North America

ISDA Comment Letter to CFTC Proposed Swap Execution Facilities and Trade Execution Requirement

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ISDA appreciates the opportunity to submit these comments on the proposed revisions to the regulations of swap execution facilities (SEFs) and the trade execution requirement published by the US Commodity Futures Trading Commission (CFTC) on November 30, 2018.

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Hard Brexit: An Impact Assessment for US Entities Registered with the CFTC

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This paper highlights the issues that must be addressed in the case of a ‘hard’ Brexit. Specifically, it:

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A Regulatory Safe Harbor for Derivatives

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A comprehensive and consistent regulatory framework for the US derivatives market is an important objective from public policy, risk mitigation and market liquidity perspectives. However, due to differences in the timing and substance of the rules implemented and/or proposed by the two primary US markets regulators – the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) – this objective is not being achieved.

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A Regulatory Safe Harbor for Derivatives

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A comprehensive and consistent regulatory framework for the US derivatives market is an important objective from public policy, risk mitigation and market liquidity perspectives. However, due to differences in the timing and substance of the rules implemented and/or proposed by the two primary US markets regulators – the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) – this objective is not being achieved.

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