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.
Documents (1) for Joint Trade Association Letter on Cash and Money Market Funds as Initial Margin
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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...