ISDA and the Futures Industry Association (FIA) supplemental 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) to add to the Complexity and Interconnectedness indicators of the G-SIB Surcharge any over-the-counter (OTC) derivatives transaction in which a US global systemically important banking organization (G-SIB), acting as agent for its client’s trade with a central counterparty (CCP), guarantees the client’s performance to the CCP.
Documents (1) for ISDA-FIA Supplemental Comment Letter to G-SIB Surcharge
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ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...