On September 11, ISDA submitted a letter in response to the US Department of the Treasury’s proposal to identify certain basket contract transactions as listed transactions. In the letter, ISDA argues that the proposed regulations would apply to many non-abusive transactions, would inappropriately take the place of substantive guidance and would generate compliance burdens and uncertainty for taxpayers.
Documents (1) for ISDA Letter to US Treasury Department on Listed Transactions
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ISDA Omnibus Canadian Representation Letter
On September 2, 2026, ISDA published the Omnibus Canadian Representation Letter (the “Omnibus Canadian Letter”), which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The...
ISDA-FIA Letter re CFTC-SEC X Margin/Port Margin
On August 31, ISDA and the Futures Industry Association (FIA) submitted a letter to the U.S. Commodity Futures Trading Commission (CFTC) and the U.S. Securities and Exchange Commission (SEC) on the agencies' Joint Request for Comment on Further Implementation of...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...
Response to SEC on FICC Guaranty Fund
On September 1, ISDA and FIA submitted a joint response to the US Securities and Exchange Commission (SEC), supporting the Fixed Income Clearing Corporation’s (FICC) proposal to establish a dedicated guaranty fund at its government securities division (GSD). FICC had...