On October 24, 2025 ISDA and SIFMA submitted comments to the CFTC on its proposed Revisions to Business Conduct and Swap Documentation Requirements for Swap Dealers and Major Swap Participants. The proposal covers amendments to requirements related to external business conduct and swap trading relationship documentations for intended-to-be-cleared and prime broker swaps, as well as requirements to provide pre-trade mid-market marks, scenario analysis, and certain daily marks.
Documents (1) for ISDA and SIFMA Comment on CFTC Proposed Revisions to Business Conduct and Swap Documentation Requirements
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