The scope of products subject to the proposed margin requirements is not consistent across the EU, Japan and the US. The inconsistency in the margin product set raises problems for both VM and IM calculation, in addition to other cross-border situations. ISDA respectfully advises the regulators that for any counterparty pair, ISDA members intend to mitigate this issue by choosing whether to use a broader product set rather than the set required by any specific regulation, in order to ensure the parties capture all in scope products.
Documents (1) for ISDA letter to global regulators on the use of a broad product set for purposes of margin calculation
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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...
ISDA Omnibus Canadian Representation Letter
On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...
Joint Response on Cross-margining
On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...