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
ISDA Publishes ISDA SIMM® Methodology, Version 2.8+2512
Following the 2026 primary calibration exercise, ISDA is pleased to publish SIMM® version 2.8+2512. This version of the ISDA SIMM has updates that are based on the full recalibration of the model using historical data up to 31 December 2025....
ISDA Treasury Forum: Scott O'Malia Opening Remarks
ISDA Treasury Forum June 11, 2026 Opening Remarks Scott O’Malia, ISDA CEO Hello and welcome to the ISDA Treasury Forum. I’d like to start by thanking CME Group for working with us once again to make this event happen...
Launch of US Treasury Repo Market Indicators
ISDA has launched the ISDA-Actrix US Treasury Repo Market Clearing Indicators in collaboration with Actrix. The indicators illustrate central clearing adoption in the US Treasury repo market. Sponsored cleared repo volumes are used as a proxy to monitor client participation...
ISDA-Actrix US Treasury Clearing Indicators
This report provides indicators that illustrate central clearing adoption in the US Treasury repo market. Sponsored cleared repo volumes are used as a proxy to monitor client participation in central clearing, the key objective of the Securities and Exchange Commission's...
