|Date||Title / Description||Documents|
February 7, 2017
ISDA sends VM ‘Big Bang’ letter to regulators
ISDA, the Global Financial Markets Association, including its Global FX Division, the Investment Association, Financial Services Roundtable, the ABA Securities Association and the American Council of Life Insurers have sent a letter to global regulators asking for a six-month transition from March 1 to give market participants time to complete the necessary steps for compliance with new variation margin requirements.
July 8, 2016
ISDA letter to BCBS/IOSCO requesting uniformity in time frame for margin requirements
On July 8, 2016, ISDA sent a letter to the Basel Committee on Banking Supervision and International Organization of Securities Commissions requesting that the phase-in of the derivatives margin requirements is reset so there is a uniform time frame for adopting the margin rules in all major financial jurisdictions.
April 12, 2016
Industry Associations Recommend Global Adoption of Entity-Based Reporting
ISDA published a paper, in partnership with 12 other trade associations, which recommends an entity-based approach to derivatives trade reporting in a bid to cut costs and complexity for end users.
April 1, 2015
Path Forward for Centralized Execution of Swaps: Key Principles
The execution of standardized derivatives on an exchange or electronic trading platform was a key objective from the G-20 summit in 2009, and regulations have either been implemented or are being developed in several key jurisdictions. However, ISDA and its members are concerned about the potential for divergences in how these rules are applied in each jurisdiction, which could lead to market fragmentation, low trading liquidity, duplicative compliance requirements and increased risk. This paper sets out common principles to help ensure regulatory consistency of centralized trading rules, and so facilitate equivalence and substituted compliance determinations.
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.
October 20, 2014
ISDA response to IOSCO consultation on risk mitigation standards for non-cleared OTC derivatives
On October 20, ISDA submitted its response to a consultation by the International Organization of Securities Commissions (IOSCO) on risk mitigation standards for non-centrally cleared OTC derivatives. IOSCO developed these proposals in consultation with the Basel Committee on Banking Supervision and the Committee on Payments and Market Infrastructures. ISDA supports IOSCO’s intention to promote regulatory standards on risk mitigation techniques for non-cleared OTC derivatives that should be ‘sufficiently compatible across jurisdictions to limit regulatory arbitrage, maintain a level playing field and avoid situations where the same transactions are subject to conflicting rules’. This principle is of particular importance in OTC derivatives, the most global of financial instruments.
May 29, 2014
IOSCO Task Force on Cross-Border Regulation invitation for industry submissions
ISDA appreciates the IOSCO Task Force on Cross-Border Regulation’s engagement with the industry at meetings in Hong Kong on April 7, London on April 25 and Washington, DC on April 28, 2014. Further to discussions during those meetings, ISDA wishes to comment on a number of specific issues, and highlight 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. This also affects other product areas and, more importantly, threatens the efficiency with which ‘real economy’ end-users can manage and transfer business risk to financial markets.
February 4, 2014
Reference Materials - ISDA Protocol and EU/US Comparison
January 24, 2014
ISDA response to IOSCO consultation on the implementation of Oil Price Reporting Agencies (PRA) principles
On January 24, ISDA submitted a response to the International Organization of Securities Commissions (IOSCO) consultation on the implementation of PRA principles. ISDA supports the implementation of the PRA principles and recognises they identify the specificities of oil markets. Accordingly, ISDA does not support alignment of these principles with the IOSCO general principles for financial benchmarks.
October 11, 2013
Dodd-Frank March 2013 Protocol (DFP2) to EMIR Top Up Agreement
**ISDA has updated the DFP2 to EMIR Top Up Agreement as of 11th October 2013 to correct some minor typographical errors. The updated version and blackline are posted here**. On September 10, ISDA published the DFP2 to EMIR Top Up Agreement. This document seeks to allow for EMIR-compliant documentation for parties that have adhered to the Dodd-Frank March Protocol (“DFP2”) and do not wish to adhere to the ISDA 2013 EMIR Portfolio Reconciliation, Dispute Resolution and Disclosure Protocol (“EMIR Protocol”) in addition to this. The explanatory memo is provided to assist in your consideration of the DFP2 to EMIR Top Up Agreement. This document is designed to facilitate compliance with EMIR and Dodd Frank - this document extends DFP2 to cover EMIR compliance “add-ons”.