ISDA, SIFMA and IIF
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) submitted a joint comment supporting the agencies' efforts to modernize and improve the risk sensitivity of the regulatory capital framework. While they support the general direction of the proposal, they provide specific technical recommendations to better align capital requirements with economic risk, improve consistency across rules, and reduce operational burdens.
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.