ISDA wrote a letter to the European Commission and the European Securities and Markets Authority in support of an urgent request by the Chair of the EU Risk-free Rate Working Group for a statement clarifying that amendments to existing transactions for benchmark reform purposes would not have the effect of imposing margin or clearing obligations under the European Markets Infrastructure Regulation (EMIR).  The letter emphasizes the importance of ensuring the clarification applies to benchmarks generally and flags that future transition initiatives may require additional regulatory assistance in the form of guidance or legislative instruments.