ISDA Letter to US Regulators on $50M IM Threshold and Documentation Requirement

ISDA, SIFMA, GFXD and SIFMA AMG are requesting that US regulators provide clarification that covered swap entities and their counterparties that will become subject to the initial margin requirements of the Margin and Capital Requirements for Covered Swap Entities or the Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants as of September 1, 2019 (phase four) and on or after September 1, 2020 (phase five) do not have to comply with the documentation requirements described therein unless the bilateral IM amount exceeds $50 million.

Click on the attached PDF to read the letter.

Documents (1) for ISDA Letter to US Regulators on $50M IM Threshold and Documentation Requirement

Expanding the Universe of Eligible VM

ISDA conducted a series of interviews with buy- and sell-side firms to understand the drivers of a growing use of non-cash assets as variation margin (VM) for non-cleared over-the-counter (OTC) derivatives and the barriers that remain to expanding the use...

ISDA Response on Hedge Accounting Guidance

On August 14, ISDA responded to an exposure draft from the Financial Accounting Standards Board (FASB). ISDA broadly supports the FASB’s proposed targeted improvements to hedge accounting, including allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognizing all Secured...

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...