International Swaps and Derivatives Association, Inc., Securities Industry and Financial Markets Association, and Institute of International Finance
ISDA, SIFMA, and IIFSupportAdvocacy
Summary: The International Swaps and Derivatives Association (ISDA), the Securities Industry and Financial Markets Association (SIFMA), and the Institute of International Finance (IIF) support the agencies' efforts to modernize the regulatory capital framework for large banking organizations. They argue that while the proposal is a constructive step forward, it requires specific adjustments to better align capital requirements with economic risk, particularly regarding cross-product netting, market risk, and CVA risk.
Attached is the joint comment letter from the International Swaps and Derivatives Association, Inc., the Securities Industry and Financial Markets Association and Institute of International Finance.