ISDA, FIA, GFMA, CMC, CMCE Respond to IOSCO on Best Practices for OTC Commodity Derivatives

ISDA, FIA, the Global Financial Markets Association (GFMA), the Commodity Markets Council (CMC) and the Commodity Markets Council Europe (CMCE), have responded to the International Organization of Securities Commissions’ (IOSCO) consultation report on best practices for over-the-counter (OTC) commodity derivatives position reporting.

The associations support IOSCO’s objectives to enhance market integrity, orderly trading and resilience in OTC commodity derivatives markets, but emphasize that these goals should be achieved through better use of existing data and stronger cross-border regulatory cooperation, rather than introducing new reporting requirements. The response strongly opposes proposals that could lead to mandatory or systematic OTC position reporting to exchanges or additional reporting layers, warning these would be duplicative, burdensome and potentially harmful to market functioning. Instead, it advocates for a targeted, risk-based approach, where exchanges can request specific OTC data on an ad hoc basis when justified, while broader oversight and intervention should remain with public authorities.

Documents (1) for ISDA, FIA, GFMA, CMC, CMCE Respond to IOSCO on Best Practices for OTC Commodity Derivatives

ISDA Publishes Updated ISDA SIMM Governance

ISDA has published an updated version of the ISDA SIMM® Governance Framework, which sets out the principles under which the ISDA Standard Initial Margin Model® operates and the process through which it will be reviewed and amended on a consistent...

ISDA Response to PRA IMA Consultation

On September 18, ISDA, the Association for Financial Markets in Europe, the Institute of International Finance and UK Finance submitted a joint response to the UK Prudential Regulation Authority consultation on adjustments to the internal model approach (IMA) for the...

Calibration Test – IQ September 2026

Calibrating capital requirements is a highly complex undertaking and getting it wrong can have serious consequences. Too much lenience might lead to banks holding insufficient capital to mitigate their risks. But excess conservatism can put balance sheets under strain, forcing...