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 of securities and derivatives, which was published in the Federal Register on June 30, 2026.
The letter made the following recommendations:
- Establish a formal, coordinated process for the joint review and approval of portfolio and cross-margining programs;
- Ensure product eligibility is assessed via common economic drivers;
- Provide regulatory certainty on issues affecting insolvency analysis;
- Work with the private sector to address the operational measures required to implement broader cross-margining and portfolio margining;
- Address regulatory impediments to safe and efficient portfolio and cross-margining programs; and
- Work with prudential and global regulators to ensure that the benefits of portfolio and cross-margining are recognized across capital, margin and cross-border frameworks.
Documents (1) for ISDA and FIA Respond to CFTC and SEC on Cross-margining
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