United States

This section catalogues ISDA’s work in the United States in the Association’s core areas of focus: documentation, public policy, market structure, market practices, research and other areas


DateTitle / DescriptionDocuments
June 7, 2013
Letter to CFTC on CME Amended Request to Adopt New Chapter 10 and New Rule 1001
Chicago Mercantile Exchange Inc. Amended Request to Adopt New Chapter 10 and New Rule 1001 (IF 12-014). Letter to Commodity Futures Trading Commission.
CME 1001.pdf
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.
Joint Trade Assn Letter to CFTC Requesting Cross Border Exemptive Order ....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
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.
Rates SDR Liquidity Data Jan through March 2013.pdf
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.
Credit DTCC SDR Data 3 11 13 3PM.pdf
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.
Credit and Rates SDR Liquidity Data Study January 2013.pdf
March 1, 2013
Survey of Buy-Side Members on Request for Quotes (RFQs)
Joint survey by SIFMA Asset Management Group, ISDA and MFA
RFQ Asset Mgmt Survey Results.pdf
February 6, 2013
Comment Letter on CFTC’s Further Proposed Cross-Border Guidance
Comment Letter to the CFTC regarding Further Proposed Guidance Regarding Compliance with Certain Swap Regulations
Cross-border comments FINAL-020613.pdf
January 23, 2013
Comment Letter on Margin Requirements
Comment Letter to the SEC regarding Capital, Margin, and Segregation Requirements for Security-Based Swap Dealers and Major Security-Based Swap Participants and Capital Requirements for Broker-Dealers
ISDA Margin Response to the SEC.pdf
January 17, 2013
Real-Time Reporting FAQ
The start of real-time reporting of interest rate and credit default swaps has raised some questions regarding the information that needs to be real-time reported with respect to swaps allocated after execution. This document provides guidance around some of the issues raised.
Real Time reporting FAQ v4-clean.pdf