ISDA provides comments regarding the recently released notice of proposed rules and advance notice of proposed rulemaking (“CFTC Margin Proposal”) concerning margin requirements for non-cleared swaps and the implementation of the related statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Our analysis of the proposed rules and response to the proposed rulemaking addresses three critical themes: providing for implementation without excessive disruption; addressing systemic risk in an appropriate manner; and developing a workable cross-border framework.
Documents (1) for ISDA letter to the CFTC on margin requirements for uncleared swaps for swap dealers and major swap participants
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ISDA In Review – December 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in December 2025.
Response to EC on Market Risk Prudential Framework
On January 6, ISDA, the Association for Financial Markets in Europe (AFME) and the Institute of International Finance (IIF) submitted a joint response to the European Commission’s (EC) targeted consultation on the application of the market risk prudential framework. ISDA,...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Response on CCP Participation Requirements
On December 24, ISDA responded to a consultation from the European Securities and Markets Authority (ESMA) on central counterparty (CCP) participation requirements. Participation requirements for CCPs are vital for safe and efficient clearing markets, and ISDA broadly supports ESMA’s consultation...
