ISDA Comment Letter to CFTC on Risk Management Requirements for DCOs

Contains the response of the International Swaps and Derivatives Association, Inc. (“ISDA”) to the Commodity Futures Trading Commission’s (the “Commission”) notice of proposed rulemaking (“NPR”) regarding the regulations to implement derivatives clearing organization (“DCO”) core principles as amended by the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”).

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Response to Eurosystem Consultation on Appia

On April 22, ISDA responded to the Eurosystem consultation on the Appia roadmap. ISDA broadly supports the roadmap and its high level principles, while recommending that the principle on market access and integration should be expanded to explicitly address interoperability...