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
Latest
ISDA In Review – June 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in June 2025.
ISDA Presents Lock-Up Agreement Proposal
ISDA is pleased to present the proposed Lock-Up Agreements and CDS – Proposed Auction Solution. “Lock-Up Agreements” are market-wide arrangements, broadly standardized and predominantly integrated with court sanctioned restructuring or bankruptcy processes. Numerous end users will sign material Lock-Up Agreements...
Key Trends in OTC Derivatives Market H2 2024
The latest data from the Bank for International Settlements (BIS) over-the-counter (OTC) derivatives statistics shows a modest increase in notional outstanding during the second half of 2024 compared to the same period in 2023. Notional outstanding for interest rate, foreign...
Request to Extend Relief on No-Action Letter 22-18
On July 3, ISDA requested to extend the relief under the Commodity Futures Trading Commission's (CFTC) no-action letter No. 22-18. ISDA requests that the relief is extended until further action by the CFTC resolves the overlapping and contradictory reporting obligations...