On January 30, ISDA responded to the UK Fair and Effective Markets Review (FEMR). ISDA raised the following issues: new rules should be considered after an assessment of the impact of current regulatory reforms; ill-considered cross-border regulation reduces competition and balkanizes markets; and standardization is more appropriate for some FICC markets than others. It would also not be appropriate to include undertakings to comply with a market code into contracts, as it could create market and legal risks.