On March 26, ISDA and the Securities Industry and Financial Markets Association submitted a joint response to the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency on the proposed reporting revisions of the Call Report, FFIEC 101 and FFIEC 102, which are designed to reflect the implementation of the Basel III Endgame proposal.
It is important that the Agencies review the comments on the Basel III Endgame proposal submitted by the Associations and consider these before finalizing the reporting requirements. In addition, the proposed reporting requirements require significant effort to implement. Thus, it is essential that the final reporting forms and instructions be published with sufficient time for banking organizations to make the necessary changes to their systems and calculations.
Documents (1) for ISDA-SIFMA Response to Proposed FFIEC Reporting Revisions
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ISDA Response on Hedge Accounting Guidance
On August 14, ISDA responded to an exposure draft from the Financial Accounting Standards Board (FASB). ISDA broadly supports the FASB’s proposed targeted improvements to hedge accounting, including allowing interest rate hedging of held-to-maturity (HTM) debt securities, recognizing all Secured...
Joint Response to EBA Consultation
On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act under Article 8 of...
Response to JSCC on Clearing Fund Consolidation
On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...
Response on CSDD Guidelines
On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...
