ISDA Responds to FCA on LIBOR Transition and the DTO

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

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...