On August 1, 2019, ISDA sent a letter to the CFTC and US Prudential regulators, co-signed by Managed Funds Association (“MFA”), Securities Industry and Financial Markets Association’s Asset Management Group (“SIFMA AMG”), Investment Company Institute (“ICI”), Institutional Money Market Funds Association (“IMMFA”), and Securities Industry and Financial Markets Association (“SIFMA”). The letter requests that US regulators:

• allow the use of a broader range of MMFs meeting the conditions set out above; and
• allow the use of comparable EU MMFs in cases where substituted compliance is available through the issuance of a comparability determination by the US Prudential Regulators.