ISDA MEMBER LOGIN REQUIRED. As the compliance date for a number of the CFTC’s Title VII rulemakings approached on October 12, the Commission released a flurry of No-Action Letters, FAQs and Q&As in an effort to provide much needed relief to market participants. These releases covered a number of rulemaking categories, including guidance on issues relating to which swaps to include in swap dealer and MSP de minimis threshold calculations, cross-border scope, securitizations, FX forwards and swaps, and Commodity Pool and ECP concerns. SIFMA, ISDA and FIA held a Joint Member Call to discuss what relief was provided, whether it goes far enough, and what more can be expected. The Associations, in coordination with counsel from Davis Polk and Mayer Brown, covered: (1) Overview of the CFTC’s Rulemaking & NAL, FAQ, Q&A Process; (2) Cross Border, Registration and Definitional Related Relief; (3) Swap Data Reporting Guidance; (4) FX Forwards and Swaps; (5) Buy-Side Concerns; (6) Clearing; (7) Securitizations.
Watch: SIFMA/ISDA/FIA Member Call: CFTC No-Action Letters, FAQs, and Q&As
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...