Home > ISDA Focus: Implementing Dodd-Frank

ISDA Focus: Implementing Dodd-Frank

The rule-making process and ISDA's views

ISDA supports regulatory efforts to increase the safety and soundness of financial and OTC derivatives markets. The Association has actively participated in the Dodd-Frank rule-making process by providing statistics, studies and comment letters to members of Congress, the SEC and the CFTC.

To listen to a recording of the May 10, 2011 ISDA Member Call: Update on US Regulatory Reform and see the accompanying slide presentation, please log in to the Members Portal.

To listen to a recording of the March 22, 2012 ISDA D/F Documentation Initiative Market Education Call and see the accompanying slide presentation, please log in to the Members Portal.

Recent comment letters from ISDA are below.


DateTitle / DescriptionDocuments
May 17, 2012
Treatment of Inter-affiliate Transactions
Letter to the Commodity Futures Trading Commission (CFTC) from ISDA and SIFMA regarding Treatment of Inter-affiliate Transactions
CFTC - Inter-affiliate clearing FINAL 51412.pdf
May 17, 2012
Procedures to Establish Appropriate Minimum Block Sizes for Large Notional Off-Facility Swaps and Block Trades
Letter to the Commodity Futures Trading Commission (CFTC) from ISDA and SIFMA regarding Procedures to Establish Appropriate Minimum Block Sizes for Large Notional Off-Facility Swaps and Block Trades
CFTC Proposed Rule - Block Sizes - ISDA Comment Letter.pdf
April 20, 2012
Uncleared Security-Based Swap Transactions Involving Eligible Contract Participants
Letter to the Securities and Exchange Commission (SEC) from ISDA and SIFMA.
0420 Uncleared SBS Comment Letter SIFMA ISDA (3).pdf
April 19, 2012
Extraterritorial legislation: the problems posed for markets, clients and regulators
Letter on extraterritoriality (ET) to US Treasury Secretary Geithner and EU Commissioner for Internal Markets and Services Barnier, from ISDA, GFMA, IBfed and Financial Services Roundtable.
Joint Trades ET Letter 19-4-2012.pdf
April 12, 2012
Prohibitions and Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Funds (“Volcker Rule”)
(CFTC)
ISDA - FINAL CFTC Volcker Rule Comment Letter 041212.pdf
February 13, 2012
Restrictions on Proprietary Trading and Certain Interests in, and Relationships with, Hedge Funds and Private Equity Funds
Comment letter sent to: Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation (FDIC) & Securities and Exchange Commission (SEC)
ISDA Comment Letter - Volcker Rule FINAL.pdf
February 13, 2012
Process for a Designated Contract Market or Swap Execution Facility to Make a Swap Available to Trade
Comment letter sent to: Commodity Futures Trading Commission (CFTC)
ISDA Comment Letter - MAT - Final.pdf
November 4, 2011
Joint Trade Association comment letter on the CFTC on its Proposed Compliance and Implementation Schedules
FIA-ISDA-SIFMA Comments on Swap Transaction Compliance and Implementation Schedule Proposals (RIN 3038AD60 3038AC96 3038AC97).pdf
October 3, 2011
Comment Letter: Notice of Proposed Rulemaking - Position Limits for Derivatives
Letter to Gary Gensler, Chairman of CFTC
CFTC - Position Limits - Hedging 100311.pdf
September 30, 2011
ISDA and FIA’s comment letter on Customer Clearing Documentation and Timing of Acceptance for Clearing
Sent to – CFTC
ISDA-FIA Response to Customer Clearing Documentation and Timing of Acceptance for Clearing NPR - FINAL 093011.pdf