On September 26, ISDA and the FIA responded to the CFTC’s notice of proposed rulemaking on derivatives clearing organizations’ (DCOs) recovery and orderly wind-down plans.
The associations acknowledge that CCP recovery, resolution and wind-down planning is paramount to preserving financial stability. They also welcome the CFTC proposal, which is well-balanced as it outlines a comprehensive analysis for DCOs, while preserving the flexibility required to adapt to changing circumstances.
The response advocates for:
- A requirement to limit clearing members’ CCP exposures during recovery and resolution;
- Non-default losses to be borne by CCPs;
- Clearing participants incurring losses due to use of recovery measures should be fairly compensated via future CCP profit sharing;
- Clearing participants to be adequately involved in the design phase of such recovery and wind-down plans;
- Within their plans, DCOs to meticulously assess any potential impact of all measures (such as the use of specific recovery tools) on clearing participants and other stakeholders.
The response to the CFTC consultation can be found here.
Documents (1) for ISDA, FIA Respond to CFTC Consultation on DCO Recovery and Orderly Wind-Down
Latest
ISDA In Review – September 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in September 2026.
ISDA Digital Assets Forum Opening Remarks
ISDA Digital Assets Forum Washington, DC October 6, 2026 Opening Remarks Scott O’Malia, CEO, ISDA Good morning, and a very warm welcome to the ISDA Digital Assets Forum. Thanks for joining us today, and a special thank you to...
Assessing Tokenized MMFs as Eligible Collateral
Distributed ledger technology and digital assets have matured from their early stages to solutions capable of addressing longstanding inefficiencies in collateral management. Tokenized money market funds (TMMFs) represent a particularly promising area for the application of this technology, combining the...
Response to EC on Carbon Accounting
On October 5, ISDA responded to the Joint Research Centre (JRC) of the European Commission (EC) survey, drawing on input from five member firms across the banking, exchange and market-data sectors. The response highlighted broad support for internationally recognized carbon...
