No-Action Relief Request: Clearing-created Swaps ("firm" or "forced" trades)

No-action relief request for SDs/MSPs who do not undertake reporting responsibilities with respect to Clearing-created Swaps under Rule 45, until such time as the Commission promulgates a rule specifically treating reporting responsibility with respect to Clearing-Created Swaps. One example of such a swap would be a “firm” or “forced” trade – a cleared trade entered into between a DCO and a clearing member pursuant to the testing that a DCO is required to do of the actionable prices clearing members must provide to the DCO as the basis for the DCO’s daily market pricing.

Documents (1) for No-Action Relief Request: Clearing-created Swaps ("firm" or "forced" trades)

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...