ISDA welcomes the opportunity to respond to the Financial Stability Board’s (FSB) Derivatives Assessment Team’s (DAT) consultative report on incentives to centrally clear over-the-counter (OTC) derivatives, and supports the work of the FSB in evaluating of the effects of Group-of-20 financial regulatory reforms. We appreciate that the FSB is evaluating not only the regulatory reforms individually, but also – importantly – how they intersect. We also welcome an analytical framework that supports post-crisis regulatory objectives while rationalizing the regulatory framework where appropriate.
ISDA members support clearing, which is an effective means to reduce counterparty risk and increase the resilience of the financial system. The clearing market infrastructure operates well, and the global approach to clearing has achieved significant reductions across many facets of systemic risk. Clearing brings a number of inherent benefits, including: multilateral netting; reduction in credit risk; operational efficiency; and a robust default management process. Many firms clear voluntarily due to these inherent benefits.
Further incentives to clear are created through the regulatory framework. Regulations such as the non-cleared derivatives margin rules and certain capital requirements apply across a broad range of products and counterparties, regardless of whether such products are suitable for clearing, or whether such counterparties pose systemic risk. As a result, these regulatory incentives may not always be appropriate. We appreciate that the DAT report seeks to identify where this may be the case.
Our key recommendations fall into the following broad subject areas:
- Recalibration of the capital framework;
- Flexibility in the clearing mandate;
- Need to increase clearing capacity; and
- Fostering harmonization where sensible.
ISDA also advocates for making non-cleared margin requirements more risk appropriate. These proposals will be the subject of a separate paper.
Click on the attached PDF to read the full paper.
Documents (1) for ISDA Response to FSB DAT Report on Clearing Incentives
Latest
Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
Episode 60: Modelling Margin
The ISDA Standard Initial Margin Model has proved to be one of the most consequential industry models ever developed. The Swap talks with two industry veterans involved in its development. Please view this page via Chrome to access the recording.
ISDA Wins Digital Solution of the Year Award
ISDA has won Digital Solution of the Year at the GlobalCapital Global Derivatives Awards 2026 for the ISDA Digital Regulatory Reporting (DRR) initiative and the ISDA Notices Hub. The award recognizes ISDA’s continued work to develop mutualized digital solutions that...
ISDA Launches Digital Emissions Definitions
ISDA has launched a natively digital version of its documentation for emissions allowance transactions, enabling the framework to be updated more efficiently as emissions trading systems (ETSs) evolve. The 2026 ISDA Emissions Transactions Definitions provide standardized documentation for physically settled...
