On March 21, ISDA, the Institute of International Bankers (IIB) and the Securities Industry and Financial Markets Association (SIFMA) submitted comment letters to the Securities and Exchange Commission (SEC) on three proposed security-based swaps (SBS) rules under the Securities Exchange Act of 1934: 1. Proposed Rule 15Fh-4(c) Prohibition Against Undue Influence over Chief Compliance Officers, 2. Proposed Rule 10B-1 Position Reporting of Large Security-Based Swap Positions and 3. Proposed Rule 9J-1 Prohibition Against Fraud, Manipulation or Deception in Connection with Security-Based Swaps.
Documents (3) for ISDA/SIFMA/IIB SBS Comment Letters to SEC
Latest
Stress Scenarios for CCP IM Simulators
ISDA has published a paper that explains why stress scenarios that central counterparties (CCPs) use for default fund sizing cannot be used for forward-looking initial margin (IM) simulators. Typically, stress scenarios used by CCPs consist of a single step, transitioning...
Paper on EMIR 3 Active Account Representativeness
On September 4, ISDA, the European Fund and Asset Management Association (EFAMA) and FIA shared a paper with EU policymakers requesting clarification on the implementation of the active account requirement under the third European Market Infrastructure Regulation in relation to...
ISDA In Review – August 2025
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2025.
Episode 51: Trading Places
Markets have been volatile so far this year, but what has this meant for market liquidity? The Swap talks to Chris Edmonds from Intercontinental Exchange on trading activity and the market, economic and geopolitical outlook. Please view this page via...