ISDA and SIFMA urge CFTC to finalise reforms to swap conduct and documentation rules
The International Swaps and Derivatives Association (ISDA) and the Securities Industry and Financial Markets Association (SIFMA) have submitted a joint comment letter to the US Commodity Futures Trading Commission (CFTC) supporting its proposed revisions to business conduct and swap documentation requirements for swap dealers and major swap participants. Filed on 24 October 2025, the response welcomes the elimination of pre-trade mid-market mark and scenario analysis disclosures, which the associations say add little value and impose unnecessary burdens. It also backs permanent relief for intended-to-be-cleared and prime brokerage swaps, alignment with existing no-action relief, and greater flexibility in daily mark valuation. ISDA and SIFMA urge the CFTC to adopt the proposals swiftly to enhance regulatory certainty, market efficiency, and consistency with securities-based swap rules.