On March 21, ISDA, the Institute of International Bankers (IIB) and the Securities Industry and Financial Markets Association (SIFMA) submitted comment letters to the Securities and Exchange Commission (SEC) on three proposed security-based swaps (SBS) rules under the Securities Exchange Act of 1934: 1. Proposed Rule 15Fh-4(c) Prohibition Against Undue Influence over Chief Compliance Officers, 2. Proposed Rule 10B-1 Position Reporting of Large Security-Based Swap Positions and 3. Proposed Rule 9J-1 Prohibition Against Fraud, Manipulation or Deception in Connection with Security-Based Swaps.
Documents (3) for ISDA/SIFMA/IIB SBS Comment Letters to SEC
Latest
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...
ISDA Requests FASB to Consider ASC 815
On November 19, ISDA submitted a request to the Emerging Issues Task Force (EITF) of the Financial Accounting Standards Board (FASB) to clarify whether FASB Accounting Standards Codification (ASC) 815 does not prohibit using the spot method to assess hedge...
ISDA Response to CFTC Tokenized Collateral and Stablecoin Initiative
ISDA has responded to the CFTC’s Request for Input on the Tokenized Collateral and Stablecoin Initiative, offering perspectives on how tokenization and GENIUS Act–compliant payment stablecoins might contribute to more efficient and resilient collateral practices in derivatives markets. The letter...