ISDA’s comment letter to the US Prudential Regulators and CFTC regarding the use of a broad product set for calculating variation margin.

ISDA provided comments to the US Prudential Regulators and CFTC regarding the use of a broad product set for calculating variation margin, when transactions are subject to the US VM requirements and another margin regulation (issued by a US regulator or a non-U.S. regulator) or contractually agreed variation margin requirements. ISDA requests that the two US regulators allow parties to run a single VM calculation across both product groups.

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