Home > Dodd-Frank Documentation Initiative

Dodd-Frank Documentation Initiative

Click to jump to documents

May 13, 2013

ISDA March 2013 Dodd-Frank Protocol

Replay the webinar           Download the slides (PDF)

March 21, 2013

Are you Ready for May 1?
Complying with the CFTC’s External Business Conduct Rules

Replay the webinar           Download the slides (PDF)

By May 1, all counterparties must have provided their registered Swap Dealers with legal classifications and representations to allow the Swap Dealers to comply with the CFTC’s External Business Conduct Rule (EBCR). After the EBCR deadline, Swap Dealers will only continue offering and executing swaps with in-scope counterparties who have provided the necessary information for compliance.                         

ISDA has developed a standard documentation solution to ease some of the operational burdens of the process, and has partnered with Markit to provide an online tool for compliance. Broadly speaking, there are three steps to compliance which will be discussed during the webinar.

  • Applying for a CICI number from DTCC
  • Adhering to the August 2012 D-F Protocol through ISDA’s Protocol Management website
  • Completing the client questionnaire either via the ISDA Amend utility or another delivery mechanism

Speakers include:
Katherine Darras, General Counsel, Americas, ISDA
David Moss, Partner, Purrington Moody Weil LLP
Lauren Teigland-Hunt, Managing Partner at Teigland-Hunt LLP

May 1 is approaching quickly. Register for this webinar, and learn what your firm needs to do now to continue trading after that date.   

December 18, 2012
Extension of compliance dates: 

The CFTC provided interim final rules for swap dealers and major swap participants, extending the compliance date for various External Business Conduct provisions covered by the ISDA August D-F Protocol from January 1, 2013 until May 1, 2013. In addition, the interim final rules extend until July 1, 2013 the compliance dates for Commission regulations related to portfolio reconciliation and swap trading relationship documentation (documentation changes required by these rules will be contained in a second, soon to be published ISDA protocol). We encourage market participants to adhere to the ISDA August D-F Protocol and provide questionnaires to counterparties well in advance of the May 1 compliance deadline.



ISDA August 2012 Dodd-Frank Protocol

ISDA Adherence           

In order to facilitate implementation of Dodd-Frank rulemakings, ISDA is launching a series of protocols starting with the ISDA August 2012 Dodd-Frank Protocol, which is now open for adherence on the Protocols Management section of the website.

Legal Memorandum on ISDA DF Protocol and Extension of Compliance Date for EBC Rule. Verify your firrm has adhered on the Protocol Adherence page.

ISDA Amend in partnership with Markit

ISDA Amend

ISDA Amend, a joint service provided by Markit and ISDA, enables swap dealers and their clients to amend multiple ISDA Master Agreements easily and efficiently with a single online tool. All aspects of the questionnaire are now available online. Visit Markit's ISDA Amend webpage.

Get started with ISDA Amend on Markit’s sign-up page: http://www.markit.com/mcpm-sign-up

DTCC CICI Utility Portal

Visit the DTCC's CICI Utility Portal, and also see their comprehensive FAQ on the topic.

Dodd-Frank Documentation Initiative webinars

ISDA held a series of calls on the August 2012 D-F Protocol, the DTCC CICI Utility Portal and ISDA Amend By Markit. The entire series is on the Dodd-Frank Documentation Market Call Archive. Selected shorter clips are below (plays in a separate window):

August 2012 D-F Protocol

DTCC CICI Utility Portal

ISDA Amend by Markit


Dodd-Frank Initiative documents:


DateTitle / DescriptionDocuments
May 1, 2013
Safe Harbor letter for Non Special Entities
Safe Harbor Letter for Non Special Entities_May 1 2013.doc
May 1, 2013
Safe Harbor letter for ERISA Special Entities
Safe Harbor Letter for ERISA Special Entities_May 1 2013.doc
April 18, 2013
Safe Harbor letter for Non-ERISA Special Entities
Safe Harbor letter for Non ERISA Special Entities.doc
March 21, 2013
Six Weeks To Go – Are you Ready? Complying with the CFTC’s External Business Conduct Rules
Slides from the May 21 ISDA webinar. By May 1, all counterparties must have provided their registered Swap Dealers with legal classifications and representations to allow the Swap Dealers to comply with the CFTC’s External Business Conduct Rule (EBCR). After the EBCR deadline, Swap Dealers will only continue offering and executing swaps with in-scope counterparties who have provided the necessary information for compliance. With Katherine Darras, General Counsel, Americas, ISDA; David Moss, Partner, Purrington Moody Weil LLP; Lauren Teigland-Hunt, Managing Partner at Teigland-Hunt LLP.
ISDA EBCR combined 03-21 9am.pdf
March 18, 2013
ISDA Amend On Boarding and Questionnaire Timelines
Advisory note to highlight important upcoming dates occurring in advance of May 1, 2013.
ISDA Amend Notification.pdf
November 26, 2012
August D-F Protocol - CICI Update
On a recent ISDA call, DTCC provided the following update regarding the CICI utility which is relevant for the ISDA D-F August Protocol questionnaire submission, in addition to Part 43 and 45 reporting.
ISDA August DF Protocol - CICI Update_11-21-12.pdf
November 9, 2012
ISDA D/F Documentation Initiative - Addendum I to ISDA August 2012 DF Protocol Questionnaire
Supplement representations covered by the ISDA August 2012 DF Protocol Questionnaire regarding “eligible contract participant” categories that will become effective on December 31, 2012. The Addendum would be relevant to any party who is a “commodity pool” and who (a) relied upon the “Large Entity” or “Hedging Entity” categories prior to December 31, 2012 or (b) wishes to engage in certain FX transactions.
26820601_16_Addendum_I_to_August_Questionnaire.pdf
November 9, 2012
ISDA D/F Documentation Initiative – Annotation of the Questionnaire
26856234_5_August_Questionnaire_modified_for_Addendum_I.pdf
September 7, 2012
ISDA DF Protocol and Extension of Compliance Date for EBC Rule
ISDA Legal Department Memorandum
ISDA DF Protocol and Extension for EBC Rule - post.pdf
September 6, 2012
Implementation Webinar: ISDA's Protocol Management, DTCC's CICI Portal Utility, Markit's ISDA Amend
Slide presentation from the webinar.
ISDA Implementation Webinar deck FINAL (9 6 12).pdf
  • 1
  • 2