On October 20, ISDA submitted its response to a consultation by the International Organization of Securities Commissions (IOSCO) on risk mitigation standards for non-centrally cleared OTC derivatives. IOSCO developed these proposals in consultation with the Basel Committee on Banking Supervision and the Committee on Payments and Market Infrastructures. ISDA supports IOSCO’s intention to promote regulatory standards on risk mitigation techniques for non-cleared OTC derivatives that should be ‘sufficiently compatible across jurisdictions to limit regulatory arbitrage, maintain a level playing field and avoid situations where the same transactions are subject to conflicting rules’. This principle is of particular importance in OTC derivatives, the most global of financial instruments.