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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Efficiency is Vital to Delivering Resilience

With less than three months to go until implementation of US Treasury clearing begins at the end of this year, it’s critical that the mandate is safely implemented without compromising market efficiency. This represents a huge change in market structure,...

Assessing Tokenized MMFs as Eligible Collateral

Distributed ledger technology and digital assets have matured from their early stages to solutions capable of addressing longstanding inefficiencies in collateral management. Tokenized money market funds (TMMFs) represent a particularly promising area for the application of this technology, combining the...