ISDA Submits Comments to FICC on Proposed Rule Changes Related to Clearing Models and Margin Segregation

On April 17, ISDA submitted a comment letter in response to the Fixed Income Clearing Corporation’s (FICC) proposed rule changes published by the Securities and Exchange Commission (SEC) on March 27, 2024. The changes would modify FICC’s government securities division (GSD) rule book so that FICC can facilitate access to clearing and settlement services of all eligible secondary market trades in US Treasury securities, in accordance with the Securities Exchange Act of 1934. The letter also addresses FICC’s advance notice to amend the GSD rules and proposed rule changes on separate and independent calculation, collection and holding of margin, published by the SEC on March 28, 2024.

Subsequently, the SEC solicited additional comments from market participants on FICC’s proposals related to the agent clearing model, as well as margin segregation via a series of questions. ISDA responded to the SEC’s questions on July 18, 2024.

Documents (2) for ISDA Submits Comments to FICC on Proposed Rule Changes Related to Clearing Models and Margin Segregation

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...