On October 29, ISDA responded to the Securities Exchange Commission’s (SEC) notice of proposed rulemaking (NPR).
With the central role governance plays in a clearing agency’s risk management, we believe this NPR is very timely and will improve governance and risk management of these entities. We, however, believe that this NPR is only the beginning and would welcome further improvements in CCP governance.
We are generally very supportive of this NPR. Risk Management Committees (RMCs), Risk Working Groups and the obligation to formally consider stakeholders viewpoints will 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.
We are also very supportive of the SEC’s thoughts about CCP’s board obligation to oversee service providers for critical services.
ISDA notes that the proposals in the NPR should be considered as a starting point in enhancing the regulatory framework for CCPs. There are several other important issues related to clearing agencies in which further regulatory action is warranted, including emergency powers, margin adequacy, transparency and CCP capital.
Documents (1) for ISDA Responds to SEC on CCP Governance
Latest
ISDA, FIA, GFMA, CMC, CMCE Respond to IOSCO on Best Practices for OTC Commodity Derivatives
ISDA, FIA, the Global Financial Markets Association (GFMA), the Commodity Markets Council (CMC) and the Commodity Markets Council Europe (CMCE), have responded to the International Organization of Securities Commissions' (IOSCO) consultation report on best practices for over-the-counter (OTC) commodity derivatives...
Joint Response to 2026 US G-SIB Surcharge Proposal
On June 18, ISDA, the Securities Industry and Financial Markets Association and the Institute of International Finance submitted a joint response to US agencies on proposed changes to the surcharge for global systemically important banks (G-SIBs). The associations welcome the...
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...
