On December 19, ISDA submitted a response to the Canadian Securities Administrators (CSA) consultation on proposed amendments to the clearing obligation in Canada. The CSA invited comments on the proposed amendments and on the specific question set out in Annex B of the notice, ie, whether including single-name credit default swaps (CDS) within the scope of the clearing obligation would be appropriate.

In the response, ISDA asks the CSA to provide an appropriate implementation period for firms to prepare for the changes – it is proposed this would be six months from the time the amended instrument enters into force. ISDA also welcomes that the proposed changes are largely in line with global developments and existing requirements on the scope of the clearing obligation in other jurisdictions. Finally, on whether single-name CDS should be included in the scope of the clearing obligation, ISDA recommends that the scope should remain in line with global peer jurisdictions and notes that no other jurisdiction currently mandates clearing for single-name CDS. The response explains that single-name CDS are not sufficiently liquid to warrant a clearing requirement.