ISDA Focus: 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.

Click here to learn about the Dodd-Frank Documentation Initiative and ISDA Amend.

Click here to visit the page for ISDA August 2012 Dodd-Frank Protocol Management.

Recent comment letters from ISDA are below.


DateTitle / DescriptionDocuments
November 23, 2010
Ownership Limitations & Governance Requirements for Security-Based Swap Clearing Agencies
Comment Letter to SEC
SEC-FMU-Conflicts-Letter-FINAL-112310.pdf
November 23, 2010
Determination of Foreign Exchange Swaps and Forwards
Comment Letter
UST-FX-Letter-112310.pdf
November 16, 2010
Mitigation of Conflicts of Interest
Comment Letter to CFTC
CFTC-NPR-Comment-Letter-111610.pdf
November 15, 2010
Offsetting of Derivatives Assets and Liabilities
Comment Letter
Netting-Letter.pdf
November 12, 2010
Reporting of Pre-enactment Swaps
Comment Letter to CFTC
ISDA-FIA-comment-letter-111210.pdf
October 27, 2010
Regulation of Agricultural Swaps
Comment Letter to CFTC & SEC
ISDA-Agricultural-Swap-ANPRM.pdf
October 22, 2010
Business Conduct Standards
Comment Letter to CFTC & SEC
SIFMA-and-ISDA-Comment-on-Business-Conduct-Standards.pdf
October 1, 2010
SEFs and Trading Determinations
Comment Letter to CFTC & SEC
Final-SEF-Letter-100110.pdf
September 20, 2010
Definitions Contained in Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Comment Letter to CFTC & SEC
Final-ANPR-definitions-Comment-092010.pdf
April 26, 2010
ISDA Response to IMF Report: Making Over-the-Counter Derivatives Safer
Comment Letter to IMF
IMF-Letter-Revised.pdf