On January 4, 2017, ISDA’s Accounting Committee issued a confirmation letter to the Staff of Office of the Chief Accountant of the Securities and Exchange Commission (SEC) related to an ISDA whitepaper on the accounting Impact of central counterparty rule book changes. The SEC staff confirmed all the conclusions of the ISDA Accounting Committee outlined in the whitepaper and follow-up submission – namely i) that the changes to the rule books of LCH and CME, as supported by legal opinions from external counsel, should result in the presentation of variation margin amounts as settlement of the derivative exposure and not collateral against it for purposes of applying the accounting and presentation guidance in ASC 815 (US GAAP covering derivatives and hedging); and ii) that the de-designation and re-designation of existing hedging relationships under ASC 815 would not be required solely because of these changes to the respective CME and LCH rule books. ISDA recognizes the significance of the continued application of hedge accounting when the hedging derivative has been affected by these rule changes and its importance to clearing members and end users.
Documents (4) for CCP Rule Book Changes on Settled-to-Market Model/Impact on Hedge Acctg
- isda-sec-vm-settlement-confirming-letter(pdf) will open in a new tab or window
- isda-vm-settlement-whitepaper-final(pdf) will open in a new tab or window
- lch-stm-model-responses-to-sec-final-003(pdf) will open in a new tab or window
- vm-as-settlement-additional-paper-for-sec-final-003(pdf) will open in a new tab or window
Latest
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
ISDA Feedback on Identifying Reference Data
On July 20, ISDA submitted feedback to the European Securities and Markets Authority (ESMA) on draft Level 3 guidance on several technical issues caused by the interaction of the recently adopted regulatory technical standard on derivatives transparency (RTS 2) and...
US Basel III Endgame 2026 Update
In March 2026, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation published a new proposal for capital rules known as the US Basel III, based...
Episode 59: Reducing Burdens
As she nears the end of her term as chair of the European Securities and Markets Authority, Verena Ross joins The Swap to discuss progress in simplifying and reducing the burden of EU financial regulation, including transaction reporting. Please view...
