ISDA-FIA Comment Letter to Federal Reserve on FR Y-15 Proposal

ISDA and the Futures Industry Association (FIA) comment letter on the proposed changes by the Board of Governors of the Federal Reserve System to the mandatory Banking Organization Systemic Risk Report form (“FR Y-15”) that would affect the treatment of client-cleared OTC derivatives transactions for purposes of the capital surcharge imposed on US global systemically important banking organizations (G-SIBs).

Documents (1) for ISDA-FIA Comment Letter to Federal Reserve on FR Y-15 Proposal

FRTB Impact on Correlation Trading

The capitalization of the correlation trading portfolio (CTP) under the Fundamental Review of the Trading Book will have an adverse economic impact for users of these instruments. In particular, there is a lack of clarity and consistency in the application...

A Path to Greater CFTC-SEC Alignment

Earlier this week, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) held a roundtable on regulatory harmonization – an initiative we wholeheartedly support. The US regulatory framework has evolved over time to facilitate financial markets...