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
Latest
ISDA and SIFMA Comment on CFTC Proposed Revisions to Business Conduct and Swap Documentation Requirements
On October 24, 2025 ISDA and SIFMA submitted comments to the CFTC on its proposed Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants. The proposal covers amendments to requirements related to external business...
Paper on Proposal 6 on Margin Transparency
On November 16, ISDA published a document that looked at proposal 6 in the final Basel Committee on Banking Supervision (BCBS), Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) report on margin transparency. Proposal...
Tender Issued for DC Administrator Role
ISDA and the Credit Derivatives Governance Committee have issued an invitation to tender for an independent regulated entity to serve as the administrator for the Credit Derivatives Determinations Committees (DCs), which includes assuming the role of DC secretary. The DC...
ISDA SIMM: The Standard for IM Calculations
The ISDA Standard Initial Margin Model (ISDA SIMM) plays an important role in ensuring margin calculations are consistent, transparent and aligned with global best practices and regulatory requirements. Since its launch in 2016, the model has been rigorously tested, regularly...