 815
On November 19, ISDA submitted a request to the Emerging Issues Task Force (EITF) of the Financial Accounting Standards Board (FASB) to clarify whether FASB Accounting Standards Codification (ASC) 815 does not prohibit using the spot method to assess hedge...
ISDA Response to CFTC Tokenized Collateral and Stablecoin Initiative
ISDA has responded to the CFTC’s Request for Input on the Tokenized Collateral and Stablecoin Initiative, offering perspectives on how tokenization and GENIUS Act–compliant payment stablecoins might contribute to more efficient and resilient collateral practices in derivatives markets. The letter...