On August 16, 2022, ISDA filed the attached comment letter with the U.S. Securities and Exchange Commission (SEC) in response to the agency’s rule proposal regarding ESG disclosures for certain investment advisers and investment companies. The SEC’s proposal addresses a number of issues related to the manner in which funds and advisers incorporate ESG factors in to their investor disclosures. ISDA’s comments are limited to the aspects of the proposal that reference derivatives instruments.
Documents (1) for ISDA Responds to SEC Rule Proposal: ESG Disclosures by Certain Investment Advisers and Investment Companies
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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...