On October 29, ISDA responded to the Securities Exchange Commission’s (SEC) notice of proposed rulemaking (NPR).
With the central role governance plays in a clearing agency’s risk management, we believe this NPR is very timely and will improve governance and risk management of these entities. We, however, believe that this NPR is only the beginning and would welcome further improvements in CCP governance.
We are generally very supportive of this NPR. Risk Management Committees (RMCs), Risk Working Groups and the obligation to formally consider stakeholders viewpoints will facilitate effective oversight by the Commission. RMCs are good practice in many central counterparties (CCPs) and are already required by regulation in many other jurisdictions. We, therefore, welcome codification of such governance bodies as proposed by this NPR.
We are also very supportive of the SEC’s thoughts about CCP’s board obligation to oversee service providers for critical services.
ISDA notes that the proposals in the NPR should be considered as a starting point in enhancing the regulatory framework for CCPs. There are several other important issues related to clearing agencies in which further regulatory action is warranted, including emergency powers, margin adequacy, transparency and CCP capital.
Documents (1) for ISDA Responds to SEC on CCP Governance
Latest
Response to MAS on Treatment of Crypto Assets
On May 15, ISDA and the Asia Securities Industry and Financial Markets Association submitted a joint response to the Monetary Authority of Singapore’s (MAS) consultation, published in April 2026, on the prudential treatment of crypto assets on permissionless blockchains, welcoming MAS’s more...
Joint Response to EC on Market Risk Delegated Act
ISDA and the Association for Financial Markets in Europe (AFME) have responded to the European Commission’s (EC) consultation on the draft legal text of the upcoming market risk delegated act. The associations welcome the ongoing efforts to address the implementation...
ISDA/ASIFMA/GFXD Letter to RBI on INR-Denominated FX Derivatives Reporting
On March 9, 2026, ISDA, ASIFMA, and GFXD submitted a joint letter to the Reserve Bank of India (RBI) in response to the RBI’s Reporting Instructions for Authorised Dealer (AD) Category – I Banks draft directions to mandate the reporting...
IRD Trading Activity FY 2025 and Q4 2025
This report analyzes interest rate derivatives (IRD) trading activity reported in Europe. The analysis is based on transactions publicly reported by 30 European approved publication arrangements (APAs) and trading venues (TVs). Key highlights for the full year 2025 include: European...
