|Date||Title / Description||Documents|
February 10, 2014
Notice of Proposed Rulemaking – Position Limits for Derivatives (RIN 3038-AD99)
ISDA/SIFMA Comment Letter to CFTC.
October 9, 2013
CDS on US Sovereign Debt - FAQ
Responses to some frequently-asked questions that ISDA has received in connection with a potential CDS Credit Event on US sovereign debt. This does not constitute legal advice, and is subject in all respects to any determination that the ISDA Americas Credit Derivatives Determinations Committee may make in relation to CDS referencing the United States. ISDA makes no comment on the likelihood of the events described in this FAQ.
August 20, 2013
Methodology for Regulatory Comparisons (Substituted Compliance)
This paper sets forth ISDA’s views regarding a conceptual framework and substantive processes for inter-jurisdictional recognition of derivatives regulation through a principles-based substituted compliance methodology. Our framework prioritizes achievement of the G-20 goals for OTC derivatives.
August 20, 2013
Common Principles - Examples (Substituted Compliance)
In our “Methodology for Regulatory Comparisons” document, ISDA proposed concepts to guide the comparisons of derivatives regulations that will be carried out by regulators assessing the possibility of substituted compliance. Our methodology relies on regulators, with input from the markets, developing common principles that will apply in various subject matter areas within derivatives regulation. These principles should be cast to support comparability of regulation without requiring identical regulation. To illustrate our proposed methodology, we offer the following examples of common principles. These examples have been developed and organized in relation to several of the original G-20 derivatives goals. (To be clear, these are merely examples and do not purport to illustrate comprehensive treatment of their subject matter areas.)
June 6, 2013
Request for Extension of CFTC Final Exemptive Order Regarding Compliance with Certain Swap Regulations
Joint Trade Association Letter to the CFTC Request for Extension of CFTC Final Exemptive Order Regarding Compliance With Certain Swap Regulations.
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.
April 2, 2013
Rates SDR Liquidity Data (January - March 2013) – DATA UPDATE
Interest Rate liquidity data based on public information compiled from the DTCC real-time reporting SDR, capturing trading activity from January 1, 2013 through March 26, 2013.
March 20, 2013
Credit Liquidity Data (January - March 2013) - DATA UPDATE
Credit data based on public data compiled from the DTCC real-time reporting SDR in the month of January 2013. Update of the document below dated March 4, 2013.
March 4, 2013
Credit and Interest Rate Liquidity Data Study (January 2013)
Credit and Interest Rate liquidity study based on public data compiled from the DTCC real-time reporting SDR in the month of January 2013.
March 1, 2013
Survey of Buy-Side Members on Request for Quotes (RFQs)
Joint survey by SIFMA Asset Management Group, ISDA and MFA