ISDA provides comments to the CFTC regarding the recently proposed rulemaking relating to the cross-border application of the Commission’s margin requirements for uncleared swaps . Our analysis of the proposed rules addresses five critical themes: supporting the ‘Guidance’ approach with modifications; addressing harmonization of global rules with simplified substituted compliance; adoption of a 5% de minimis exemption patterned after the “emerging markets” exemption in the Guidance; swaps of non-US CSE’s executed through or by a US branch should receive exemption; and margin rules should only take effect 12 months after rules are finalized by global regulators..
Documents (1) for ISDA letter responding to the CFTC’s proposed cross-border rules for margin
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Updated OTC Derivatives Compliance Calendar
ISDA has updated its global calendar of compliance deadlines and regulatory dates for the over-the-counter (OTC) derivatives space.
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As the derivatives industry prepared for the September 2016 implementation of initial margin requirements for non-cleared derivatives, one challenge stood out: counterparties needed to agree on the amount of initial margin to be exchanged. But if each firm developed its...
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