ISDA has responded to the Swiss Financial Market Supervisory Authority (FINMA) consultation on updated clearing requirements resulting from the transition away from IBORs. ISDA’s response highlights the following points:

• ISDA members are very supportive of central clearing;
• There should be a sufficient notice period for clearing participants (clearing members and their clients);
• Transactions stemming from post-trade risk reduction exercises should be exempt from the clearing obligation;
• ISDA members welcome the Swiss clearing obligations.