Comments and Recommendations Regarding Notice of Proposed Rulemaking re: Mandatory Contractual Stay Requirements for Qualified Financial Contracts

The International Swaps and Derivatives Association, Inc. (“ISDA”) appreciates the opportunity to provide the Office of the Comptroller of the Currency (the “OCC”) with comments and recommendations regarding the notice of proposed rulemaking (the “OCC Proposed Rule”) promulgated by the OCC regarding mandatory contractual stay requirements for qualified financial contracts (“QFCs”) of federally chartered and licensed financial institutions that are members of systemically important U.S. banking organizations and the U.S. operations of systemically important foreign banking organizations (together, “Covered Banks”).

Documents (1) for Comments and Recommendations Regarding Notice of Proposed Rulemaking re: Mandatory Contractual Stay Requirements for Qualified Financial Contracts

Maintaining Focus on Basel III Endgame Recalibration

In its original form, the US Basel III endgame proposal would have resulted in disproportionate increases in capital for trading book activities, forcing banks to make difficult choices about their participation in certain businesses. After two-and-a-half years, a revised proposal...

IRRBB Management in EMDEs

Interest rate risk in the banking book (IRRBB) has become a growing priority for banks and regulators in emerging market and developing economies (EMDEs). As many of these countries face monetary tightening cycles and ongoing macroeconomic volatility, bank balance sheets...

Response to CPMI-IOSCO on Consultation

On February 5, ISDA and FIA responded to the Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) consultation on the management of general business risks and general business losses by financial market infrastructures (FMIs)....