On August 25, 2021, ISDA submitted a response to the Financial Conduct Authority’s (FCA) CP21/22 on LIBOR transition and the derivatives trading obligation (DTO). Currently, the classes of derivatives that are subject to the DTO are swaps referencing US dollar LIBOR, sterling LIBOR, EURIBOR and certain credit default swaps. The FCA is modifying the DTO in light of interest rate benchmark reform and the transition from LIBOR to risk-free rates.
While we generally support the FCA’s proposals, we have asked the FCA to consider phasing in any new products to be included within the scope of the DTO. This would help to alleviate the pressures on firms currently working hard to effect LIBOR transition by the end of 2021.
Documents (1) for ISDA Responds to FCA on LIBOR Transition and the DTO
Latest
ISDA In Review – September 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in September 2025.
A Path to Greater CFTC-SEC Alignment
Earlier this week, the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) held a roundtable on regulatory harmonization – an initiative we wholeheartedly support. The US regulatory framework has evolved over time to facilitate financial markets...
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Working Towards Tokenized Collateral
One of the lessons learned from recent market shocks – including the 2020 dash for cash and the UK gilt market crisis in 2022 – is that when volatility strikes and market participants must suddenly generate large amounts of cash...