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
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
September 30, 2011
ISDA’s comment letter on Clearing Member Risk Management
Sent to – CFTC
NPR_Comment_CM_Risk_Management.pdf
September 26, 2011
ISDA and SIFMA’s Comments regarding Study on International Swap Regulation Mandated by Section 719(c) of the Dodd-Frank Wall Street Reform and Consumer Protection Act
Sent to – CFTC & SEC
CFTC-SEC_Intl_Study_--_FINAL_092611.pdf
September 9, 2011
Review of Swaps for Mandatory Clearing under Section 723 of Dodd-Frank
Letter to CFTC Commissioner Scott O'Malia
ISDA - Response Final Rule Mandatory Clearing.pdf
September 8, 2011
Joint Trade Association letter addressing the treatment of Inter-Affiliate Transactions under Title VII of the Dodd-Frank
Sent to – CFTC, SEC, Federal Reserve, OCC, FDIC, FHFA & FCA
Joint_Trade_Associations_Inter-Affiliate_Swaps_Treatment_Comment_Letter.pdf