Supporting G20 Objectives

The IIGC and the industry's commitments to global supervisors

ISDA and the industry have worked in close collaboration with global supervisors to achieve greater levels of counterparty credit risk management, regulatory transparency and operational efficiency. The ISDA Industry Governance Committee (IIGC) is comprised of major dealers and buy side institutions and serves as a forum for market participants to communicate with regulators and to further strengthen the OTC derivatives market infrastructure.

The following materials include information on the structure of the IIGC:

Below are recent industry letters (and supplements) to the global supervisory group, and explanatory press releases which serve as useful summaries.

Click here to see Standardization Documents.

DateTitle / DescriptionDocuments
March 16, 2016
ISDA Comments on Regulation Automated Trading; Proposed Rule: 17 CFR Parts 1, 38, 40
ISDA comment letter to the Commodity Futures Trading Commission (CFTC) on Proposed Rule, Regulation Automated Trading.
Regulation AT-comment-03-16-16 (002).pdf
February 24, 2015
Public comment on the IOSCO Task Force on Cross-Border Regulation Consultation Report
ISDA appreciates the International Organization of Securities Commissions (IOSCO) Task Force on Cross-Border Regulation’s engagement with the industry throughout this consultation process. ISDA has previously submitted comments to the Task Force on a number of specific issues, and highlighted how OTC derivatives markets have been affected by a lack of effective cross-border regulatory harmonization. OTC derivatives markets have historically been the most global in nature of all financial markets, and the absence of consistency in regulatory reform is having a direct impact on these markets as a result. We appreciate the efforts of the Task Force, in this latest Consultation Report, to identify tools at a regulator’s disposal to address cross border regulation. In this letter, ISDA reiterates how cross-border regulatory harmonization could be achieved, and suggests ways in which IOSCO can reduce undesirable regulatory outcomes that threaten the efficient functioning of markets.
IOSCO Cross Border consultation response for submission.pdf
April 12, 2013
Letter on Margin Requirements for Non-Centrally-Cleared Derivatives
Letter from ISDA, IIF, AFME and SIFMA to the chairs of the BCBS, FSB, CGFS, IOSCO and CPSS (the “five chairs”) on concerns regarding the effects of initial margin (IM) requirements. The letter respectfully requests the chairs consider withdrawing or suspending any IM requirements until the consequences of such requirements have been fully analyzed and clarified.
Margin Requirements for Non-Cleared Derivatives.pdf
November 29, 2012
ISDA Response to the Fourth Financial Stability Board Progress Report on Implementation of OTC Derivatives Market Reforms
Comment letter to the FSB
ISDA response to 4th FSB paper -  final - Nov 2012.pdf
July 31, 2012
ISDA Response to the Third Financial Stability Board Progress Report on Implementation of OTC Derivatives Market Reforms
Comment letter to the FSB
ISDA response to 3rd FSB paper - final - Jul 2012.pdf
November 30, 2011
ISDA Response to the Financial Stability Board Progress Report on Implementation of OTC Derivatives Market Reforms
Comment letter to the FSB
September 26, 2011
Consultative report on OTC derivatives data reporting and aggregation requirements
Comment letter to CPSS-IOSCO
IOSCO-CPSS 20110923final versionv2.pdf
July 29, 2011
Letter to Financial Stability Board (FSB) providing overview of industry achievements
ISDA provides the FSB with an overview of industry achievements over the past year. The letter covers recent developments under the headings of clearing, standardisation, exchange and electronic trading, trade repositories and financial law reform. There is also an appendix details of various studies and resources published by ISDA over the past months, which provide some background to the marketplace and to ISDA’s work.
June 30, 2011
Implementation Plan for Unique Product Identifiers
Industry implementation plan for UPI and product taxonomies for the OTC derivative asset classes.
ISDA UPI Implementation Plan Final.pdf
June 14, 2011
ISDA Announces New IIGC Co-chairs
Press Release
IIGC CoChair Release.pdf