Letter to Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation. This response is targeted to the specific risk-based capital requirements for derivative and repo-style transactions that are cleared on central counterparties (CCP Rules). (OCC RIN 1557-AD46; OCC Docket ID OCC-2012-0009; FRB RIN 7100 AD 87; FRB Docket No. R-1442; FDIC RIN 3064-AD96)
Documents (1) for Notice of Proposed Rulemaking – Regulatory Capital Rules: Standardized Approach for Risk-weighted Assets; Market Discipline and Disclosure Requirements
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Paper on MIFIR PTT
On April 7, ISDA, the Association for Financial Markets in Europe (AFME), the International Capital Market Association (ICMA) and the European Banking Federation (EBF) published a paper on proposals relating to post-trade transparency (PTT) under the Markets in Financial Instruments...
Data Integrity for Single-sided Reporting
On April 2, ISDA published a paper on why single-sided reporting does not compromise the quality and integrity of data received by supervisors. The paper addresses concerns among regulators that moving from dual-sided reporting would adversely affect the quality of...
Paper on Removal of SI Regime
On April 2, ISDA, the Association for Financial Markets in Europe (AFME) and the International Capital Market Association (ICMA) published an update to a paper, originally published in October 2025, on the practical implications of the systematic internalizer (SI) regime...
