ISDA Responds to CPMI-IOSCO Consultation on Margin Proposals

On June 29, ISDA submitted a response to a consultation from the Committee on Payments and Market Infrastructures (CPMI) and the International Organization of Securities Commissions (IOSCO) on updated guidance and public quantitative disclosures to implement the 2025 margin proposals.

ISDA’s response makes the following points:

  • Retain the final report language on margin simulators;
  • Require multi-step, day-by-day stress replay to reflect path dependency;
  • Enhance standardization of central counterparty outputs and transparency on stress scenarios and add-ons;
  • Clarify that simulators are not a substitute for disclosures needed to support replicability; and
  • Refine the backward-looking responsiveness measure by reporting responsiveness over pre-defined historical stress periods rather than via a one-year window.

Documents (1) for ISDA Responds to CPMI-IOSCO Consultation on Margin Proposals

ISDA Omnibus Canadian Representation Letter

On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...

Joint Response on Cross-margining

On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...

Response to SEC on FICC Guaranty Fund

On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...