ISDA welcomes the opportunity to respond to the Financial Stability Board’s (FSB) Derivatives Assessment Team’s (DAT) consultative report on incentives to centrally clear over-the-counter (OTC) derivatives, and supports the work of the FSB in evaluating of the effects of Group-of-20 financial regulatory reforms. We appreciate that the FSB is evaluating not only the regulatory reforms individually, but also – importantly – how they intersect. We also welcome an analytical framework that supports post-crisis regulatory objectives while rationalizing the regulatory framework where appropriate.
ISDA members support clearing, which is an effective means to reduce counterparty risk and increase the resilience of the financial system. The clearing market infrastructure operates well, and the global approach to clearing has achieved significant reductions across many facets of systemic risk. Clearing brings a number of inherent benefits, including: multilateral netting; reduction in credit risk; operational efficiency; and a robust default management process. Many firms clear voluntarily due to these inherent benefits.
Further incentives to clear are created through the regulatory framework. Regulations such as the non-cleared derivatives margin rules and certain capital requirements apply across a broad range of products and counterparties, regardless of whether such products are suitable for clearing, or whether such counterparties pose systemic risk. As a result, these regulatory incentives may not always be appropriate. We appreciate that the DAT report seeks to identify where this may be the case.
Our key recommendations fall into the following broad subject areas:
- Recalibration of the capital framework;
- Flexibility in the clearing mandate;
- Need to increase clearing capacity; and
- Fostering harmonization where sensible.
ISDA also advocates for making non-cleared margin requirements more risk appropriate. These proposals will be the subject of a separate paper.
Click on the attached PDF to read the full paper.
Documents (1) for ISDA Response to FSB DAT Report on Clearing Incentives
Latest
ISDA Treasury Forum: Scott O'Malia Opening Remarks
ISDA Treasury Forum June 11, 2026 Opening Remarks Scott O’Malia, ISDA CEO Hello and welcome to the ISDA Treasury Forum. I’d like to start by thanking CME Group for working with us once again to make this event happen...
Launch of US Treasury Repo Market Indicators
ISDA has launched the ISDA-Actrix US Treasury Repo Market Clearing Indicators in collaboration with Actrix. The indicators illustrate central clearing adoption in the US Treasury repo market. Sponsored cleared repo volumes are used as a proxy to monitor client participation...
ISDA-Actrix US Treasury Clearing Indicators
This report provides indicators that illustrate central clearing adoption in the US Treasury repo market. Sponsored cleared repo volumes are used as a proxy to monitor client participation in central clearing, the key objective of the Securities and Exchange Commission's...
ISDA In Review – May 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in May 2026.
