Changes to a registered person’s status as a SD or MSP such as deregistration and limited purpose designations impact the operational ability of its counterparties to comply with their some obligations as SDs or MSPs under Part 43 and Part 45. This letter requests relief from certain requirements under the Reporting Rules and interpretive guidance with respect to other requirements under the Reporting Rules as set forth in the letter.
Documents (1) for No-Action Relief and Interpretive Guidance Request: Swap Dealer (SD) and Major Swap Participant (MSP) changes in Registration Status on Counterparties’ Obligations under Reporting Requirements.
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ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...