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).

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