On October 11, ISDA responded to the Commodity Futures Trading Commission’s (CFTC) notice of proposed rulemaking (NPR). With the central role governance plays in a derivatives clearing obligation’s (DCO) risk management, we believe this NPR is very timely and will improve governance and risk management of DCOs. We, however, believe that this NPR is only the beginning and would welcome further improvements in DCO governance.
We are generally very supportive of this NPR. Risk Management Committees (RMCs), Risk Working Groups and wider consultation will promote transparency, accountability and predictability, and facilitate effective oversight by the Commission.
RMCs are good practice in many central counterparties (CCPs) and are already required by regulation in many other jurisdictions. We, therefore, welcome codification of such governance bodies as proposed by this NPR.
ISDA welcomes the consultation on additional topics, namely Market Participant Consultation Prior to a Rule Change and RMC Member Information Sharing with Firm to Obtain Expert Opinions. We believe both proposals would significantly improve DCO governance.
We note that the Securities Exchange Commission is also consulting on CCP governance and welcome that the two Commissions are liaising with each other.
Documents (1) for ISDA Responds to CFTC on CCP Governance
Latest
ISDA AGM Studio: Darcy Bradbury & Tyler Wellensiek
Darcy Bradbury, ISDA board member and managing director at D. E. Shaw, and Tyler Wellensiek, managing director and global head of market structure at BlackRock, speaks with Chris Young, ISDA’s head of US public policy, about how the post‑crisis regulatory...
Response to ESMA Guarantees
On April 30, ISDA responded to the European Securities and Markets Authority (ESMA) consultation paper on guarantees as central counterparty (CCP) collateral and certain aspects of CCP investment policy. ISDA broadly supports ESMA’s proposed draft regulatory technical standards (RTS) to...
ISDA AGM Studio: Jenny Cosco and Jason Granet
Jenny Cosco, global head of government relations and regulatory strategy at LSEG, and Jason Granet, chief investment officer at BNY, speak with Tara Kruse, ISDA’s global head of derivative products and infrastructure, about how firms can manage liquidity pressures during...
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.
