ISDA letter responding to the CFTC’s proposed cross-border rules for margin

ISDA provides comments to the CFTC regarding the recently proposed rulemaking relating to the cross-border application of the Commission’s margin requirements for uncleared swaps . Our analysis of the proposed rules addresses five critical themes: supporting the ‘Guidance’ approach with modifications; addressing harmonization of global rules with simplified substituted compliance; adoption of a 5% de minimis exemption patterned after the “emerging markets” exemption in the Guidance; swaps of non-US CSE’s executed through or by a US branch should receive exemption; and margin rules should only take effect 12 months after rules are finalized by global regulators..

Documents (1) for ISDA letter responding to the CFTC’s proposed cross-border rules for margin

Episode 60: Modelling Margin

The ISDA Standard Initial Margin Model has proved to be one of the most consequential industry models ever developed. The Swap talks with two industry veterans involved in its development. Please view this page via Chrome to access the recording.

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