On March 21, ISDA, the Institute of International Bankers (IIB) and the Securities Industry and Financial Markets Association (SIFMA) submitted comment letters to the Securities and Exchange Commission (SEC) on three proposed security-based swaps (SBS) rules under the Securities Exchange Act of 1934: 1. Proposed Rule 15Fh-4(c) Prohibition Against Undue Influence over Chief Compliance Officers, 2. Proposed Rule 10B-1 Position Reporting of Large Security-Based Swap Positions and 3. Proposed Rule 9J-1 Prohibition Against Fraud, Manipulation or Deception in Connection with Security-Based Swaps.
Documents (3) for ISDA/SIFMA/IIB SBS Comment Letters to SEC
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Expanding the Universe of Eligible VM
ISDA conducted a series of interviews with buy- and sell-side firms to understand the drivers of a growing use of non-cash assets as variation margin (VM) for non-cleared over-the-counter (OTC) derivatives and the barriers that remain to expanding the use...
ISDA Response on Hedge Accounting Guidance
On August 14, ISDA responded to an exposure draft from the Financial Accounting Standards Board (FASB). ISDA broadly supports the FASB’s proposed targeted improvements to hedge accounting, including allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognizing all Secured...
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...