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
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.
Methodology for Regulatory Comparisons 20130820.pdf
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.)
Common Principles - Examples 20130820.pdf
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