Hard Brexit: An Impact Assessment for US Entities Registered with the CFTC

This paper highlights the issues that must be addressed in the case of a ‘hard’ Brexit. Specifically, it:

  • Identifies exiting US Commodity Futures Trading Commission (CFTC) equivalence determinations and no-action relief that is currently provided to the European Union (EU) and should be extended to entities registered with the CFTC in order to preserve continuity and market stability once the UK exits the EU.
  • Analyzes the impact of a hard Brexit on US market participants, and where appropriate, proposes regulatory and contractual solutions to minimize any negative impacts a hard Brexit would have on US market participants.

We note that Brexit discussions are ongoing and, based on developments, the regulatory and contractual approaches may change.

Click on the attached PDF to read the full document.

Documents (1) for Hard Brexit: An Impact Assessment for US Entities Registered with the CFTC

ISDA Omnibus Canadian Representation Letter

On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...

Joint Response on Cross-margining

On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...