ISDA letter to the PRs on margin and capital requirements for covered swap entities

ISDA provides comments to the Prudential Regulators (the “PRs”) regarding the recently released notice of proposed rulemaking and request for comments (“PR Margin Proposal”) concerning margin and capital requirements for non-cleared swaps and non-cleared security-based swaps and the implementation of the related statutory provisions enacted by Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”). Our analysis of the proposed rules addresses three critical themes: providing for implementation without excessive disruption; addressing systemic risk in an appropriate manner; and developing a workable cross-border framework.

Documents (1) for ISDA letter to the PRs on margin and capital requirements for covered swap entities

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...

SwapsInfo H1 2026 & Q2 2026 Review

Trading activity in interest rate derivatives (IRD) and credit derivatives increased in the first half of 2026 compared with the same period in 2025. Growth in IRD was driven by overnight index swaps (OIS), while higher index credit derivatives activity...