On March 6, ISDA submitted a response to the UK Financial Conduct Authority’s (FCA) consultation on improving transparency for bond and derivatives markets. In the response, ISDA recommends the framework be calibrated to allow for longer deferrals for larger trades and smaller real-time size thresholds for sterling swaps to avoid adverse effects on pricing, which would be detrimental to UK markets and investors. The response also includes recommendations on the categorization of over-the-counter derivatives, the role of trading venues and the FCA in the calibration of transparency requirements, improvements to the fields and flags for post-trade reporting and the definition of a systematic internalizer.