ISDA, SIFMA, GFXD and SIFMA AMG are requesting that US regulators provide clarification that covered swap entities and their counterparties that will become subject to the initial margin requirements of the Margin and Capital Requirements for Covered Swap Entities or the Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants as of September 1, 2019 (phase four) and on or after September 1, 2020 (phase five) do not have to comply with the documentation requirements described therein unless the bilateral IM amount exceeds $50 million.
Click on the attached PDF to read the letter.
Documents (1) for ISDA Letter to US Regulators on $50M IM Threshold and Documentation Requirement
Latest
ISDA Response to HMT, BoE on UK CCPs
On November 18, ISDA submitted its responses to the Bank of England (BoE) consultation on ensuring the resilience of central counterparties (CCPs) and the UK Treasury’s (HMT) two draft CCP statutory instruments (SIs). These consultations form part of the update...
Doubling Down on Appropriate Trading Book Capital
Throughout ISDA’s 40th anniversary year, we’ve been reflecting on the quest for greater consistency and efficiency that underpins everything we’ve achieved since 1985. It was at the heart of the original efforts to bring greater standardization to the nascent derivatives...
Determining Initial Reference Index for New Trades
On November 25, 2025, ISDA published a Market Practice Note (MPN) to recommend a specific methodology that market participants could elect to use for the purposes of determining the Initial Reference Index for certain new inflation derivative transactions given that...
ISDA Response to FCA on Fund Tokenization
On November 21, ISDA responded to the Financial Conduct Authority’s (FCA) consultation paper CP25/28 on progressing fund tokenization. In the response, ISDA focuses on the use of tokenized assets as both cleared and non-cleared derivatives collateral. Tokenization presents a significant...