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
August 27, 2012
Comment Letter on the Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act
Letter to the Commodity Futures Trading Commission (CFTC) regarding Cross-Border Guidance and Related Privacy Implications
Comment Letter - CFTC Reporting Obligations FINAL 082712.pdf
August 10, 2012
Proposed Interpretive Guidance and Policy Statement: Cross-Border Application of Certain Swaps Provisions of the Commodity Exchange Act (RIN 3038-AD57); Notice of Proposed Exemptive Order and Request for Comment (RIN 3038-AD85)
Letter to CFTC on Extraterritoriality (ET)
CFTC ISDA Comment - Cross-Border and Int Order FINAL 081012.pdf
July 3, 2012
CFTC Reporting Rules - Compliance Challenges
ISDA letter to CFTC on reporting obligations under Part 20, Part 43, Part 45 and Part 46 of the Code of Federal Regulations (CFR)
ISDA Reporting Challenges- 070312.pdf
June 29, 2012
ISDA-SIFMA Response to CFTC Proposed Rulemaking - Aggregation, Position Limits for Futures and Swaps
Comment Letter
ISDA SIFMA Aggregation Comment Letter.pdf
May 29, 2012
Aggregation, Position Limits for Futures and Swaps
Letter to the Commodity Futures Trading Commission (CFTC) from ISDA and SIFMA regarding Aggregation, Position Limits for Futures and Swaps
ISDA SIFMA Aggregation Comment Letter 2817 C F R  Part 151 Fed  Reg  3176829.pdf
May 29, 2012
Proposed Rulemaking Schedule of CFTC Title VII Rulemaking
Letter to the Commodity Futures Trading Commission (CFTC) from SIFMA and ISDA regarding Commissioner O’Malia’s Proposed Rulemaking Schedule
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