ISDA’s response to the CFTC’s Request for Comment on Part 45 and Related Provisions of the Swap Data Reporting Rules

The CFTC interdivisional staff working group was established by the CFTC to identify and make recommendations to resolve reporting challenges, and to consider data field standardization and consistency in reporting. Consistent with this effort, the Commission requested comment on specific swap data reporting and recordkeeping rules, to help determine how such rules are being applied, and whether clarifications, enhancements or guidance may be appropriate. The request for comment is limited to part 45 and related provisions.

Documents (1) for ISDA’s response to the CFTC’s Request for Comment on Part 45 and Related Provisions of the Swap Data Reporting Rules

Expanding the Universe of Eligible VM

ISDA conducted a series of interviews with buy- and sell-side firms to understand the drivers of a growing use of non-cash assets as variation margin (VM) for non-cleared over-the-counter (OTC) derivatives and the barriers that remain to expanding the use...

ISDA Response on Hedge Accounting Guidance

On August 14, ISDA responded to an exposure draft from the Financial Accounting Standards Board (FASB). ISDA broadly supports the FASB’s proposed targeted improvements to hedge accounting, including allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognizing all Secured...

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...