On April 11, 2024, ISDA and the Securities Industry and Financial Markets Association (SIFMA) filed a comment to the US Commodity Futures Trading Commission (CFTC) in response to the proposed amendments to Part 43 Real-Time Public Reporting and Part 45 Swap Data Recordkeeping and Reporting Requirements, which was published in the Federal Register on December 28, 2023.
Documents (1) for ISDA/SIFMA Response to CFTC P43/P45 2023 NPRM
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ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...