On September 30, ISDA responded to Financial Conduct Authority (FCA) consultation CP24/14 on the derivatives trading obligation (DTO) and post-trade risk reduction services (PTRRS). ISDA welcomes the proposals, which continue the reforms started in the Wholesale Markets Review.

In the response, ISDA highlights its support for including certain overnight index swaps based on the US Secured Overnight Financing Rate within the classes of derivatives subject to the DTO and expanding the list of PTRRS exempted from the DTO and other obligations. ISDA welcomes the fact that the FCA clarifies its plans on how it intends to use its powers to suspend or modify the DTO after the end of 2024. ISDA asks that the FCA provide the industry with sufficient implementation time for the changes proposed and provide flexibility for PTRRS to evolve.