ISDA/SIFMA/IIB SBS Comment Letters to SEC

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.

Eyeing the Basel III Finish Line

An effective regulatory capital framework relies on multiple ingredients, from appropriate drafting to rigorous testing and consultation. Even minor calibration distortions can inflate capital requirements, which could negatively affect the capacity of banks to support deep and liquid markets, with...

Joint Comment Letter on Basel III Endgame Proposal

The Institute of International Finance (IIF), the International Swaps and Derivatives Association, Inc. (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) today submitted a joint comment letter to the Board of Governors of the Federal Reserve System, the...