On May 14, 2025, the Investment Industry Association of Canada (IIAC) delivered a response to the British Columbia Securities Commission (BCSC) on proposed amendments to National Instrument 94-101, Mandatory Central Counterparty Clearing of Derivatives (NI 94-101).The proposed amendments are intended to reflect transition away from interbank benchmarks and adoption of overnight risk-free interests rate benchmarks. Generally, the amendments encourage harmonization with other jurisdictions and mirror the amendments that were proposed by other Canadian Securities Administrators (CSA) members in September 2024.

The IIAC’s response includes the following issues:

(a) The BCSC and CSA’s emphasis on international harmonization but divergence from the maturity ranges for overnight index swaps found in the US Commodity Futures Trading Commission (“CFTC”) regulations; and

(b) The lack of data to support the addition of single-name credit default swaps to the list of mandatory clearable derivatives found in Appendix “A” of NI 94-101.