On April 7, 2021, ISDA and FIA submitted a joint response to the European Commission (EC)’s consultation on the draft delegated act and accompanying annex to specify the conditions under which the commercial terms for clearing services for over-the-counter derivatives are considered to be fair, reasonable, non-discriminatory and transparent (FRANDT). In the response, the associations thank the EC for the pragmatic changes and refinements they have made in a number of important areas of FRANDT, which will make the rules more proportionate. A number of critical issues are highlighted that should be considered before the FRANDT rules are finalized. These include questions on territorial scope, application of FRANDT to new/prospective clients only, the implementation period, proposed requirements on the refusal of clearing orders, and suspension, liquidation or close out of client positions and notice periods.
Documents (1) for ISDA and FIA Respond to EC’s Consultation on FRANDT Requirements
Latest
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...