In an August 26, 2015 letter to the Financial Times, a group of banking industry organizations, including ISDA, expressed concern that the Basel III leverage ratio framework operates inappropriately as applied to cleared derivatives. Basel III established a global leverage ratio for banks to determine how much regulatory capital they must hold against their exposures. This includes a leverage ratio for banks' cleared derivatives. (The ratio is currently being tested at 3% of exposure before it takes full effect in January 2017.)

The current Basel framework does not allow banks to account for collateral received by clients, leading to additional (unnecessary) exposure in calculating the leverage ratio. As noted by ISDA CEO Scott O'Malia, client cash collateral operates to reduce exposure of a bank's clearing business, which is not recognized by the leverage ratio. O'Malia warned that this could lead to banks exiting the clearing business, creating higher costs for users seeking to clear.

The letter is intended to push the Basel Committee to reevaluate these leverage ratio rules.