On August 31, ISDA and the Futures Industry Association (FIA) submitted a letter to the U.S. Commodity Futures Trading Commission (CFTC) and the U.S. Securities and Exchange Commission (SEC) on the agencies’ Joint Request for Comment on Further Implementation of Portfolio Margining and Cross-Margining of Securities and Derivatives 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, including across swaps and security-based swaps in initial margin calculations;
- provide regulatory certainty on issues impacting 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 bank capital framework recognizes the benefits of portfolio and cross-margining.
Documents (1) for ISDA and FIA Letter on CFTC-SEC Joint Request for Comment on Portfolio Margining and Cross-Margining of Securities and Derivatives
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