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

Launch of ISDA Notices Hub and Protocol

ISDA has launched the ISDA Notices Hub and the ISDA 2025 Notices Hub Protocol, giving users a faster and more efficient method for delivering critical notices and reducing the uncertainty and risk of losses that can result from delays. The...

ISDA response to ESMA MiFIR Review Consultation

On July 11, ISDA submitted a response to the European Securities and Markets Authority's (ESMA) fourth package of Level 2 consultation under the Markets in Financial Instruments Regulation Review (MiFIR), on transparency for derivatives, package orders and input/output data for...