ISDA’s letter to the CFTC in response to the Notice of Proposed Rulemaking regarding Clearing Member Risk Management (the “NPR”, and the rules it describes, the “Proposed Rule”) issued by the Commodity Futures Trading Commission (the “Commission”), seeking comments on proposed rules regarding risk management for cleared trades by futures commission merchants (“FCMs”), swap dealers(“SDs”) and major swap participants (“MSPs”) that are clearing members.
Documents (1) for ISDA’s comment letter on Clearing Member Risk Management
Latest
Stress Scenarios for CCP IM Simulators
ISDA has published a paper that explains why stress scenarios that central counterparties (CCPs) use for default fund sizing cannot be used for forward-looking initial margin (IM) simulators. Typically, stress scenarios used by CCPs consist of a single step, transitioning...
Paper on EMIR 3 Active Account Representativeness
On September 4, ISDA, the European Fund and Asset Management Association (EFAMA) and FIA shared a paper with EU policymakers requesting clarification on the implementation of the active account requirement under the third European Market Infrastructure Regulation in relation to...
ISDA In Review – August 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2025.
Episode 51: Trading Places
Markets have been volatile so far this year, but what has this meant for market liquidity? The Swap talks to Chris Edmonds from Intercontinental Exchange on trading activity and the market, economic and geopolitical outlook. Please view this page via...