In this response to the Commodity Futures Trading Commission’s (CFTC) Project KISS, ISDA identifies a series of rules, practices, and other CFTC interpretations and guidance that the commission should re-evaluate and either revise or amend to promote economic growth and remove costly and ineffective barriers to the efficient and safe functioning of the derivatives markets. The letter is structured by providing comments on a series of specific subject matter areas, in each instance following two sets of recommendations—recommendations for streamlining the CFTC’s rules and related interpretations and guidance, and recommendations for improving the CFTC’s oversight responsibilities. The subject matter areas addressed are as follows:
(1) Trading;
(2) Clearing;
(3) Reporting;
(4) Registration; and
(5) A series of other areas, including:
(a) Margin;
(b) Capital and liquidity;
(c) Cross-border swaps regulation;
(d) Regulation automated trading;
(e) Position limits; and
(f) CFTC internal processes and procedures and regulatory structure.
In some cases, this letter will recommend changes to CFTC rules, no-action relief, and guidance to resolve instances where those rules or interpretations are ambiguous or otherwise incomplete and unclear in a way that places an unnecessary element of uncertainty on businesses, transactions and markets without promoting any corresponding regulatory or policy goals. In other instances, we recommend changes to resolve issues that present burdens on or barriers to the efficient functioning of the derivatives markets.
Click on the PDF to read the full response.
Documents (1) for ISDA Response to CFTC Project KISS
Latest
Episode 56: Countdown to Treasury Clearing
With less than nine months to go until the first US Treasury clearing mandates come into force, BlackRock’s Tyler Wellensiek and BNY’s Nate Wuerffel discuss industry progress. Please view this page via Chrome to access the recording.
Response to Eurosystem Consultation on Appia
On April 22, ISDA responded to the Eurosystem consultation on the Appia roadmap. ISDA broadly supports the roadmap and its high level principles, while recommending that the principle on market access and integration should be expanded to explicitly address interoperability...
ISDA Responds to ESMA on PTRR Clearing Exemption
On April 20, ISDA submitted a response to the European Securities and Markets Authority (ESMA) consultation paper on a draft regulatory technical standard (RTS) for the post-trade risk reduction (PTRR) exemption from the derivatives clearing obligation under Article 4b of the...
Response on Competitiveness of EU Banking Sector
On April 17, ISDA responded to the European Commission’s (EC) targeted consultation on the competitiveness of the EU banking sector. The EU is aiming to bolster the ability of its financial markets and banking sector to grow, remain competitive and...
