ISDA letter to the CFTC on margin requirements for uncleared swaps for swap dealers and major swap participants

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