The International Swaps and Derivatives Association (ISDA) has responded to the Financial Conduct Authority's consultation paper CP25/28 on progressing fund tokenisation. The response focuses on using tokenised assets as collateral for both cleared and non-cleared derivatives, highlighting tokenisation's potential to improve risk management through accelerated collateral movement and facilitate 24/7 trading. ISDA emphasises the need to maintain risk management, legal enforceability and liquidity foundations from traditional markets when transitioning to distributed ledger technology for tokenised collateral.

The International Swaps and Derivatives Association (ISDA) has responded to the Financial Conduct Authority (FCA) consultation paper CP23/32 on improving transparency for bond and derivatives markets. ISDA recommends the framework be calibrated to allow for longer deferrals for larger trades and smaller real-time size thresholds for sterling swaps to avoid adverse effects on pricing, which would be detrimental to UK markets and investors.

The International Swaps and Derivatives Association (ISDA) has responded to the Financial Conduct Authority (FCA)’s consultation on the anti-greenwashing rule (AGR). ISDA highlights the potential negative effects that actual or perceived misrepresentation of sustainability features may have on investor and consumer perceptions of sustainable finance products and supports efforts aimed at bolstering trust in the market. ISDA also considers sustainability-linked derivatives, environmental, social and governance derivatives and voluntary carbon credits to be in the scope of the AGR. ISDA points out that the guidance is primarily retail-focused and recommends that future guidance include a wholesale focus, with examples relevant to the over-the-counter derivatives market.

The International Swaps and Derivatives Association (ISDA) has responded to the Financial Conduct Authority (FCA)'s consultation on sustainability disclosure requirements for portfolio management. ISDA supports the FCA’s approach to monitor developments and increase transparency around the use of derivatives in sustainable investing. ISDA also makes recommendations on the treatment of derivatives expected to be proposed by the European Union’s Platform on Sustainable Finance and highlights that it should be implemented consistently by the relevant authorities.

The International Swaps and Derivatives Association (ISDA) has responded to the Fixed Income Clearing Corporation’s (FICC) proposed changes to the Government Securities Division Rulebook. ISDA comments on the FICC’s proposal to amend its trade submission rules relating to mandatory clearing of certain US Treasury transactions.

The International Swaps and Derivatives Association (ISDA) has submitted its response to the Financial Stability Board’s (FSB) consultation on liquidity preparedness for margin and collateral calls. In its response ISDA highlights several considerations relevant to the non-bank financial intermediation (NBFI) sector’s liquidity preparedness for margin and collateral calls.

The International Swaps and Derivatives Association (ISDA) has responded to the International Organization of Securities Commissions (IOSCO)'s consultation on post-trade risk reduction services (PTRRS). Generally, ISDA supports IOSCO's review of the PTRRS landscape and proposed best practices. However, ISDA suggests that transactions resulting from PTRRS should be exempt from the clearing obligation as the effect on the mitigation of systemic risk is not applicable to these transactions.

The International Swaps and Derivatives Association (ISDA) has submitted its response to the joint Bank of England (BoE) and the Financial Conduct Authority (FCA) consultation on part two of the UK European Market Infrastructure Regulation (UK EMIR) Refit reporting Q&A and proposed validation rules.

The International Swaps and Derivatives Association (ISDA) has submitted a paper to the Financial Conduct Authority (FCA), proposing the use of unique product identifiers (UPI) for over-the-counter derivatives reporting under MIFIR. The paper, which complements ISDA's response to FCA’s discussion paper DP24/2, suggests that implementing UPI would require only minor modifications to transaction fields while still meeting the FCA's transparency requirements for MIFIR reporting.

The International Swaps and Derivatives Association (ISDA) has submitted an agenda request to the Financial Accounting Standards Board’s (FASB) Emerging Issues Task Force (EITF) seeking clarification on the application of Accounting Standards Codification (ASC) Topic 815, Derivatives and Hedging. ISDA asks the EITF to confirm that ASC 815 does not prohibit use of the spot method to assess hedge effectiveness for net investment hedges that are not ‘perfectly effective.’ The request, prompted by challenges in hedging foreign operations—such as using CNH derivatives for CNY exposures—proposes amending ASC 815-35-35-5 to permit recognition of excluded components in earnings when a hedge is highly effective and to replace references to ‘fair value’ with ‘value of the included component’ to clarify hedge accounting treatment for multinational companies.

The International Swaps and Derivatives Association (ISDA) submitted a paper to the European Securities and Markets Authority (ESMA), addressing the implementation of identifying reference data for over-the-counter (OTC) derivatives under the Markets in Financial Instruments Regulation (MIFIR) transparency requirements. The paper advocates for adopting the unique product identifier instead of retaining the International Securities Identification Number; arguing this would enhance transparency, improve consolidated tape effectiveness and align with international standards while reducing operational complexity.

The International Swaps and Derivatives Association (ISDA) has submitted its supplementary analysis to the European Securities and Markets Authority (ESMA) proposing cost savings for regulatory reporting. ISDA’s analysis, which is based on member questionnaire responses, serves as an addition to a joint response addressing ESMA's call for evidence on simplifying financial transaction reporting. Key cost-saving measures identified include distinguishing instruments between the European Market Infrastructure Regulation and the Markets in Financial Instruments Regulation frameworks, implementing single-sided reporting, and eliminating pairing and matching requirements.