ISDA offered additional guidance on documentation
for the OTC derivatives market in the event of a "no
deal" Brexit.
ISDA stated that the earliest date on which a "no
deal" Brexit could occur is October 31, 2019. However, Brexit
could be delayed if (i) the UK government approves the withdrawal
agreement and it is implemented in both the United Kingdom and the
European Union, (ii) the United Kingdom proposes extending the
two-year withdrawal period under certain provisions of the Treaty
of the European Union ("TEU") and the European Council
agrees to the extension, or (iii) the United Kingdom rescinds the
provision under the TEU allowing for an extension.
The ISDA FAQs address: