ISDA filed the attached comment letter in response to the CFTC’s ANPRM to amend exisiting requirement related to swap dealers’ risk management programs.
Documents (1) for ISDA Comment Letter to US Commodity Futures Trading Commission (CFTC) Advanced Notice of Proposed Rulemaking regarding Risk Management Program Regulations
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ISDA In Review – October 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in October 2026.
ISDA Briefing on EMIR Compromise Amendments under MISP
On November 2, ISDA published its recommendations on the European Parliament (EP) compromise amendments to EMIR under the Market Integration and Supervision Package (MISP). The briefing covers five areas: transaction reporting (Article 9), non-financial counterparties (Article 10), initial margin model...
Response on UK MIFIR Reporting Guidelines
On November 6, ISDA responded to the Financial Conduct Authority’s (FCA) consultation CP26/34 ‘Preparing for the new transaction reporting regime’ on the upcoming changes to the UK Markets in Financial Instruments Regulation (MIFIR) transaction reporting regime, as set out in...
Response on Transaction Reporting and Transparency
On October 30, ISDA submitted comments on the European Parliament’s (EP) proposed transaction reporting and transparency-related amendments to the European Commission’s Market Integration and Supervision Package (MISP). On transaction reporting, ISDA commends the EP’s ambition but cautions against trying to...