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
RMB IRD Growth in Mainland China & Hong Kong
This report analyzes interest rate derivatives (IRD) activity in mainland China and Hong Kong, with a particular focus on renminbi (RMB)-denominated IRD. It examines market growth, structure and integration across onshore and offshore centers, and places these developments within the...
ISDA and SIFMA Comment on CFTC Proposed Revisions to Business Conduct and Swap Documentation Requirements
On October 24, 2025 ISDA and SIFMA submitted comments to the CFTC on its proposed Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants. The proposal covers amendments to requirements related to external business...
Paper on Proposal 6 on Margin Transparency
On November 16, ISDA published a document that looked at proposal 6 in the final Basel Committee on Banking Supervision (BCBS), Committee on Payments and Market Infrastructures (CPMI) and International Organization of Securities Commissions (IOSCO) report on margin transparency. Proposal...
Tender Issued for DC Administrator Role
ISDA and the Credit Derivatives Governance Committee have issued an invitation to tender for an independent regulated entity to serve as the administrator for the Credit Derivatives Determinations Committees (DCs), which includes assuming the role of DC secretary. The DC...
