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
Latest
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...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...
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...