On March 26, ISDA and the Securities Industry and Financial Markets Association submitted a joint response to the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency on the proposed reporting revisions of the Call Report, FFIEC 101 and FFIEC 102, which are designed to reflect the implementation of the Basel III Endgame proposal.
It is important that the Agencies review the comments on the Basel III Endgame proposal submitted by the Associations and consider these before finalizing the reporting requirements. In addition, the proposed reporting requirements require significant effort to implement. Thus, it is essential that the final reporting forms and instructions be published with sufficient time for banking organizations to make the necessary changes to their systems and calculations.
Documents (1) for ISDA-SIFMA Response to Proposed FFIEC Reporting Revisions
Latest
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...
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...