ISLA Responses to Recent Consultations

Advocacy is an extremely important part of the Association’s work, and since the start of January 2022, ISLA has responded to a number of key consultations on behalf of its member firms across the region.


On 7 January 2022, ISLA wrote to the Securities and Exchange Commission (SEC) regarding its proposed Exchange Act Rule 10c-1 (Proposal 17 CFR Part 240 [Release No. 34-93613; File No. S7-18-21]).

In the letter, ISLA informed the SEC of questions and challenges members have raised in response to the proposal, including suggested regulatory reporting timeframes and further clarification on the scope of the proposal.

ISLA also included comments on relevant conclusions drawn from the European Union’s Securities Finance Transaction Regulation (SFTR) and emphasised the benefits of establishing market derived data standards before setting regulatory reporting requirements.

ISLA welcome further discussion with the SEC and are keen to support improving market transparency.

To view ISLA’s response click here.

Sustainability Disclosure Requirements (SDR)

On 7 January 2022, ISLA wrote to the Financial Conduct Authority (FCA) regarding their Discussion Paper 21/4 on Sustainability Disclosure Requirements (SDR) and Investment Labels.

In the letter, ISLA emphasised the importance of distinguishing between direct investments and investment tools when defining the criteria for sustainable investment labelling and disclosures. ISLA also highlighted the ways in which securities lending can significantly contribute towards sustainability objectives of investment managers.

Additionally, ISLA requested clarification from the FCA regarding ESG collateral guidelines, highlighting the unintended consequences of narrowing collateral schedules if acceptability is limited.

ISLA would welcome guidance from the FCA regarding responsible investment compatibility for products such as securities lending.

To view ISLA’s response click here.

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